CD Projekt — AGM Information 2023

May 10, 2023

Documentation submitted to the Ordinary General Meeting of

CD PROJEKT S.A. scheduled for 6 June 2023

On 30 March 2023 the Company published its annual financial statement, which included, among others, the following items:

• Management Board report on CD PROJEKT Capital Group and CD PROJEKT S.A. activities in 2022;
• Financial statement of CD PROJEKT S.A. for 2022;
• Audit report concerning the financial statement of CD PROJEKT S.A. for 2022;
• Consolidated Financial Statement of the CD PROJEKT Capital Group for 2022;
• Audit report concerning the Consolidated Financial Statement of the CD PROJEKT Capital Group for 2022.

The Company, with regard to the fact that the Company's merger with its subsidiary CD PROJEKT RED STORE sp. z o.o. was registered on 28 February 2023, also publishes:

• Management Board report on CD PROJEKT RED STORE sp. z o.o. activities in 2022;
• Financial statement of CD PROJEKT RED STORE sp. z o.o. for 2022;
• Audit report concerning the financial statement of CD PROJEKT RED STORE sp. z o.o. for 2022;

On 20 April 2023 the Company published a merger plan signed on that day between the Company and its subsidiary SPOKKO sp. z o.o. (including the annexes to the plan), which constitutes an annex to resolution to no. 24.

On 9 May 2023 the Supervisory Board adopted a resolution concerning adoption of the CD PROJEKT S.A. Supervisory Board report on the remuneration of the Management Board and the Supervisory Board for 2022.

This documentation has been published on www.cdprojekt.com and is also available at the Company headquarters.

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Furthermore, the following resolutions and reports of the Supervisory Board are submitted to the Ordinary General Meeting:

Resolution no. 1 of 9 May 2023

of the Supervisory Board of CD PROJEKT S.A.

concerning assessment of the Company financial statement for 2022, Management Board recommendation concerning allocation of net profit for 2022, Management Board report on CD PROJEKT Group and CD PROJEKT S.A. activities in 2022 and Consolidated Financial Statement of the CD PROJEKT Group for 2022, and approval and submission to the General Meeting of the results of assessment of the Company financial statement for 2022, Management Board recommendation concerning allocation of net profit for 2022, Management Board report on CD PROJEKT Group and CD PROJEKT S.A. activities in 2022 and Consolidated Financial Statement of the CD PROJEKT Group for 2022, along with the Supervisory Board report on the activities of the Supervisory Board in 2022, together with an assessment of the work of the Supervisory Board, assessment of the condition of the Company which acknowledges the adequacy and effectiveness of its internal control systems, risk management, compliance with

the applicable norms and practices, internal audit, and discharge by the Company of its disclosure obligations with regard to corporate governance policies

Pursuant to Art. 382 § 3, art. 382 § 3¹ of the Commercial Companies Code and item 2.11 of the Best Practice for WSE Listed Companies, the Supervisory Board has decided the following:

§ 1

• 1. Having carried out an assessment of the Financial Statement of the Company for 2022, along with the audit report concerning the annual financial statement, submitted by an independent auditor, the Supervisory Board declares that the Financial Statement of CD PROJEKT S.A. for 2022 is materially consistent with the existing accounts and documents, as well as factually correct.
• 1. The Supervisory Board submits the Financial Statement of the Company for 2022 to the General Meeting along with motion for its approval.
• 1. Having carried out an assessment of the Financial Statement of the Company for 2022, along with the Management Board recommendation concerning allocation of net profit, expressed in CD PROJEKT S.A. Management Board Resolution no. 10/2023 of 8 May 2023 on the adoption and on the submitting of the recommendation to the Supervisory Board and the Annual General Meeting of the motion regarding the allocation of the net profit, the Supervisory Board hereby recommends that the net profit for 2022, in the amount of 341 072 820.59 (three hundred fortyone million seventy-two thousand eight hundred twenty 59/100) PLN be allocated as follows: a) 99 910 510.00 (ninety-nine million nine hundred ten thousand five hundred ten 00/100) PLN is to be divided among shareholders by issuing a dividend at 1.00 (one) PLN per each of the 99 910 510 (ninety-nine million nine hundred ten thousand five hundred ten) shares participating in the dividend; moreover, a request is submitted to the Ordinary General Meeting of the Company to set the dividend record date to 13 June 2023 and the dividend payment date to 20 June 2023;

b) the remaining portion of the profit, i.e. 241 162 310.59 (two hundred forty-one million one hundred sixty-two thousand three hundred ten 59/100) is to be allocated to the Company's reserve capital;

Having carried out an assessment of the Consolidated Financial Statement of the CD PROJEKT Group for 2022 and the Management Board report on the activities of the CD PROJEKT Group and CD PROJEKT S.A. in 2022, along with the audit report concerning the annual consolidated financial statement, submitted by an independent auditor, the Supervisory Board declares that the Consolidated Financial Statement of the CD PROJEKT Group for 2022 and the Management Board report on the activities of the CD PROJEKT Group and CD PROJEKT S.A. in 2022 are materially consistent with the existing accounts and documents, as well as factually correct.

