Bank Pekao S.A.

Board/Management Information • Apr 18, 2024

on the assessment of application by Bank Polska Kasa Opieki Spółka Akcyjna in 2023 of the Principles of Corporate Governance for Supervised Institutions issued by the Polish Financial Supervision Authority on 22 July 2014

Assessment of application by Bank Polska Kasa Opieki Spółka Akcyjna in 2023 of the Principles of Corporate Governance for Supervised Institutions issued by the Polish Financial Supervision Authority on 22 July 2014

On 14 October 2014 by the Resolution No. 356/X/14 the Management Board of Bank Polska Kasa Opieki Spółka Akcyjna (the "Bank") adopted for application by the Bank the Principles of Corporate Governance for Supervised Institutions issued by the Polish Financial Supervision Authority on 22 July 2014 (hereinafter "Principles"). On 5 November 2014, The Bank's Supervisory Board by the Resolution No. 33/14 issued a positive opinion on the adoption of the Principles by the Bank. Due to the fact that some of the recommendations were addressed to the shareholders, the Bank's Ordinary General Meeting on 30 April 2015 passed Resolution No. 25 on the adoption of the Principles for application.

In order to meet the requirements of § 27 of the Principles, according to which the supervising body evaluates the application of the Principles on a regular basis and the results of that evaluation are published on the website of the supervised institution and communicated to other bodies of the supervised institution, and in relation to § 18 p 20 of the Statute of Bank Polska Kasa Opieki Spółka Akcyjna and § 4 item 2 of the Rules of procedure of Supervisory Board, an analysis of the application of the Principles by the Bank in 2023 was conducted.

As a result of this analysis carried out on the basis of information provided by the Bank's units responsible for the application of individual Principles, it was established that in 2023 the Bank applied the Principles with the exception of:

• chapter 9 regarding management of assets at customer risk due to the fact that the Bank does not pursue any activity in this area, and doesn't offer products involving the management of assets at the client's risk,
• § 49 item 4 and § 52 item 2 due to the fact that the Bank has an audit and a compliance unit and therefore these provisions do not apply to the Bank.

The Bank applied the principle set out in § 21 item 2 of the Corporate Governance Principles for the Supervised Institutions regarding the chairman of the Supervisory Board. The election of the Chairman of the Bank's Supervisory Board was made on the basis of knowledge, experience, including the management of the body, and skills that confirm the competences necessary for the proper performance of supervision duties. Moreover, in accordance with point 90 of the Guidelines on the assessment of the suitability of members of the management body and persons performing key functions EBA/GL/2021/06, ESMA35-36-2319 of 2 July 2021, the Bank recognizes that the Chairman of the Supervisory Board of the Bank is independent.

ASSESSMENT OF SUPERVISORY BOARD

The Bank's Supervisory Board, acting on the basis of § 27 of the Principles, having acknowledged the results of the analysis of the application of the Principles by the Bank in 2023, has not identified any misconduct in their application. The Bank's Supervisory Board positively assesses the Bank's actions in this respect as adequate and consistent with the requirements of the said rules.