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Alior Bank S.A.

AGM Information May 20, 2025

5492_rns_2025-05-20_55e4ee2c-ee9a-4bc4-8fb2-9e513bd9447e.pdf

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Draft resolutions to be adopted by the Annual General Meeting of Alior Bank S.A. convened for 16 June 2025

Regarding item 2 of the agenda

Resolution No. _/2025 of the Annual General Meeting of Alior Bank Spółka Akcyjna dated 16 June 2025

on: appointment of the Chairperson of the Annual General Meeting of the Bank.

§ 1

Pursuant to Article 409 § 1 of the Code of Commercial Partnerships and Companies and § 16(1) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank elects __________________ to act as the Chairperson of the Annual General Meeting.

§ 2

The resolution shall enter into effect upon its adoption.

Justification of the Resolution of the Annual General Meeting concerning the election of the Chairperson of the Annual General Meeting of the Bank

In accordance with Article 409 § 1 of the Code of Commercial Partnerships and Companies, the chairperson is elected from among those entitled to participate in the general meeting. Pursuant to § 28 of the Rules of Procedure of the General Meeting of Shareholders of Alior Bank Spółka Akcyjna (hereinafter referred to as the "Rules of Procedure of the Bank's General Meeting"), the General Meeting is opened by the Chairperson of the Supervisory Board or one of their Deputies, after which the Chairperson of the General Meeting is elected from among the participants. Should none of the aforementioned individuals be able to open the General Meeting, it shall be opened by the President of the Management Board or a person appointed by the Management Board. The election of the Chairperson of the General Meeting of Shareholders of the Bank shall be conducted by secret ballot. The person opening the General Meeting shall supervise the proper conduct of the voting and announce its results. Every participant of the General Meeting has the right to stand as a candidate for Chairperson as well as to nominate one candidate for this position.

Regarding item 4 of the agenda

Resolution No. _/2025 of the Annual General Meeting of Alior Bank Spółka Akcyjna dated 16 June 2025

on: adoption of the agenda of the Annual General Meeting of the Bank.

§ 1

The Annual General Meeting of the Bank adopts the following agenda:

    1. Opening of the Annual General Meeting.
    1. Election of the Chairperson of the Annual General Meeting.
    1. Verification whether the Annual General Meeting has been convened correctly and is capable of adopting binding resolutions.
    1. Adoption of the agenda of the Annual General Meeting.
    1. Presentation and review of the following:
    2. a) The Financial statements of Alior Bank Spółka Akcyjna for the year ended 31 December 2024,
    3. b) The Consolidated financial statements of the Alior Bank Spółka Akcyjna Group for the year ended 31 December 2024,
    4. c) Report of the Management Board on the activities of the Alior Bank S.A. Capital Group in 2024 comprising the report of the Management Board on the activities of Alior Bank S.A. and the Statement on Sustainable Development.
    1. Presentation and review of the Report on the activities of the Supervisory Board of Alior Bank Spółka Akcyjna in the financial year ended 31 December 2024.
    1. Presentation to the Annual General Meeting of the list of amendments made to the Regulations of the Supervisory Board of Alior Bank Spółka Akcyjna.
    1. Presentation to the Annual General Meeting of the Report on the assessment of the application by Alior Bank Spółka Akcyjna of the Corporate Governance Principles for Supervised Institutions in the year 2024.
    1. Adoption of resolutions on:
    2. a) review and approval of the Report on the activities of the Supervisory Board of Alior Bank Spółka Akcyjna in the financial year ended 31 December 2024,
    3. b) review and approval of the Financial statements of Alior Bank Spółka Akcyjna for the year ended 31 December 2024,
    4. c) review and approval of the Consolidated financial statements of the Alior Bank Spółka Akcyjna Group for the year ended 31 December 2024,
    5. d) review and approval of the Report of the Management Board on the activities of the Alior Bank S.A. Capital Group in 2024 comprising the report of the Management

Board on the activities of Alior Bank S.A. and the Statement on Sustainable Development.

    1. Adoption of a resolution on the distribution of the profits of the Bank for the financial year 2024.
    1. Adoption of resolutions on granting discharge to Members of the Management Board of the Bank for the performance of their duties in the financial year 2024.
    1. Adoption of resolutions on granting discharge to Members of the Supervisory Board of the Bank for the performance of their duties in the financial year 2024.
    1. Adoption of a resolution on the position of the Annual General Meeting of the Bank regarding the assessment of the functioning of the remuneration policy in effect at the Bank.
    1. Adoption of a resolution on the adoption of the updated "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A.".
    1. Adoption of a resolution on the assessment of the collective suitability of the Supervisory Board of Alior Bank S.A.
    1. Adoption of a resolution on expressing an opinion on the "Report on the remuneration of members of the Management Board and the Supervisory Board of Alior Bank S.A. for the year 2024" submitted by the Supervisory Board of the Bank.
    1. Adoption of a resolution on the assessment of the adequacy of internal regulations concerning the functioning of the Supervisory Board of Alior Bank S.A. and its effectiveness.
    1. Adoption of a resolution amending the Articles of Association of Alior Bank S.A.
    1. Closure of the Annual General Meeting.

§ 2

The resolution shall enter into effect into upon its adoption.

Justification of the Resolution of the Annual General Meeting of the Bank on the adoption of the agenda of the Annual General Meeting

The General Meeting proceeds in accordance with the adopted agenda. The agenda contained in the draft resolution was proposed by the Management Board of the Bank. Pursuant to Article 404 § 1 of the Code of Commercial Partnerships and Companies, no resolution may be adopted on matters not included in the agenda unless the entire share capital is represented at the General Meeting and no participant raises an objection to the resolution being adopted. In accordance with § 31(3)(2) of the Rules of Procedure of the Bank's General Meeting, it is the specific responsibility of the Chairperson of the General Meeting to present the published agenda of the General Meeting.

on: review and approval of the Report on the activities of the Supervisory Board of Alior Bank Spółka Akcyjna in the financial year ended 31 December 2024,

§ 1

Pursuant to Article 382 § 3 of the Code of Commercial Partnerships and Companies and § 23(2)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank, following review, approves the Report on the activities of the Supervisory Board of Alior Bank Spółka Akcyjna in the financial year ended 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the Resolution of the Annual General Meeting of the Bank on review and approval of the Report on the activities of the Supervisory Board of Alior Bank Spółka Akcyjna in the financial year ended 31 December 2024

In accordance with Article 382 § 3 of the Code of Commercial Partnerships and Companies, the specific responsibilities of the supervisory board include the evaluation of reports referred to in Article 395 § 2(1) of the Code, in terms of their conformity with the books, documents, and actual state of affairs, as well as the assessment of the management board's proposals regarding the allocation of profit or coverage of loss. Furthermore, the supervisory board is required to prepare and submit to the General Meeting an annual written report on its activities for the past financial year (the supervisory board report). Pursuant to Article 395 § 5 of the Code of Commercial Partnerships and Companies, the agenda of the Annual general meeting may also include consideration and approval of the consolidated financial statements of the capital group as defined under accounting regulations, in addition to the matters specified in § 2 of the aforementioned Article.

Accordingly, the Supervisory Board of the Bank has prepared the above Report and recommends its approval.

on: review and approval of the financial statements of Alior Bank Spółka Akcyjna for the year ended 31 December 2024

§ 1

Pursuant to Article 395 § 2(1) of the Code of Commercial Partnerships and Companies and § 17(1)(1)(a) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank, following review, approves the financial statements of Alior Bank Spółka Akcyjna for the year ended 31 December 2024, comprising:

  • − the statement of financial position as at 31 December 2024, presenting total assets and liabilities of PLN 93,038,466 thousand,
  • − the income statement for the period from 1 January 2024 to 31 December 2024, showing a net profit of PLN 2,417,499 thousand,
  • − the statement of comprehensive income for the period from 1 January 2024 to 31 December 2024, showing total comprehensive income of PLN 2,509,841 thousand,
  • − the statement of changes in equity for the financial year from 1 January 2024 to 31 December 2024, indicating an increase in equity of PLN 1,932,793 thousand,
  • − the statement of cash flows for the period from 1 January 2024 to 31 December 2024, showing a decrease in cash and cash equivalents of PLN 410,501 thousand,
  • − additional notes and explanations.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the review and approval of the financial statements of Alior Bank Spółka Akcyjna for the year ended 31 December 2024

The subject of the proceedings of the Annual General Meeting should be the review and approval of the financial statements for the previous financial year in accordance with Article 395 § 1 and § 2(1) of the Code of Commercial Partnerships and Companies, Article 53 (1) of the Accounting Act of 29 September 1994 and § 17(1)(1a) of the Articles of Association of Alior Bank Spółka Akcyjna (hereinafter: "Articles of Association of the Bank"). The annual financial statements must be approved by the Annual General Meeting no later than 6 months after the balance sheet date.

The Supervisory Board has issued a positive assessment of the financial statements of the Bank for the year ended 31 December 2024 and recommended that the Annual General Meeting of the Bank approve them.

on: review and approval of the consolidated financial statements of the Alior Bank Spółka Akcyjna Group for the year ended 31 December 2024.

§ 1

Pursuant to Article 395 § 5 of the Code of Commercial Partnerships and Companies and § 17(1)(1)(b) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank, following review, approves the consolidated financial statements of the Alior Bank Spółka Akcyjna Capital Group for the year ended 31 December 2024, comprising:

  • − statement of financial position as at 31 December 2024, presenting total assets and liabilities of PLN 93,293,487 thousand,
  • − income statement for the period from 1 January 2024 to 31 December 2024, showing a net profit for the Capital Group of PLN 2,445,022 thousand,
  • − statement of comprehensive income for the period from 1 January 2024 to 31 December 2024, showing total comprehensive income of PLN 2,537,301 thousand,
  • − statement of changes in equity for the financial year from 1 January 2024 to 31 December 2024, indicating an increase in equity of PLN 1,957,129 thousand,
  • − statement of cash flows for the period from 1 January 2024 to 31 December 2024, showing a decrease in cash of PLN 415,908 thousand,
  • − additional notes and explanations.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the review and approval of the Consolidated Financial Statements of the Alior Bank Spółka Akcyjna Group for the year ended 31 December 2024

The subject of the proceedings of the Annual General Meeting should be the review and approval of the consolidated financial statements of the capital group for the previous financial year in accordance with Article 395 § 5 of the Code of Commercial Partnerships and Companies, Article 63c(4) of the Accounting Act of 29 September 1994, and § 17(1)(1b) of the Articles of Association of the Bank. The annual consolidated financial statements must be approved by the Annual General Meeting no later than 6 months after the balance sheet date.