• 1. The Supervisory Board submits the Consolidated Financial Statement of the CD PROJEKT Group for 2022 and the Management Board report on the activities of the CD PROJEKT Group and CD PROJEKT S.A. in 2022 to the General Meeting along with a motion for their approval.
• 1. The Supervisory Board adopts and submits to the General Meeting the Supervisory Board report on the activities of the Supervisory Board in 2022, together with an assessment of the work of the Supervisory Board, assessment of the condition of the Company which acknowledges the adequacy and effectiveness of its internal control systems, risk management, compliance with the applicable norms and practices, internal audit, and discharge by the Company of its

disclosure obligations with regard to corporate governance policies, as appended to this resolution, along with a motion for its approval.

§ 2

The resolution enters into force on the date of its adoption

Supervisory Board report concerning results of assessment of the Company financial statement for 2022, Management Board recommendation concerning allocation of net profit for 2022, Management Board report on CD PROJEKT Group and CD PROJEKT S.A. activities in 2022 and Consolidated Financial Statement of the CD PROJEKT Group for 2022, along with Supervisory Board report on the activities of the Supervisory Board in 2022, together with an assessment of the work of the Supervisory Board, assessment of the condition of the Company which acknowledges the adequacy and effectiveness of its internal control systems, risk management, compliance with the applicable norms and practices, internal audit, and discharge by the Company of its disclosure obligations with regard to corporate governance policies

I. Assessment of the financial statement for the period between 1 January 2022 and 31 December 2022 of CD PROJEKT S.A. with its registered seat in Warsaw

In the course of discharging its official duties, the Supervisory Board adopted Resolution no. 1 of 9 March 2022, selecting Grant Thornton Polska sp. z o.o. sp. k. with a registered office in Poznań as the audit firm contracted to perform an audit of the financial statement for the period between 1 January 2022 and 31 December 2022.

The audit concerned the Financial Statement covering the period between 1 January and 31 December 2022, prepared on 30 March 2023.

The Supervisory Board familiarized itself with the audit report prepared by an independent auditor concerning the Financial Statement for 2022, provided by the audit firm contracted to perform the audit. With regard to the aforementioned financial statement, on 30 March 2023 the auditor issued an opinion declaring that the financial statement, which comprises numerical data and supplementary information:

• presents a truthful and clear description of the material and financial standing of the Company as of 31 December 2022, along with its financial results and cash flows for the financial year ending on that date, in line with the International Accounting Standards, International Financial Reporting Standards, interpretations associated therewith as published in the relevant European Commission regulations, as well as the adopted accounting practices,
• is based on properly maintained accounting records,
• is formally and materially consistent with the legal requirements applicable to the Company as well as its Articles.

The abovementioned opinion is consistent with the supplementary report provided to the Audit Committee on 30 March 2023.

The abovementioned outcome of the audit formed the basis for the Supervisory Board assessment of the Financial Statement of the Company for 2022.

Having reviewed the audit report submitted thereto, the Supervisory Board declares that the Financial Statement of the Company for 2022 is materially consistent with existing accounts and documents, as well as factually correct.A

II. Assessment of the recommendation of the Management Board of CD PROJEKT S.A. with a registered seat in Warsaw concerning allocation of net profit for 2022

Having performer an assessment of the Financial Statement of the Company for 2022 and the Management Board's recommendation concerning allocation of net profit expressed in CD PROJEKT S.A. Management Board resolution no. 10/2023 of 8 May 2023 on the adoption and on the submitting of the recommendation to the Supervisory Board and the Annual General Meeting of the motion regarding the allocation of the net profit, the Supervisory Board hereby recommends that the net profit for 2022, in the amount of 341 072 820.59 (three hundred forty-one million seventy-two thousand eight hundred twenty 59/100) PLN be allocated as follows:

• a) 99 910 510.00 (ninety-nine million nine hundred ten thousand five hundred ten 00/100) PLN is to be divided among shareholders by issuing a dividend at 1.00 (one) PLN per each of the 99 910 510 (ninety-nine million nine hundred ten thousand five hundred ten) shares participating in the dividend; moreover, a request is submitted to the Ordinary General Meeting of the Company to set the dividend record date to 13 June 2023 and the dividend payment date to 20 June 2023;
• b) the remaining portion of the profit, i.e. 241 162 310.59 (two hundred forty-one million one hundred sixty-two thousand three hundred ten 59/100) is to be allocated to the Company's reserve capital;