The Supervisory Board of the Bank has issued a positive assessment of the consolidated financial statements of the Capital Group for the year ended 31 December 2024 and recommended that the Annual General Meeting of the Bank approve them.

on: review and approval of the Report of the Management Board on the activities of the Alior Bank S.A. Capital Group in 2024 comprising the report of the Management Board on the activities of Alior Bank S.A. and the Statement on Sustainable Development.

§ 1

Pursuant to Article 395 § 2(1) of the Code of Commercial Partnerships and Companies and § 17(1)(1)(a–c) of the Articles of Association of Alior Bank S.A., in conjunction with Article 55(2a) and subsequent provisions of the Accounting Act of 29 September 1994, the Annual General Meeting of the Bank, following review, approves the Report of the Management Board on the activities of the Alior Bank S.A. Capital Group in 2024, including the Report of the Management Board on the activities of Alior Bank S.A. and the Statement on Sustainable Development.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the review and approval of the Report of the Management Board on the activities of the Alior Bank S.A. Capital Group in 2024 comprising the report of the Management Board on the activities of Alior Bank S.A. and the Statement on Sustainable Development.

The subject of the proceedings of the Annual General Meeting should be the review and approval of the report of the Management Board on the company's activities as well as the report on the activities of the capital group, pursuant to Article 395 § 2(1) of the Code of Commercial Partnerships and Companies. Furthermore, under Article 395 § 1 and § 2(1) of the Code of Commercial Partnerships and Companies, in conjunction with Article 55(2a) and subsequent provisions and Article 63r(1) of the Accounting Act of 29 September 1994, such report is subject to approval by the Annual General Meeting no later than six months after the balance sheet date.

The Supervisory Board of the Bank has assessed the Report of the Management Board on the activities of the Alior Bank S.A. Capital Group in 2024 comprising the report of the Management Board on the activities of Alior Bank S.A. and the Statement on Sustainable Development, and has recommended its approval to the Annual General Meeting of the Bank.

Regarding item 10 of the agenda

Resolution No. _/2025 of the Annual General Meeting of Alior Bank Spółka Akcyjna dated 16 June 2025

on: allocation of the profit for the financial year 2024.

§ 1

Pursuant to Article 395 § 2(2) of the Code of Commercial Partnerships and Companies and § 17(1)(2) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank resolves that the net profit of the Bank for the financial year 2024, in the total amount of 2,417,499,553.87 PLN (in words: in words: two billion four hundred seventeen million four hundred ninety nine thousand five hundred fifty three zlotys and 87/100), shall be allocated as follows:

  • 1) part of the profit, amounting to 1,199,791,177.29 PLN (in words: in words: one billion one hundred ninety-nine million seven hundred ninety-one thousand one hundred seventy-seven zlotys and 29/100), shall be distributed as a dividend,
  • 2) the remaining part of the profit, amounting to 1,217,708,376.58 PLN (in words: one billion two hundred seventeen million seven hundred eight thousand three hundred seventy six zlotys and 58/100), shall be allocated to the reserve capital, including the undistributable profit earned from the activities of the Housing Savings Fund in the amount of 17,136,562.53 PLN (in words: seventeen million one hundred thirty six thousand five hundred sixty two zlotys and 53/100).

§ 2 The dividend per share shall amount to 9.19 PLN (in words: nine zlotys and 19/100).

§ 3 The dividend record date shall be set for 30 June 2025.

§ 4 The dividend payment date shall be set for 14 July 2025.

§ 5 The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the allocation of the profit for the financial year 2024

The agenda of the Annual General Meeting should include the adoption of a resolution on the allocation of profit or coverage of loss pursuant to Article 395 § 2(2) of the Code of Commercial Partnerships and Companies and § 17(1)(2) of the Articles of Association of the Bank.

The profit allocation proposed by the Management Board of the Bank for the financial year 2024 takes into account:

  • the current economic and financial position of the Bank and the Group, as well as the Bank's and the Group's strategy and resulting development plans and changing capital requirements,
  • the risk strategy aimed at ensuring capital security for the Bank and the Group, i.e. maintaining the Tier 1 ratio, capital adequacy ratio, and internal capital coverage ratio at levels not lower than those required under supervisory regulations and internal minimum thresholds, considering Article 26(2) of the CRR Regulation and Article 2 of the Own Funds Regulation,
  • the recommendations of the Polish Financial Supervision Authority (KNF),
  • the KNF's positions on the dividend policy for financial institutions, including the Individual recommendation of the Polish Financial Supervision Authority regarding the payment of dividends for 2024 dated 13 March 2025,
  • the limitations arising from the Act on Macroprudential Supervision,
  • the guidelines of the Bank Guarantee Fund (BFG) regarding MREL limits,
  • the applicable provisions of the Code of Commercial Partnerships and Companies, in particular Article 348 § 1, which provides that the amount allocated for distribution among shareholders may not exceed the profit for the last financial year, increased by retained earnings from previous years and amounts transferred from reserve and supplementary capitals created from profit which may be allocated to dividend distribution; this amount must be reduced by uncovered losses, treasury shares and amounts that, pursuant to law or the Articles of Association, must be allocated from profit for the last financial year to reserve or supplementary capital,
  • the principles set forth in the Best Practice for GPW Listed Companies, in particular principle 4.14,
  • the macroeconomic situation and the conditions on the financial markets in Poland and globally,
  • Art. 5 sec. 5 of the Act of 26 October 1995 on social forms of housing development, according to which the surplus of collected funds over due liabilities of the housing fund resulting from contractual credit agreements may be allocated for the purpose specified in this Article.

The Supervisory Board of the Bank issued a positive opinion on the proposal of the Management Board concerning the allocation of the Bank's profit for the financial year 2024.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Piotr Krzysztof Żabski discharge for the performance of his duties as Vice-President of the Management Board of the Bank acting as the Chair of the Management Board during the period from 1 November 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Marcin Mieczysław Ciszewski discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 November 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Jacek Michał Iljin discharge for the performance of his duties:

  • as Vice-President of the Management Board of the Bank acting as the Chair of the Management Board from 15 August 2024 to 31 August 2024,

  • as Vice-President of the Management Board of the Bank from 1 September 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Wojciech Przybył discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 October 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Zdzisław Adam Wojtera discharge for the performance of his duties:

  • as Vice-President of the Management Board of the Bank acting as the Chair of the Management Board from 1 September 2024 to 31 October 2024,

  • as Vice-President of the Management Board of the Bank from 1 November 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Radomir Gibała discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 January 2024 to 31 August 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Tomasz Miklas discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 January 2024 to 19 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Grzegorz Olszewski discharge for the performance of his duties as President of the Management Board of the Bank during the period from 1 January 2024 to 15 May 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Paweł Władysław Broniewski discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 January 2024 to 15 May 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Szymon Stefan Kamiński discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 January 2024 to 15 May 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Rafał Gedymin Litwińczuk discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 January 2024 to 15 May 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Paweł Leszek Tymczyszyn discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 January 2024 to 15 May 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Jacek Polańczyk discharge for the performance of his duties as Vice-President of the Management Board of the Bank during the period from 1 January 2024 to 15 May 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Management Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

on: granting discharge to a Member of the Supervisory Board of the Bank delegated to temporarily perform the duties of the Vice-President of the Bank's Management Board for the performance of duties in the financial year 2024.

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Artur Chołody discharge for the performance of his duties:

  • as Member of the Supervisory Board of the Bank delegated to temporarily perform the duties of the Vice-President of the Bank's Management Board acting as Chair of the Management Board for the period from 15 May 2024 to 14 August 2024

  • as Member of the Supervisory Board of the Bank delegated to temporarily perform the duties of the Vice-President of the Bank's Management Board for the period from 18 November 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to the Member of the Supervisory Board of the Bank delegated to temporarily perform the duties of the Vice-President of the Bank's Management Board in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

Accordingly, it is necessary to present this draft resolution for consideration by the Annual General Meeting of the Bank.

The Bank's Supervisory Board adopted a resolution to recommend to the Annual General Meeting of the Bank to grant discharge to the above member of the Supervisory Board of the Bank delegated to temporarily perform the duties of the Vice-President of the Bank's Management Board on account of the performance of his duties in the financial year 2024.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Jan Paweł Zimowicz discharge for the performance of his duties:

  • as Member of the Supervisory Board of the Bank during the period from 26 April 2024 to 31 December 2024, and

  • as Deputy Chairperson of the Supervisory Board of the Bank during the period from 7 May 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Artur Jarosław Kucharski discharge for the performance of his duties as Member of the Supervisory Board of the Bank during the period from 26 April 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Maciej Jacek Gutowski discharge for the performance of his duties as Member of the Supervisory Board of the Bank during the period from 26 April 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Radosław Grabowski discharge for the performance of his duties as Member of the Supervisory Board of the Bank during the period from 26 April 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Robert Pusz discharge for the performance of his duties as Member of the Supervisory Board of the Bank during the period from 17 April 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17 (1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank grants discharge to Mr Filip Aleksander Majdowski for the performance of his duties as Member and Chairperson of the Supervisory Board of the Bank during the period between 1 January 2024 and 7 March 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Ernest Gerard Bejda discharge for the performance of his duties:

  • as Member of the Supervisory Board of the Bank from 1 January 2024 to 26 April 2024,

  • as Deputy Chairperson of the Supervisory Board of the Bank from 1 January 2024 to 18 March 2024, and

  • as Chairperson of the Supervisory Board of the Bank from 18 March 2024 to 26 April 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Paweł Wojciech Knop discharge for the performance of his duties:

  • as Member of the Supervisory Board of the Bank from 1 January 2024 to 26 April 2024, and - as Deputy Chairperson of the Supervisory Board of the Bank from 18 March 2024 to 26 April 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Marek Pietrzak discharge for the performance of his duties as a Member of the Supervisory Board of the Bank for the period from 1 January 2024 to 26 April 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Dominik Mikołaj Witek discharge for the performance of his duties as a Member of the Supervisory Board of the Bank for the period from 1 January 2024 to 26 April 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Ms Małgorzata Erlich-Smurzyńska discharge for the performance of her duties as a Member of the Supervisory Board of the Bank for the period from 1 January 2024 to 26 April 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Jacek Paweł Kij discharge for the performance of his duties as a Member of the Supervisory Board of the Bank for the period from 1 January 2024 to 26 April 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Jarosław Jerzy Mastalerz discharge for the performance of his duties:

  • as Member of the Supervisory Board of the Bank from 26 April 2024 to 6 November 2024, and

  • as Chairperson of the Supervisory Board of the Bank from 7 May 2024 to 6 November 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Artur Chołody discharge for the performance of his duties as a Member of the Supervisory Board of the Bank for the period from 27 April 2024 to 14 May 2024 and for the period from 15 August 2024 to 17 November 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Paweł Augustyn Wajda discharge for the performance of his duties:

  • as Member of the Supervisory Board of the Bank from 27 November 2024 to 31 December 2024, and

  • as Chairperson of the Supervisory Board of the Bank from 19 December 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: granting discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

§ 1

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies and § 17(1)(3) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank hereby grants Mr Rafał Tadeusz Janczura discharge for the performance of his duties as Member of the Supervisory Board of the Bank during the period from 17 April 2024 to 31 December 2024.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the resolution of the Annual General Meeting of the Bank on the granting of discharge to a Member of the Supervisory Board of the Bank for the performance of duties in the financial year 2024

Pursuant to Article 395 § 2(3) of the Code of Commercial Partnerships and Companies, the agenda of the Annual General Meeting should include the granting of discharge to members of the company's governing bodies in respect of the performance of their duties.

on: the position of the Annual General Meeting of the Bank regarding the assessment of the functioning of the remuneration policy in effect at the Bank.

§ 1

Pursuant to Article 28(4) of the "Corporate Governance Principles for Supervised Institutions" in the wording adopted by Resolution No. 218/2014 of the Polish Financial Supervision Authority of 22 July 2014, taking into account the "Report of the Supervisory Board on the assessment of the functioning of the Remuneration Policy in effect at Alior Bank S.A. in the year 2024", as submitted by the Supervisory Board of the Bank, the Annual General Meeting of the Bank states that the remuneration policy in force at the Bank fosters growth and ensures security of the Bank's operations.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the Resolution of the Annual General Meeting of the Bank on the position of the Annual General Meeting of the Bank regarding the assessment of the functioning of the remuneration policy in effect at the Bank

Pursuant to § 28(3) of the Corporate Governance Principles for Supervised Institutions issued by the Polish Financial Supervision Authority, the supervisory body is required to prepare and submit to the governing body an annual report on the assessment of the functioning of the remuneration policy in the supervised institution.

Accordingly, the Supervisory Board of the Bank carried out an assessment of the functioning of the Bank's remuneration policy in 2024. The results of this assessment were presented in the "Report of the Supervisory Board on the Assessment of the Functioning of the Remuneration Policy at Alior Bank S.A. in 2024".

In accordance with § 28(4) of the Corporate Governance Principles for Supervised Institutions, the governing body shall assess whether the adopted remuneration policy supports the development and operational security of the supervised institution.

In 2024, the remuneration policy was implemented at the Bank in line with the assumptions of the internal regulations in force. The policy complied with generally applicable legal regulations, the guidelines of the competent supervisory authorities, and was consistent with ethical conduct principles and the Bank's values. The Management Board of the Bank made efforts to ensure that the remuneration policy reflected the Bank's adopted business strategy. The actions undertaken in this area in 2024 aimed to ensure long-term value growth for shareholders and the stable operation of the Bank. They were consistent with the provisions and objectives of the Bank's internal regulations and ensured gender neutrality of the remuneration policy. The Bank's development and security were supported by remuneration systems aligned with the interests of the Bank's customers, shareholders, and employees.

The Supervisory Board has a positive assessment of the functioning of the remuneration policy at the Bank in 2024.

on: adoption of the updated "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A.".

Pursuant to § 17 (2)(11) of the Articles of Association of Alior Bank S.A. in conjunction with Article 22aa of the Act of 29 August 1997 – Banking Law, the Annual General Meeting of the Bank resolves as follows:

§ 1

The Annual General Meeting approves the "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A." in the wording specified in Appendix 1 to this resolution.

§ 2

The resolution shall enter into effect into upon its adoption.

Justification of the Resolution of the Annual General Meeting of the Bank on the adoption of the updated "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A."

The Supervisory Board of the Bank has approved the updated version of the regulation titled "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A.", which incorporates the guidelines of the Methodology for the Assessment of the Suitability of Members of the Governing Bodies of Supervised Entities (issued by the Polish Financial Supervision Authority), as well as the draft regulation published by the Ministry of Justice implementing the Women on Boards Directive concerning the improvement of gender balance among directors of listed companies. The General Meeting of the Bank, pursuant to § 17(2)(11) of the Articles of Association of Alior Bank S.A. in conjunction with Article 22aa of the Banking Law Act of 29 August 1997, adopts the updated "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A."

Appendix 1 to Resolution No. __/2025 of the Annual General Meeting of Alior Bank Spółka Akcyjna of 16 June 2025 on: approval of the updated "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A.".

POLICY OF SELECTION AND SUITABILITY ASSESSMENT OF SUPERVISORY BOARD MEMBERS OF ALIOR BANK S.A.

In order to assess whether the Supervisory Board Members meet the requirements referred to in Article 22aa of the Banking Law Act, the present "Policy of Selection and Suitability Assessment of Supervisory Board Members of Alior Bank S.A." ("Policy") is hereby adopted.

§ 1.

DEFINITIONS

Whenever the following terms or abbreviations are used in this Policy (including in Appendix 1 to the Policy), they shall be understood as follows:

Shareholder A shareholder of the Bank proposing a candidate for a Supervisory Board
Member before or during the General Meeting
Bank Alior Bank Spółka Akcyjna with its registered office in Warsaw
CRR Regulation No. 575/2013 of the European Parliament and of the Council
(EU) of 26 June 2013 on prudential requirements for credit institutions
and investment firms, amending Regulation (EU) No. 648/2012
Best Practice Code of Best Practice for WSE Listed Companies (adopted by a
resolution of the Stock Exchange Council)
PFSA Polish Financial Supervision Authority
Audit Committee Audit Committee of the Supervisory Board of the Bank
Nomination Committee Nomination and Remuneration Committee of the Supervisory Board of
the Bank
Expert Unit A person or organisational unit of the Bank responsible for the HR
substantive area appointed by the Nomination Committee
Methodology Methodology for assessing the suitability of members of the bodies of:
banks, protection scheme managers, insurance companies, reinsurance
companies, pension companies (KNF -
Polish Financial Supervision
Authority [PFSA])
Banking Law Act Banking Law Act of 29 August 1997
Supervisory Board Supervisory Board of the Bank
Recommendation Z Recommendation Z on the principles of internal governance in banks,
issued by the PFSA
Regulation concerning
the scope of tasks to be
performed by the
nomination committee
Regulation of the Minister of Finance of 7 May 2018 concerning the
detailed scope of tasks to be performed by the nomination committee at
major banks
Act on Expert Auditors the Act of 11 May 2017 on Statutory Auditors, Audit Firms and Public
Oversight
Act on Trading the Act of 29 July 2005 on Trading in Financial Instruments
Act on the Rules for
Obtaining Information
About the Criminal
Record
the Act of 12 April 2018 on the Rules for Obtaining Information About
the Criminal Record of persons applying for employment and persons
working in the financial sector
Act on the Principles of
Property Management
the Act of 16 December 2016 on the Principles of State Property
Management
General Meeting General Meeting of the Bank
Guidelines European Banking Authority guidelines on the assessment of the
suitability of members of the management body and of persons
performing key functions of 2 July 2021
Management Board Management Board of the Bank
PCG Principles of Corporate Governance for supervised institutions adopted
under the Resolution of the Polish Financial Supervision Authority of 22
July 2014

§ 2.

LEGAL BASIS

    1. This Policy has been adopted under:
    2. 1) Article 22 section 2 and 3 and Article 22a section 1 and 2 in conjunction with Article 22aa of the Banking Law Act,
    3. 2) Article 9cd.5 of the Banking Law Act in conjunction with § 1 of the Regulation concerning the scope of tasks to be performed by the nomination committee,
    4. 3) Article 9ce of the Banking Law Act,
    5. 4) Article 111 section 6 to 6e of the Act on Trading,
    6. 5) Article 129 section 3 of the Act on Statutory Auditors,
  • 6) Article 22 of the Act on the Principles of Property Management,
  • 7) the Act on the Rules for Obtaining Information About the Criminal Record.
    1. This Policy has been adopted with concern to the Guidelines, Methodology and Best Practice.
    1. If any provisions of this Policy prove to be inconsistent with generally binding provisions of law, relevant provisions of law should be applied when selecting and assessing Supervisory Board Members.

§ 3. OBJECTIVES, GENERAL AND DETAILED SCOPE

    1. This Policy has been put into place in the Bank to exercise the obligations stemming from the binding law as well as to support the pursuit of the Bank's strategy by ensuring that the functions of the Supervisory Board Members are performed by individuals possessing the requisite competencies, skills and experience relevant to their functions and responsibilities, and who offer assurance of the proper performance of those duties.
    1. The principles set out in this Policy shall apply to both candidates for the Supervisory Board and to its existing Members.
    1. All individuals involved in the process of selecting and assessing the suitability of candidates for the Supervisory Board and current Supervisory Board Members are obliged to apply the provisions of this Policy.
    1. This Policy sets forth the rules for the selection and suitability assessment of the Supervisory Board Members within the meaning of Article 22aa of the Banking Law Act, and of the Guidelines and Methodology.