III. Assessment of the Consolidated Financial Statement of the CD PROJEKT Group and the Management Board report on the activities of the CD PROJEKT Group and CD PROJEKT S.A. in 2022

In the course of discharging its official duties, the Supervisory Board adopted Resolution no. 1 of 9 March 2022, selecting Grant Thornton Polska sp. z o.o. sp. k. with a registered office in Poznań as the audit firm contracted to perform an audit of the Consolidated Financial Statement of the CD PROJEKT Group as well as the Management Board report on the activities of the CD PROJEKT Group and CD PROJEKT S.A. for the period between 1 January 2022 and 31 December 2022.

The audit concerned the consolidated financial statement covering the period between 1 January and 31 December 2022, prepared on 30 March 2023.

The Management Board submitted to the Supervisory Board an audit report prepared by an independent auditor concerning the consolidated financial statement for 2022, provided by the audit firm contracted to perform the audit.

With regard to the aforementioned financial statement, on 30 March 2023 the auditor issued an opinion declaring that the financial statement, which comprises numerical data and supplementary information:

• presents a truthful and clear description of the material and financial standing of the Group as of 31 December 2022, along with its financial results and cash flows for the financial year ending on that date, in line with the International Accounting Standards, International Financial Reporting Standards, interpretations associated therewith as published in the relevant European Commission regulations, as well as the adopted accounting practices,
• is formally and materially consistent with the legal requirements applicable to the Group as well as the Articles of Association of its Parent Company.

The abovementioned opinion is consistent with the supplementary report provided to the Audit Committee on 30 March 2023.

The abovementioned outcome of the audit formed the basis for the Supervisory Board assessment of the Consolidated Financial Statement of the CD PROJEKT Group for 2022.

Having reviewed the audit report submitted thereto, the Supervisory Board declares that the Consolidated Financial Statement of the CD PROJEKT Group for 2022 is materially consistent with existing accounts and documents, as well as factually correct.

Similarly, with regard to its assessment of the Management Board report on CD PROJEKT Group and CD PROJEKT S.A. activities between 1 January and 31 December 2022, the Supervisory Board availed itself of the documentation provided by the abovementioned audit firm. The Supervisory Board concurs with the auditor's opinion, issued on 30 March 2023, that this report is consistent with the applicable legal regulations as well as with information contained in the consolidated financial statement attached thereto. This is supplemented by a statement to the effect that, given the knowledge concerning the Group and its environment gained in the course of auditing its financial statement, no significant discrepancies have been identified in the report on the Group's activities.

IV. Supervisory Board report on the activities of the Supervisory Board in 2022, together with an assessment of the work of the Supervisory Board, assessment of the condition of the Company which acknowledges the adequacy and effectiveness of its internal control systems, risk management, compliance with the applicable norms and practices, internal audit, and discharge by the Company of its disclosure obligations with regard to corporate governance policies

In the course of discharging its obligations stemming from the Commercial Companies Code ("CCC"), Best Practices for WSE Listed Companies, 2021 edition ("BP2021"), the Company Articles and the CD PROJEKT S.A. Supervisory Board Regulations, the Supervisory Board of CD PROJEKT S.A. ("CD PROJEKT S.A.", "the Company") submits to the Ordinary General Meeting the Supervisory Board Report for the period between 1 January and 31 December 2021 (principle 2.11 of BP2021), including:

• information regarding the composition of the Supervisory Board and its committees, including the independence of members of the Supervisory Board, along with information regarding the composition of the Supervisory Board in the context of diversity (principle 2.11.1 of BP2021),

• summary of the activities of the Supervisory Board and its committees (principle 2.11.2 of BP2021),

• consolidated assessment of the condition of the Company, along with its internal control, risk management, compliance and internal audit systems (principle 2.11.3 of BP2021; Art. 382 §3¹ of CCC),

• assessment of the discharge, by the Management Board, of duties specified in Art. 380¹ of CCC; assessment of the means by which the Management Board prepares or submits to the Supervisory Board information, documentation, reports and clarification sought in accordance with Art. 382 § 4 of CCC; information on the total remuneration payable by the Company in association with audits commissioned by the Supervisory Board during the given financial year, as specified in Art. 382¹ of the CCC (Art. 382 § 3¹ of the CCC),

• assessment of expenditures incurred by the Company and its Group in the context of supporting culture, sports, charities, media, NGOs and trade unions (principle 2.11.5 of BP2021),

• assessment of the observance, by the Company, of corporate governance policies and discharge of disclosure obligations related thereto, as specified in the Stock Exchange Regulations and regulations concerning current and periodic disclosures required from issuers of securities (principle 2.11.4 of BP2021),

The term "Best Practices for WSE Listed Companies, 2021 edition" denotes a collection of corporate governance practices bearing the aforementioned title, which is annexed to Resolution no. 13/1834/2021 of the Supervisory Board of the Warsaw Stock Exchange, dated 29 March 2021.