§ 4. SELECTION AND ASSESSMENT PROCESS

    1. The process of selection and suitability assessment of the Supervisory Board Members is based on applicable laws, the provisions of the Bank's Articles of Association, the Rules of Procedure of the Supervisory Board of the Bank, and the Rules of Procedure of the General Meeting, as well as this Policy.
    1. Supervisory Board Members are selected from a sufficiently wide group of candidates.
    1. Nominations for Supervisory Board Members should be put forward in a sufficient time as to enable the shareholders participating in the General Meeting to make decisions with due consideration, yet not later than 3 days before the General Meeting. The nominations put forward, along with a complete set of materials relating to them, should be immediately published on the Bank's website.
    1. The process of selecting and assessing the suitability of candidates for the Supervisory Board, as well as current Members, shall take into account the nature, scale, and complexity of the Bank's operations. In determining the composition of the Supervisory Board, including the number of its Members and the number of independent Members, the Bank shall particularly consider:
    2. a) the size and complexity of the Bank's organisational structure, including the range of management,
    3. b) the specificity of the Bank's operations, including the scope of activities, specialisation, legal form, sources of financing,
  • c) business plans of the Bank,
  • d) the position and importance of the Bank in the banking system,
  • e) shareholding composition.
    1. The composition of the Supervisory Board should ensure that this body possesses competencies relevant to its functions, deriving from the specialist knowledge and experience of its individual Members.
    1. Selection and assessment of Supervisory Board Members are held under the suitability assessment.
    1. The selection and suitability assessment process for candidates and Supervisory Board Members shall be conducted with consideration for the diversity policy adopted by the Bank, as referred to in § 14 of this Policy.

§ 5.

SCOPE OF ASSESSMENT

The scope of the assessment shall comprise:

    1. The individual suitability of a candidate for, or a Member of, the Supervisory Board to perform functions within the body, understood as the degree to which the person is deemed to possess a good repute and independently hold an adequate level of knowledge (minimum requirement: higher education), skills and experience (minimum requirement: 60 months, of which at least 36 months must be in managerial positions) enabling the performance of duties as a Supervisory Board Member. Suitability also encompasses the individual's honesty, integrity, independence of judgement, and ability to devote sufficient time to perform their duties.
    1. The individual suitability of a candidate for, and a Member of, the Audit Committee.
    1. The collective suitability of the Audit Committee as a body.
    1. The collective suitability of the Supervisory Board as a governing body.

§ 6.

GROUNDS FOR ASSESSMENT

    1. In order to ensure the individual suitability of the Supervisory Board Members, the Bank shall carry out individual assessments of their suitability.
    1. To ensure the individual suitability of candidates for the Supervisory Board, a preliminary individual assessment shall be conducted by the Shareholder and the General Meeting prior to appointment.
    1. The Nomination Committee and the Supervisory Board shall assess the individual suitability of a candidate for the Audit Committee prior to appointment, particularly in relation to the specific criteria required of Audit Committee Members, as defined by applicable legal provisions and the Bank's internal regulations.
    1. The chairperson of the Supervisory Board should not combine their function with the management of the Audit Committee acting within the Board.
  • Suitability assessments of candidates for the Bank's other advisory committees shall be conducted by the Nomination Committee based on the current individual suitability assessments of the Supervisory Board Members.

  • The Bank shall conduct secondary assessments of the individual suitability of Supervisory Board Members

in the following instances:

  • 1) annually,
  • 2) before communicating an intention to acquire a qualifying block of shares of a supervised entity or to become its parent entity (in the event of planned changes in the composition of the bodies),
  • 3) as part of inspection/review of the PCG,
  • 4) before the end of term of office of the Supervisory Board (regardless of whether there are plans to re-appoint a given person to another term),
  • 5) upon receipt of information that criminal charges or fiscal offences have been brought against a Supervisory Board Member, or that they have caused significant financial losses,
  • 6) in the event of new circumstances which may affect suitability assessment, in particular, with regard to identified cases of a potential conflict of interests or identification of shortcomings in the primary assessment process of the Supervisory Board Member concerned,
  • 7) if a given person is entrusted with additional competences/takes up additional roles (the assessment of time commitment and of conflicts of interests),
  • 8) if there are regular or gross cases of negative secondary individual or collective assessment of the Supervisory Board Members – in terms of guarantee of the Supervisory Board Members in the context of appointing or keeping such persons in the Management Board,
  • 9) upon identification of significant breaches of duty by Supervisory Board Members,
  • 10) when there are reasonable grounds to suspect that a money laundering or terrorist financing offence has been or is being committed or attempted in connection with an act or omission of certain members of the body, or that there is a higher risk of such an offence being committed in connection with the Bank's activities, in particular in situations where the Bank:
    • a) has failed to implement adequate internal control or oversight mechanisms to monitor and mitigate money laundering/terrorist financing risks (e.g., identified through onsite or off-site supervision, supervisory dialogue, or sanctions context);
    • b) has been found in breach of its anti-money laundering/terrorist financing obligations domestically or internationally;

or

  • c) has materially changed its business activities or business model in a way that suggests that its exposure to money laundering/terrorist financing risks has significantly increased.
    1. The Bank assesses the collective suitability of the Supervisory Board each time:
  • 1) before appointing the composition of a Bank's body to a new term of office (regardless of whether the composition of that body is the same or not),
  • 2) before communicating an intention to acquire a qualifying block of shares of a supervised entity or to become its parent entity (in the event of planned changes in the composition of the bodies),
  • 3) in the event of changes in the division of competences within the Supervisory Board (including membership of advisory committees);
  • 4) before any changes are made to the composition of the Supervisory Board of the Bank, in particular the appointment, dismissal, resignation or suspension of its Member (or immediately thereafter if, for reasons beyond the Bank's control, it has not been possible to carry out a suitability assessment in advance - e.g. if a Supervisory Board Member resigns with immediate effect),
  • 5) when there is a material change to the Bank's business model, risk appetite or strategy or structure at the individual level or at the Alior Bank Group level,
  • 6) when there are reasonable grounds to suspect that a money laundering or terrorist financing offence has been or is being committed or attempted in connection with an act or omission of certain bodies of the Bank, or there is a higher risk of such an offence being committed in connection with the Bank's activities, in particular in situations where the Bank:
    • a) has failed to implement adequate internal control or oversight mechanisms to monitor and mitigate money laundering/terrorist financing risks (e.g., identified through on-site or off-site supervision, supervisory dialogue, or sanctions context);
    • b) has been found in breach of its anti-money laundering/terrorist financing obligations domestically or internationally; or
    • c) has materially changed its business activities or business model in a way that suggests that its exposure to money laundering/terrorist financing risks has significantly increased.
    • 7) in the event of new circumstances which may affect the assessment of collective suitability of the members of the Supervisory Board,
  • 8) as part of the PCG review;
  • 9) when there is a significant change in the individual suitability assessment of any Member;
  • 10) at the time of appointment and any change in the composition of the Audit Committee, in terms of whether an adequate number of its Members meet the criteria of independence as well as knowledge and skills in the field of accounting or auditing (i.e. compliance with the rules on the appointment and composition of the Audit Committee),
  • 11) each time a Supervisory Board is entrusted in gremio with the function of an Audit Committee – to verify whether the relevant number of its Members meet the independence criteria and have knowledge and skills in accounting and examination of financial statements.
    1. If there is more than one premise of the suitability assessment referred to in this paragraph at the same time, the suitability assessment may be carried out once.

§ 7. ASSESSMENT CRITERIA

    1. The basic criteria for assessing suitability include:
    2. 1) knowledge level, including education, training, titles and qualifications/degrees, in particular:
  • a) to have obtained higher education,
  • b) expected directional education (field of study related to the financial services sector, in particular in the field of banking and finance, economics, law, accounting, auditing, administration, financial regulations, information technology, and quantitative methods),
  • 2) the skills necessary for the performance of the function entrusted (both "hard" skills, resulting directly from the education and experience possessed, and "soft" skills, necessary for the management of the institution),
  • 3) in cases where gaps in specialist knowledge are identified which can be remedied in a short period, appointment to the Supervisory Board may be made subject to the condition that such knowledge is supplemented within a prescribed timeframe, not exceeding 3 months,
  • 4) professional experience, including performing a managerial or supervisory function in the past, and specialisation in relevant areas for the Bank's operations, including in particular:
    • a) at least 60 months of professional experience, in principle in positions related to the financial services sector, in particular in financial institutions,
    • b) at least 36 months of experience in managerial positions, either as part of the management body or directly reporting to it;
  • 5) reputation, integrity and ethics, independence of judgement and absence of a conflict of interest,
  • 6) devoting enough time to perform the duties of a Supervisory Board Member,
  • 7) proficiency in the Polish language,
  • 8) clean criminal record, reputation, and financial situation (both current and historical, assessed in terms of susceptibility to undue pressure or an increased tendency to accept excessive risk);
  • 9) other relevant criteria for the Supervisory Board's operations as the body, including activities in the Bank's interest.
    1. Suitability is also assessed in terms of the number of functions that a Supervisory Board Member may perform simultaneously, in accordance with Article 22aa sections 2 to 6 of the Banking Law Act, according to which:
    2. 1) the number of functions of a management board or supervisory board member performed simultaneously by a Supervisory Board Member should depend on individual circumstances and the nature, scale, and degree of complexity of the Bank's operations;
    3. 2) A Supervisory Board Member may perform simultaneously no more than one function of a management board member and two functions of a supervisory board member, or four functions of a supervisory board member, provided that the above limitation does not apply to functions performed by a Supervisory Board Member in non-business entities economic, as well as to persons representing the State Treasury in the Supervisory Board,
    4. 3) one function is regarded as:
      • a) functions of a management board or supervisory board member performed in entities belonging to the same capital group within the meaning of Article 3.1.44 of the Accounting Act of 29 September 1994;
      • b) functions of a Supervisory Board Member performed in:
  • i. entities covered by the same institutional protection system that meet the conditions referred to in Article 113.7 of the CRR, or
  • ii. entities in which the Bank holds a significant block of shares referred to in Article 4.1.36 of the CRR.
    1. When assessing the suitability of a Supervisory Board Member, account is also taken of the fulfilment of the requirements referred to in Article 111(6b) of the Act on Trading, according to which members of the Supervisory Board of a bank conducting brokerage activities may not be persons found guilty by a valid court decision of a tax offence, an offence against document reliability, property, economic turnover, money and securities trading, crimes or offences specified in Article 305, Article 307 or Article 308 of the Act of 30 June 2000 - Industrial Property Law, or an offence specified in the laws referred to in Article 1(2) of the Act of 21 July 2006 on Financial Market Supervision and an offence constituting an infringement of equivalent provisions in force in other Member States.
    1. When assessing Supervisory Board Members' suitability, the requirement of meeting the independence criteria is taken into account by at least two Supervisory Board Members, pursuant to § 18 section 4 of the Bank's Articles of Association in conjunction with Article 129 section 3 of the Act on Statutory Auditors.
    1. In the banking sector, without prejudice to the presumption of innocence applicable in criminal proceedings and other fundamental rights, at least the following circumstances are taken into account in the assessment process:
    2. a) convictions or pending criminal proceedings, in particular relating to: offences under the laws governing banking, finance, securities, insurance, securities markets or financial or payment instruments, including laws relating to money laundering, corruption, market manipulation or insider dealing and usury; offences of dishonesty, fraud or financial crime; tax offences; other offences under the laws relating to companies, bankruptcy, insolvency or consumer protection;
    3. b) other relevant measures taken currently or in the past by a regulatory or professional body in relation to non-compliance with the banking, financial, securities or insurance regulations in question;
    4. c) cases where there is a reasonable suspicion that an offence relating to money laundering or terrorist financing (Article 165a or Article 299 of the Act of 6 June 1997 - Penal Code) has been committed using the activities of a bank, a financial holding company or a mixed financial holding company, a reasonable suspicion of an attempt to commit that offence or the existence of an increased risk of committing that offence.
    1. The assessment of collective suitability should also assess whether the authority, through its decisions, has demonstrated a sufficient understanding of the money laundering/terrorist financing risks and how they affect the institution's activities, and whether it has adequately managed those risks, including corrective measures where appropriate.

§ 8.

PRIMARY ASSESSMENT OF THE SUITABILITY OF A CANDIDATE FOR A SUPERVISORY BOARD MEMBER

  1. The primary suitability of candidates to the Supervisory Board of the Bank is assessed by the Shareholder.

    1. The expected level of competence of candidates and Supervisory Board Members is specified in Appendix 1.
    1. The suitability assessment shall be performed by completing, initially by the candidate and subsequently by the Shareholder, the forms prescribed in the current PFSA Methodology set, which are made available to Shareholders together with the materials for the General Meeting.
    1. Candidacy for the Supervisory Board is presented in accordance with the provisions of the Rules and Regulations of the General Meeting. When proposing a candidacy for a Supervisory Board Member, a participant in the General Meeting should present the suitability assessment result together with the candidate's CV, including, in particular, the candidate's education and previous professional experience.
    1. The participant in the General Meeting proposing a candidacy for a Supervisory Board Member should provide an exhausting justification. In preparing the justification, the participant of the General Meeting assesses the individual suitability of the candidate, taking into account the provisions of Article 22 section 2 in connection with Article 22aa of the Banking Law Act, on the basis of the forms referred to in section 3 above made available by the Bank.
    1. The participant of the General Meeting presenting the candidacy provides the Bank with the completed forms referred to in (3) above.
    1. The primary assessment of individual suitability is approved by the General Meeting in the form of a resolution.
    1. The Expert Unit communicates the final outcome of the initial assessment of the individual suitability of the Supervisory Board candidate to the Supervisory Board.

§ 9. SECONDARY INDIVIDUAL SUITABILITY ASSESSMENT OF A SUPERVISORY BOARD MEMBER

    1. Each Supervisory Board Member of the Bank is obliged to inform the Expert Unit promptly of any changes to the data covered by the content of the Suitability Assessment Form since their last assessment (e.g., involvement in legal proceedings, imposition of a ban on conducting business activity, attainment of additional qualifications, changes in supplementary professional activities, etc.).
    1. The Expert Unit maintains a register of external professional and political functions held by Supervisory Board Members. This register shall be updated without delay upon notification of any changes by the respective Member.
    1. In the cases specified in § 6 section 5, the Nomination Committee decides to initiate the secondary assessment of the individual suitability of a Supervisory Board Member and requests the Expert Unit to carry out the necessary actions in this regard.
    1. The Expert Unit, taking into account:
    2. 1) an event leading to the need for a secondary assessment of individual suitability,
    3. 2) documentation of the prior assessment of the individual suitability of the Supervisory Board Member
  • determines to what extent a secondary assessment of individual suitability should be carried out.

    1. In principle, the secondary assessment of individual suitability covers the full range of criteria. However, if the need to carry out an assessment arises from:
    2. 1) receipt of information that a Supervisory Board Member has been charged in criminal proceedings or in proceedings for a fiscal offence or has caused significant property damage,
    3. 2) new circumstances coming to light that may affect the assessment of the suitability of a Supervisory Board Member, in particular with regard to identified cases of potential conflict of interest
  • the assessment of suitability may be limited to clarifying the aforementioned circumstances.

    1. Taking into account the scope of the assessment of individual suitability established in the previous action, the Expert Unit prepares a list of information and statements to be provided by the Supervisory Board Member. The Expert Unit selects the appropriate forms to be completed according to the current statement for the PFSA Methodology, published on the PFSA website.
    1. A Supervisory Board Member prepares the information and statements indicated on the list provided by the Expert Unit. The Supervisory Board Member attaches the documents indicated in the questionnaires to confirm the veracity of the information contained in them. A Supervisory Board Member is obliged to present information on individual suitability assessment criteria, as long as it has not changed, has not been updated or outdated since the previous assessment. If the information from the previous suitability assessment is still valid, a Supervisory Board Member may make a statement in this regard. With regard to the assessment of warranty (including a clean criminal record) and devoting sufficient time to the performance of his or her duties, a Supervisory Board Member is required to provide complete information in each case, unless such information has been provided within the last 12 months.
    1. The Expert Unit verifies whether the documents referred to in section 5 above have been completed and contain all the necessary information, including the identification of deficiencies requiring adjustment or completion, and forwards the documents to the Supervisory Board Member for adjustment/completion.
    1. The Substantive Unit shall verify the respective content areas of the Suitability Assessment Form with the relevant organisational units of the Bank, namely: a) the Compliance Department – in respect of Sections F: "integrity" and G: "financial situation and conflict of interest" (within the scope of the Compliance Department's competence);

b) the Legal Department – in respect of Sections I: "accumulation of functions" and J: "time commitment" (within the scope of the Legal Department's competence);

c) the Audit Department – in respect of Section F: "integrity" (insofar as concerns findings resulting from internal audit reviews);

d) other Bank units – depending on the subject matter requiring verification.

  1. The Expert Unit performs an initial assessment of the documents and information submitted by the Supervisory Board Member referred to in (5) or revised/completed in accordance with (6) above. It documents the process by completing the Bank-reserved sections of the questionnaires, and forwards the file to the Nomination Committee. Afterwards, the Expert Unit provides the documentation to the Nomination Committee.

    1. The Nomination Committee carries out a secondary assessment of individual suitability on the basis of the available information held on the Supervisory Board Member concerned which is relevant to the assessment. A member of the Nomination Committee is not involved in their own secondary individual suitability assessment process.
    1. In carrying out the secondary assessment of individual suitability, the Nomination Committee may be assisted by an external adviser.
    1. The Nomination Committee prepares a recommendation on the secondary assessment of the individual suitability of the Supervisory Board Member. If the result of the assessment is positive, the Nomination Committee recommends a positive assessment of the suitability of the Supervisory Board Member and that he/she remain entrusted with the function of Supervisory Board Member. In the event that the suitability assessment results in objections against a Supervisory Board Member that can be removed as a result of corrective measures, the Nomination Committee may recommend such corrective measures. In the event of a negative assessment, the Nomination Committee recommends that an Extraordinary Meeting of Shareholders be convened in order to remove a Supervisory Board Member from their position. The Nomination Committee communicates its recommendation to the Supervisory Board and the General Meeting.
    1. The Supervisory Board reports to the PFSA on the suitability assessment carried out, its results and the decision taken.

§ 10.

COLLECTIVE SUITABILITY ASSESSMENT OF THE SUPERVISORY BOARD

    1. In the cases specified in § 6.6, the Nomination Committee decides to initiate the assessment of the collective suitability of the Supervisory Board and requests the Expert Unit to carry out the necessary actions in this regard.
    1. The Expert Unit verifies the validity of individual assessments Supervisory Board to the extent necessary to carry out a collective suitability assessment (i.e., within the scope of competences). If it is determined that at least part of the information necessary to carry out the collective suitability assessment of the Supervisory Board is not available or has become outdated, the Expert Unit proceeds to complete the missing information. If this is not the case, the Expert Unit proceeds with the primary assessment of the collective suitability of the Supervisory Board.
    1. If the collective suitability assessment of the Supervisory Board results from changes in the composition of the Audit Committee, the Expert Unit obtains the candidate assessment form from the Audit Committee Members or from candidates to the Audit Committee – according to the current statement of the PFSA Methodology.
    1. The Expert Unit carries out the primary collective assessment of the suitability of the Supervisory Board and the Audit Committee (if necessary) and documents the assessment process by completing the Form of the Collective Assessment of the Suitability of the Supervisory Board, and in the case of assessing the Audit Committee, the Audit Committee's collective suitability form – both according to the current statement of the PFSA Methodology. Afterwards, the Expert Unit provides the abovementioned documentation to the Nomination Committee.
    1. The Nomination Committee prepares a recommendation for the Supervisory Board regarding the collective assessment of the Supervisory Board. If the assessment result is positive, the Nomination

Committee issues a positive collective suitability assessment of the Supervisory Board in its current composition. If the outcome of the assessment is negative, the Nomination Committee recommends remedial measures including, in particular: adjusting the division of responsibilities among the Supervisory Board Members, convening an Extraordinary General Meeting to complete the composition of the Supervisory Board, taking possible measures to minimise conflicts of interest or organising training for the Supervisory Board or its individual Members to ensure the individual and collective suitability of this body. The Nomination Committee communicates its recommendation to the Supervisory Board.

    1. The Supervisory Board carries out the collective assessment of the suitability Supervisory Board in the form of a resolution. If a vote takes place contrary to the recommendation of the Nomination Committee, the Supervisory Board should present in writing or in the form of minutes a justification of such action. The assessment result may also include recommendations concerning remedial measures that should be taken in order to remove the reservations or irregularities found. In the event of a negative collective suitability assessment, the inclusion of such a recommendation is mandatory. The Supervisory Board documents the process of the collective suitability assessment and its outcome.
    1. At least once a year, the General Meeting approves the collective suitability assessment of the Supervisory Board according to the information as at the end of the financial year.
    1. The Supervisory Board provides the PFSA with information on the assessment result, and in the event of a negative assessment – also with information on recommended remedial actions.
    1. If the collective suitability assessment of the Management Board has given rise to recommendations concerning remedial measures, the Supervisory Board immediately undertakes and documents actions aimed at their implementation.

§ 11. PROCESS OF PRIMARY INDIVIDUAL SUITABILITY ASSESSMENT OF A CANDIDATE FOR MEMBERSHIP OF THE AUDIT COMMITTEE

    1. In the process of assessing suitability to serve as Members of the Audit Committee, consideration is given to legal requirements as well as to good practice regarding: the composition and independence of the Members of the Audit Committee; knowledge and skills in: accounting or auditing; the industry; independence; and having the appropriate knowledge and skills if the Audit Committee tasks are entrusted to the Supervisory Board.
    1. The candidate for Audit Committee Member completes the individual suitability assessment form – according to the current summary for the PFSA Methodology and with attachments confirming the information indicated in the form, including: that the candidate for Audit Committee Member has the necessary knowledge and skills in the field of accounting and financial reporting, taking into account directional education, specialist certificates or qualifications, as well as the required minimum professional experience in a position directly related to financial accounting, management accounting or auditing. The set of materials referred to above is forwarded by the candidate for the Audit Committee Member to the Expert Unit.
    1. The Expert Unit verifies the documents received and, if necessary, asks the candidate to supplement them, as well as carries out a preliminary assessment.
  • Primary suitability of candidates to the Audit Committee is assessed by the Nomination Committee.

§ 12. SECONDARY INDIVIDUAL SUITABILITY ASSESSMENT OF AN AUDIT COMMITTEE MEMBER

    1. In the cases referred to in § 6(6) point (6), point (8) or point (9), the Nomination Committee decides to initiate the process of secondary assessment of the individual suitability of a Member of the Audit Committee of the Supervisory Board and requests the Expert Unit to carry out the necessary activities in this respect.
    1. The Expert Unit, taking into account:
    2. 1) an event leading to the need for a secondary assessment of individual suitability of an Audit Committee Member,
    3. 2) documentation of the prior assessment of the individual suitability of the Member Audit Committee
  • determines the extent of the secondary assessment to be conducted.

    1. Taking into account the scope of the assessment of the individual suitability of an Audit Committee Member established in the previous step, the Expert Unit prepares a list of information and statements to be provided by the Audit Committee Member. This list contains materials confirming that an Audit Committee Member has the competences listed in § 11(2) above.
    1. The Expert Unit selects the appropriate forms to be completed according to the current statement for the PFSA Methodology.
    1. The Audit Committee Member prepares the information and statements indicated on the list provided by the Expert Unit, attaching supporting documents verifying the truthfulness of the submitted data.
    1. The Expert Unit verifies whether the documents referred to in section 5 above have been correctly completed and contain all the necessary information, including the identification of deficiencies requiring adjustment or completion, and forwards the documents to the Audit Committee Member for adjustment/completion.
    1. The Expert Unit shall make a preliminary assessment of the documents and information submitted or completed/revised by an Audit Committee Member in accordance with section 5 or section 6 above, as appropriate. The Expert Unit shall document the assessment process by completing the sections in the questionnaires reserved for completion by the Bank. Afterwards, the Expert Unit provides the documentation to the Nomination Committee.
    1. The Nomination Committee carries out a secondary assessment of individual suitability based on the available information held on the Audit Committee Member – relevant to the assessment. A member of the Nomination Committee is not involved in their own secondary individual suitability assessment process.
    1. In carrying out the secondary assessment of individual suitability, the Nomination Committee may be assisted by an external adviser.
    1. The Nomination Committee prepares a recommendation on the secondary assessment of the individual suitability of the Supervisory Board Member. If the outcome of the assessment is positive, the Nominations Committee recommends a positive assessment of the suitability of the Audit Committee Member and that he/she remain on the Committee. If the result of the suitability assessment contains reservations concerning an Audit Committee Member that may be removed thanks to corrective measures, the Nomination Committee may recommend the application of such measures. In the event of a negative secondary individual suitability assessment of an Audit Committee Member, the Nomination Committee shall recommend changes to the composition of the Audit Committee. The Nomination Committee communicates its recommendation to the Supervisory Board.
    1. The Supervisory Board provides the PFSA with information on the outcome of the secondary assessment of the individual suitability of an Audit Committee Member and, in the event of a negative assessment, also information on the recommended remedial action.

§ 13.

ASSESSMENT OF THE COLLECTIVE SUITABILITY OF THE AUDIT COMMITTEE

    1. Each and every time the composition of the Audit Committee changes, the Nomination Committee decides to initiate the assessment of the collective suitability of the Audit Committee and requests the Expert Unit to carry out the necessary actions in this regard.
    1. The Expert Unit verifies the validity of individual assessments of the Audit Committee to the extent necessary to carry out a collective suitability assessment (i.e., within the scope of competences). If it is found that at least some of the information necessary to carry out the assessment of the Audit Committee's collective suitability is not available or has become outdated, the Expert Unit proceeds to complete the missing information. If this is not the case, the Expert Unit proceeds with the primary assessment of the collective suitability of the Audit Committee.
    1. If the collective suitability assessment results from changes in the composition of the Audit Committee, the Expert Unit obtains the candidate assessment form from candidates to the Audit Committee – according to the current statement of the PFSA Methodology.
    1. The Expert Unit carries out the primary collective assessment of the suitability of the Audit Committee and documents the assessment process by completing the Audit Committee's collective suitability form – according to the current statement of the PFSA Methodology. Afterwards, the Expert Unit provides the documentation to the Nomination Committee.
    1. The Nomination Committee prepares a recommendation for the Supervisory Board regarding the collective assessment of the Audit Committee. If the assessment result is positive, the Nomination Committee issues a positive collective suitability assessment of the Audit Committee in its current composition. In the event that the result of the collective suitability assessment is negative, the Nomination Committee recommends a change in the composition of the Audit Committee. The Nomination Committee communicates its recommendation to the Supervisory Board.
    1. The Supervisory Board carries out the collective assessment of the suitability of the Audit Committee in the form of a resolution.

SUCCESSION PLANNING FOR BOARD MEMBERS

    1. In the event of a vacancy on the Supervisory Board and, in particular, in the event of a sudden and unexpected situation, the Supervisory Board carries out an assessment of the collective suitability referred to in § 10, including an assessment of the impact of the occurrence of the vacancy on the continued functioning of the supervisory body and its advisory committees and, if necessary, initiates action by the General Meeting to ensure the collective suitability of the Supervisory Board.
    1. Until the members of the Supervisory Board are replenished, the body functions in a reduced composition. In the event that the composition of the Supervisory Board falls below the minimum specified in the Bank's Articles of Association, an Extraordinary General Meeting is convened without delay in order to supplement the composition of the Supervisory Board at least to the minimum specified in the Bank's Articles of Association.
    1. In the event that the occurrence of a vacancy on the Supervisory Board reduces the number of Members of the Nomination Committee below the minimum specified in the Rules of Procedure of the Nomination Committee - the Supervisory Board carries out the collective suitability assessment referred to in § 10, disregarding the recommendation of the Nomination Committee.
    1. The Supervisory Board Members are selected from a group of potential candidates who may be nominated by, among others, the Management Board, the Supervisory Board and the Shareholders.

§ 15.

DIVERSITY POLICY

    1. The Diversity Policy defines the goals and criteria of diversity, including but not limited to, in such areas AS gender, field of education, specialist knowledge, age and professional experience, as well as indicates the date and method of how the achievement of these goals should be monitored. When assessing candidates for the Supervisory Board, the Bank takes into account a wide set of features and competences required to be a Supervisory Board Member.
    1. The Bank endeavours to ensure diversity of the Supervisory Board, in particular, in the scope of education and professional experience, gender and age of members of the Supervisory Board, and to the extent ensuring a broad spectrum of views of the supervisory body.
    1. When determining the composition of the Supervisory Board, the Bank seeks to achieve:
    2. a) gender balance within this body;
    3. b) a total number of positions in the Management Board and the Supervisory Board held by individuals of the underrepresented gender at a level no lower than the number closest to 33% of all positions across both bodies;
    4. c) a situation in which at least one person of the underrepresented gender holds a position on the Supervisory Board of the Bank.
    1. In assessing the diversity of Supervisory Board Members in terms of education and professional experience, particular consideration may be given to criteria such as: the country or region in which education or experience was acquired; the profile of education; field of study; specialisation; types of entities in which the candidate has held positions or been employed; and length of professional service.
    1. In cases where candidates for a position on the Supervisory Board possess equivalent qualifications, preference shall be given to the candidate representing the underrepresented gender within the Bank's governing bodies, unless the selection of a candidate of the opposite gender is justified by other non-discriminatory diversity considerations established by law.
    1. The Bank recruits Members of the Supervisory Board primarily with regard to the criteria outlined in section 4 above, which are essential for the effective functioning and overall suitability of the Supervisory Board.
    1. Shaping the composition of the Supervisory Board should not take place with the sole aim of increasing diversity at the expense of the functioning and suitability of the Supervisory Board as a whole or the suitability of individual members.

§ 16. INFORMATION AND DOCUMENTATION OBLIGATIONS

    1. To document the course of the suitability assessment process, the HR Division archives all related documentation, including Suitability Assessment Forms and declarations submitted by candidates for or the Bank's Supervisory Board Members.
    1. Immediately following the appointment of the Supervisory Board or any changes to its composition, the Bank shall notify the Polish Financial Supervision Authority of the composition or the changes thereto, along with confirmation that the Members concerned meet the suitability requirements set out in Article 22aa of the Banking Law Act.
    1. The Bank shall promptly inform the Polish Financial Supervision Authority of any negative outcome of an individual suitability assessment of a Supervisory Board Member or of the collective suitability assessment of the Supervisory Board, as well as of the measures undertaken in response to such outcomes.
    1. The Bank announces, in a publicly available manner, information that members of the Supervisory Board meet the suitability requirements specified in Article 22aa of the Banking Law Act.

§ 17. PRINCIPLES OF DEVELOPMENT AND TRAINING

    1. The rules for the development of Supervisory Board Members are set out in a separate regulation adopted by the Bank: "Development Policy for Members of the Management Board and Supervisory Board of Alior Bank S.A."
    1. The development activities set out in the regulation referred to in section 1 above are coordinated by the HR Division.

§ 17. PRINCIPLES OF AMENDMENTS AND REVIEWS

    1. Controls and independent monitoring of their compliance are regulated by the Instruction issued by the Managing Director of the HR Division.
    1. In cases not covered by this Policy, the provisions of the Methodology are applicable.
    1. The Nomination Committee monitors the effectiveness of the Bank's application of this Policy, including to the extent indicated in the Diversity Policy described in § 14, and reviews its content and implementation.

Appendices:

Appendix 1 Competencies of a Supervisory Board Member and of a Candidate for the Position of Supervisory Board Member

COMPETENCIES OF A SUPERVISORY BOARD MEMBER AND OF A CANDIDATE FOR A SUPERVISORY BOARD MEMBER

If marked with (*) – high level it expected from at least 3 members of the Supervisory Board as part of the collective suitability assessment

If marked with (**) – high level it expected from at least 2 members of the Supervisory Board as part of the collective suitability assessment

EXPECTED COMPETENCIES RELATED TO THE MANAGEMENT OF THE
MANAGED ENTITY
Level
required
by entity
(individual
assessment)
MARKET KNOWLEDGE
Candidate has a general knowledge of the financial market, with particular focus on the sector
in which the entity under supervision operates and with particular focus on the knowledge of
the Polish market.
average*
KNOWLEDGE OF LEGAL REQUIREMENTS AND REGULATORY
FRAMEWORKS
Candidate has knowledge of regulations, recommendations issued by supervisory authorities
and codes of best practice regulating activities in the financial market sector in which the
entity under supervision operates.
average*
STRATEGIC PLANNING (MANAGEMENT SKILLS)
Candidate understands the operating strategy/business plan of the institution and knows how
to implement them.
KNOWLEDGE OF THE MANAGEMENT SYSTEM, INCLUDING RISK
MANAGEMENT
Candidate understands the methodology of risk management –
identifying, assessing,
monitoring, controlling and mitigating the main types of risk connected with the institution.
ACCOUNTING AND FINANCIAL AUDIT
Candidate has up-to-date knowledge on accounting, accounting standards and financial audit.
SUPERVISION, CONTROL AND INTERNAL AUDIT
Candidate understands the rules and standards applicable to the functioning of the audit and
internal control system.
INTERPRETATION OF FINANCIAL INFORMATION (SKILLS IN THE AREA OF
FINANCE AND ACCOUNTING)
Candidate can interpret financial and accounting data, analyse presented data and draw
conclusions necessary for management purposes within the entity while taking into account
the market situation.
average*
POSSESSION OF SKILLS IN THE FIELD OF INSURANCE basic
of the information presented, to carry out the analysis and draw the conclusions necessary for
the management of the entity while taking into account the market situation.
POSSESSION OF SKILLS IN THE FIELD OF ACTUARIAL FUNCTION
A member of the body understands the importance and role of the actuarial function in the
basic
entity; he/she is able to carry out data analysis and interpret information taking into account
the entity's strategy and the market situation.
KNOWLEDGE OF THE POLISH LANGUAGE
Candidate has a proven knowledge of the Polish language, effectively communicates with
high
employees in Polish (both with regard to day-to-day and industry-related issues), understands
topics addressed during the body's meetings; candidate can use the Polish language in
presentations and speeches given during conferences, workshops or key meetings.
Level
required by
EXPECTED COMPETENCIES RELATED TO RISK MANAGEMENT IN THE
the entity
ACTIVITIES OF THE MANAGED ENTITY
(individual
assessment)
BUSINESS MODEL RISK
average**
business risk
strategic risk
RISK IN THE AREA OF CREDIT RISK
credit risk
concentration risk
basic**
collective borrower default risk
counterparty risk
settlement/delivery risk
Foreign currency lending risk
RISK IN THE AREA OF MARKET RISK
position risk
basic**
currency risk
commodity price risk
Interest rate credit valuation adjustment (CVA) risk
RISK IN THE AREA OF OPERATIONAL RISK
operational risk
IT risk
average**
legal risk
model risk
AML risk
RISK IN THE AREA OF LIQUIDITY AND FINANCING
liquidity Risk
market liquidity risk
basic**
intraday liquidity risk
liquidity concentration risk
funding risk
RISK IN THE AREA OF CAPITAL MANAGEMENT
basic**
excessive leverage risk
insolvency risk
MANAGEMENT RISKS
compliance risk
reputational risk
average**
RISK IN THE AREA OF SYSTEMIC RISK
systemic risk
contagion risk
basic**
EXPECTED COMPETENCIES RELATED TO THE MANAGEMENT OF MAIN
AREAS OF OPERATIONS OF THE MANAGED ENTITY
Level
required by
the entity
(individual
assessment)
RETAIL BANKING average*
CORPORATE BANKING average*
RISK MANAGEMENT basic*
FINANCE average*
OPERATIONS basic**
IT basic**
STRATEGY average*
OVERSIGHT OF SUBSIDIARIES average **
HR basic*
LEGAL, REGULATIONS, AUDIT, PERSONAL DATA PROTECTION average*
SECURITY / CYBERSECURITY / AML average **
OTHER * average **

* optional – depending on the current allocation of responsibilities within the Bank's Management Board

EXPECTED PERSONAL COMPETENCIES Level
required
by entity
(individual
assessment)
AUTHENTICITY
Candidate's words and actions are consistent and their behaviour is consistent with the
reported values and beliefs. Candidate openly states their intentions, ideas and opinions,
encourages their environment to be open and honest, and properly informs their supervisor
about the actual situation, thus recognising existing risks and problems.
meets the
criteria
LANGUAGE
Candidate can communicate verbally in an organised and conventional manner and write in
the native language or language used at work in the place where the institution is located.
high
DECISIVENESS meets the
criteria
Candidate makes decisions in a timely manner based on available information, acting quickly
and in accordance with the specified procedure, for example by expressing their views and
not postponing the decision.
COMMUNICATION
Candidate can communicate a message in a clear and socially acceptable way and in
appropriate form. Candidate focuses on communicating and obtaining clear and transparent
information as well as encourages to actively provide feedback.
high
JUDGEMENT
Candidate can accurately evaluate information and various modes of procedures as well as
reach logical conclusions. Candidate verifies, recognises and understands important issues.
Candidate has the ability to holistically assess the situation beyond the perspective of the
position held, especially when solving problems that may threaten the continued operation of
an enterprise.
high

CUSTOMER CARE AND HIGH STANDARDS

Candidate focuses on ensuring high standards and, where possible, finding ways to raise
them. In particular: Candidate refuses to approve the development and marketing of products
and services as well as to bear capital expenditures in circumstances when they are not able to
appropriately measure risk due to the lack of understanding the structure, rules or basic
assumptions of the proposed solution. Candidate identifies and examines the expectations and
needs of customers as well as ensures the communication of accurate, complete and clear
information to customers. Candidate takes into consideration, in particular, the value of a
product for the
customer as well as the adequacy and suitability of a product.
high
LEADERSHIP SKILLS
Candidate indicates lines of action and ensures leadership, supports teamwork, motivates
employees and ensures they have the professional competencies necessary for the performed
functions or necessary to achieve set goals. It is open to criticism and ensures a constructive
debate.
average*

LOYALTY

Candidate identifies with the organisation and shows commitment. Candidate shows that they are willing to devote a sufficient amount of time to work and is able to appropriately perform their duties, defends the organisation's interests and operates in an objective and critical way. Candidate identifies and foresees potential conflicts of interests. meets the criteria

EXTERNAL AWARENESS

Candidate continuously monitors the status of the organisation, its internal power structure and adopted methods of operation. Candidate has good awareness regarding the domestic and global economic situation (including financial, economic and social development) that may have an impact on the organisation and interests of individual entities. At the same time, Candidate can effectively use this information. high

NEGOTIATIONS average*

Candidate identifies and discloses interests in a way intended to reach a consensus in the
pursuit of negotiating objectives.
PERSUASION
Candidate can influence the opinions of others, using their gift of persuasion and natural
authority and tact. Candidate has a strong personality and ability to remain unyielding.
high
TEAMWORK
Candidate is aware of the group interest and contributes to achieving the common objective;
Candidate can function as part of the group.
high
STRATEGIC SKILLS
Candidate can create and develop realistic plans and strategies related to future development
(including by using scenario analysis), which translates into the ability to set long-term goals.
Candidate appropriately takes into consideration risk to which the organisation is exposed
and takes appropriate steps to manage this risk.
average*
RESISTANCE TO STRESS
Candidate is resistant to stress and can act logically, even under strong pressure and in
moments of uncertainty.
high
SENSE OF RESPONSIBILITY
Candidate understands internal and external conditions and motivations, carefully assesses
them and takes them into consideration. Candidate can draw conclusions and is aware that
their actions affect the interests of interested parties.
meets the
criteria
CHAIRING MEETINGS
Candidate can effectively and efficiently chair meetings, creating an atmosphere of openness
and encouraging everyone to participate on equal terms; Candidate is task-oriented and aware
of the responsibilities of others.
high
ABILITY TO ASK THE RIGHT QUESTIONS TO MEMBERS OF MANAGING
BODIES OF THE ENTITY UNDER SUPERVISION high
Candidate has the ability to address problematic issues with members of managing bodies of
the entity under supervision
GROUPTHINK
The candidate has the ability to resist groupthink. high

on: assessment of the collective suitability of the Supervisory Board of Alior Bank S.A.

Pursuant to § 17 (2)(11) of the Articles of Association of Alior Bank S.A. in conjunction with § 10 (7) of the "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A." ("Selection and Assessment Policy"), the Annual General Meeting resolves as follows:

§ 1

The Annual General Meeting of the Bank approves the positive assessment of the collective suitability of the Supervisory Board of the Bank as at the end of the financial year 2024 and concludes that the Supervisory Board of the Bank in the financial year 2024 met the requirements set out in the Selection and Assessment Policy, including in particular:

  • a) an adequate number of its members met the independence criteria;
  • b) an adequate number of its members held the required accounting knowledge and skills;
  • c) an adequate number of its members held the required auditing knowledge and skills;
  • d) an adequate number of its members held the required knowledge and skills in the financial sector;
  • e) all members of the Supervisory Board of the Bank had at least a high level of competence to chair meetings;
  • f) the Supervisory Board of the Bank had the required level of other competencies as a body;
  • g) the members of the Supervisory Board of the Bank declared their willingness to devote sufficient time to perform their duties as members of the Supervisory Board of the Bank.

§ 2

The Resolution enters into force on the date of its adoption.

Justification of the Resolution of the Annual General Meeting of the Bank on the assessment of the collective suitability of the Supervisory Board of Alior Bank S.A.

In accordance with Recommendation 7.3 of the "Recommendation Z on the Internal Governance Principles in Banks," issued by the Polish Financial Supervision Authority, the bodies of a bank responsible for appointing individuals to specified functions or positions are also responsible for ensuring appropriate selection and assessment of the suitability of supervisory board members. Pursuant to § 10(7) of the "Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A." attached to Resolution No. 10/2024 of the Annual General Meeting of Alior Bank Spółka Akcyjna dated 26 April 2024, the General Meeting shall approve the collective suitability assessment of the Supervisory Board at least once a year, based on information as at the end of the financial year. The Supervisory Board of the Bank submitted to the General Meeting of Shareholders information that, in carrying out the collective suitability assessment, it had taken into account the results of the individual suitability assessments of the members of the Supervisory Board to the extent necessary to complete the collective assessment. The Supervisory Board has therefore requested that the General Meeting approve the collective suitability assessment.

on: expressing an opinion on the "Report on the remuneration of members of the Management Board and the Supervisory Board of Alior Bank S.A. for the year 2024" submitted by the Supervisory Board of the Bank.

§ 1

Pursuant to § 17(1)(1b) of the Articles of Association of Alior Bank S.A., the Annual General Meeting of the Bank gives a positive opinion on the "Report on remuneration of members of the Management Board and the Supervisory Board of Alior Bank S.A. for the year 2024", as submitted by the Supervisory Board of the Bank.

§ 2 The Resolution enters into force on the date of its adoption.

Justification of the Resolution of the Annual General Meeting of the Bank on expressing an opinion on the "Report on the remuneration of members of the Management Board and the Supervisory Board of Alior Bank S.A. for the year 2024" submitted by the Supervisory Board of the Bank

Pursuant to § 17(1)(1b) of the Articles of Association of the Bank in conjunction with Article 395 § 2¹ of the Code of Commercial Partnerships and Companies and Article 90g(6) of the Act of 29 July 2005 on Public Offering, Conditions Governing the Introduction of Financial Instruments to Organised Trading, and Public Companies, the General Meeting shall adopt a resolution expressing an opinion on the remuneration report.

Regarding item 17 of the agenda

Resolution No. _/2025 of the Annual General Meeting of Alior Bank Spółka Akcyjna dated 16 June 2025

on: assessment of the adequacy of internal regulations concerning the functioning of the Supervisory Board of Alior Bank S.A. and its effectiveness.

Pursuant to § 17 (2)(11) of the Articles of Association of Alior Bank S.A. and in accordance with recommendation 8.9 of Recommendation Z concerning corporate governance in banks, issued by the Polish Financial Supervision Authority pursuant to Resolution No. 289/2020 of 9 October 2020, the Annual General Meeting of the Bank resolves as follows:

§ 1

Having regard to the following internal regulations of the Bank regarding the functioning of the Supervisory Board of the Bank:

  • − Articles of Association of Alior Bank S.A.,
  • − Organisational Regulations of Alior Bank S.A.,
  • − Regulations of the Supervisory Board of Alior Bank S.A.,
  • − Regulations of the Audit Committee of the Supervisory Board of Alior Bank S.A.,
  • − Regulations of the Nomination and Remuneration Committee of the Supervisory Board of Alior Bank S.A.,
  • − Regulations of the Risk Committee of the Supervisory Board of Alior Bank S.A.,
  • − Regulations of the Committee for Strategy and Development of the Supervisory Board of the Bank of Alior Bank S.A.,
  • − Policy for the Selection and Suitability Assessment of Members of the Supervisory Board of Alior Bank S.A.
  • − Resolution of the Supervisory Board of the Bank on the self-assessment of the adequacy of
  • − internal regulations concerning the functioning of the Supervisory Board of the Bank and effectiveness of the Supervisory Board in the year 2024,

the Annual General Meeting of the Bank positively assesses the adequacy of internal regulations concerning the functioning of the Supervisory Board of the Bank.

§ 2

On the basis of the Report on the Activities of the Supervisory Board of Alior Bank Spółka Akcyjna in the financial year ending 31 December 2024, the Annual General Meeting of the Bank positively assesses the effectiveness of the Supervisory Board of the Bank in the year 2024.

§ 3

The Resolution enters into force on the date of its adoption.

Justification of the Resolution of the Annual General Meeting of the Bank on the assessment of the adequacy of internal regulations concerning the functioning of the Supervisory Board of Alior Bank S.A. and its effectiveness

According to Recommendation 8.9 of Recommendation Z of the Polish Financial Supervision Authority regarding the principles of internal governance in banks, the adequacy of internal regulations governing the functioning of the supervisory board and the effectiveness of its operations should be subject to regular self-assessment and evaluation by the general meeting.

Accordingly, and in view of the adoption by the Supervisory Board of the Bank of Resolution No. 98/2025 of 19 May 2025 on the approval of the "Report on the activities of the Supervisory Board of the Bank in the financial year 2024" and the completion of the self-assessment of the Supervisory Board's operations, the effectiveness of its work, and the adequacy of internal regulations concerning the Supervisory Board's functioning in 2024, it is necessary to submit this draft resolution for deliberation by the Annual General Meeting of the Bank.

on: amendment to the Articles of Association of Alior Bank Spółka Akcyjna.

Pursuant to Article 430 § 1 of the Code of Commercial Partnerships and Companies and § 17(2)(1) of the Articles of Association of Alior Bank Spółka Akcyjna ("Bank"), the following is hereby resolved:

§ 1

The Articles of Association of the Bank shall be amended as follows:

  • 1) in § 7(3), points 4 and 5 shall be added and shall read as follows:
  • "4) to issue capital bonds within the meaning of Article 27a of the Act of 15 January 2015 on Bonds,
  • 5) to issue convertible bonds within the meaning of Article 19(1) of the Act of 15 January 2015 on Bonds.";
  • 2) § 17(2)(6), which currently reads:
  • "6) to issue convertible bonds and bonds with pre-emptive rights to subscribe for shares of the Bank, as well as subscription warrants,"

shall now read as follows:

"6) to issue convertible bonds, bonds with pre-emptive rights to subscribe for shares of the Bank, as well as subscription warrants and capital bonds,".

§ 2

The Annual General Meeting of the Bank authorises the Supervisory Board of the Bank to compile a consolidated version of the Articles of Association, incorporating the amendments introduced by means of the present resolution.

§ 3

The resolution shall enter into force on the date of its adoption, with binding effect as of the entry of the amendments to the Articles of Association into the register of entrepreneurs of the National Court Register.

Justification of the resolution of the Annual General Meeting of the Bank on the amendments to the Articles of Association of Alior Bank Spółka Akcyjna

The proposed amendments to the Articles of Association of the Bank are related to the introduction of Article 27a into the Act of 15 January 2015 on Bonds ("Bonds Act"), which enables banks to issue capital bonds. According to this provision, capital bonds are issued with the aim of qualifying them as own funds instruments:

1) as additional Tier I instruments or

2) as Tier II instruments,

in accordance with the provisions of Articles 52 and 63 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and amending Regulation (EU) No 648/2012.

Accordingly, it is proposed to add a new point 4 in § 7(3) of the Articles of Association of the Bank to enable the Bank to issue capital bonds. At the same time, a technical amendment to § 17(2)(6) of the Articles of Association is proposed, so that the requirement for a resolution of the General Meeting also applies to the issuance of capital bonds.

Furthermore, to align the wording of the Articles of Association with the provisions of the Bonds Act, it is proposed that § 7(3)(5) of the Articles of Association explicitly states that the Bank may issue convertible bonds. Pursuant to Article 19(1) of the Bonds Act, the issuance of convertible bonds is permitted only if provided for in the company's articles of association. While the current wording of the Articles of Association of the Bank implies such possibility (as § 17(2)(6) of the Articles of Association states that the issuance of convertible bonds requires a resolution of the General Meeting), it is recommended, in view of the aforementioned provision of the Bonds Act, to explicitly specify the Bank's authorisation to issue convertible bonds.

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