IV.1. Composition of the Supervisory Board during the 2022 financial year

In the 2022 financial year, the following persons held membership of the Supervisory Board:

Between 1 January and 31 December 2022:

• I) Katarzyna Szwarc Chairperson of the Supervisory Board; Member of the Supervisory Board lacking actual and significant ties to any shareholder controlling at least 5% of the total number of votes in the Company,
• II) Piotr Pągowski Deputy Chairperson of the Supervisory Board; Member of the Supervisory Board lacking actual and significant ties to any shareholder controlling at least 5% of the total number of votes in the Company, meeting independence criteria expressed in the act of 11 May 2017 on licensed auditors, audit firms and public supervision,
• III) Maciej Nielubowicz Secretary of the Supervisory Board,
• IV) Łukasz Wejchert Member of the Supervisory Board lacking actual and significant ties to any shareholder controlling at least 5% of the total number of votes in the Company, meeting independence criteria expressed in the act of 11 May 2017 on licensed auditors, audit firms and public supervision,
• V) Michał Bień Member of the Supervisory Board lacking actual and significant ties to any shareholder controlling at least 5% of the total number of votes in the Company, meeting independence criteria expressed in the act of 11 May 2017 on licensed auditors, audit firms and public supervision,

During the 2022 financial year the composition of the Supervisory Board included one woman.

IV.2. Scope of activities of the Supervisory Board during the reporting period, including discharge of duties of the Audit Committee:

In the course of discharging its legal and statutory obligations in 2022 the Supervisory Board conducted active oversight of all matters related to Company activities.

In particular, the Supervisory Board performed analyses of the Management Board's plans concerning the strategy of the Company and its Group, and provided ongoing assessment of the Company's operating and financial status.

In 2022 the Supervisory Board of CD PROJEKT S.A. properly discharged all duties incumbent upon the supervisory board of a public company under the relevant legislation, the Company Articles of Association and the Supervisory Board Regulations.

The Supervisory Board held six meetings in 2022. Additionally, the Supervisory Board conducted its affairs by adopting resolutions outside of meetings.

In line with its prerogatives, in 2022 the Supervisory Board furthermore observed a significant portion of the Best Practices for WSE Listed Companies insofar as such practices apply to supervisory board of public companies.

Pursuant to the Act of 11 May 2017 on licensed auditors, audit firms and public supervision ("the Act"), an Audit Committee operated within the framework of the Supervisory Board, with the following composition:

Between 1 January and 31 December 2022:

• I) Michał Bień Chairperson of the Audit Committee meeting independence criteria specified in Art. 129 section 3 of the Act,
• II) Maciej Nielubowicz Member of the Audit Committee possessing knowledge and expertise in the scope of accounting or auditing financial statements,
• III) Łukasz Wejchert Member of the Audit Committee meeting independence criteria specified in Art. 129 section 3 of the Act,
• IV) Piotr Pągowski Member of the Audit Committee meeting independence criteria specified in Art. 129 section 5 of the Act,
• V) Katarzyna Szwarc Member of the Audit Committee meeting independence criteria specified in Art. 129 section 5 of the Act.

The Audit Committee held four meetings during the reporting period. Additionally, the Audit Committee performed its work outside of meetings.

In the course of discharging its duties, the Audit Committee, among others, monitored the financial reporting and financial audit activities, i.a. by analyzing the Company's periodic financial statements prior to their publication and organizing periodic meetings with auditors.

In the Supervisory Board's opinion, the current composition of the Supervisory Board enables fulfillment of all tasks incumbent upon the control organ of a public company.

In 2022 the supervisory activities of the Supervisory Board of CD PROJEKT S.A. were exercised on an ongoing basis and with due diligence. The Supervisory Board carefully monitored all significant matters related to the Company's activities. As requested by the Supervisory Board, the Management Board provided up-to-date reports regarding the legal condition of the Company and activities undertaken in all of the Company's activity areas.

In discharging its supervisory duties, the Supervisory Board relied on written documentation submitted by the Management Board as well as current information and explanations provided by Board Members during Supervisory Board meetings. As a rule, Supervisory Board meetings were attended by the Management Board except in matters related to assessment of the Management Board's performance and other personal matters involving members of the Management Board. The Supervisory Board made extensive use of remote communication tools, enabling better control and day-to-day supervision of the Company's matters.

IV.3. 3. Summary assessment of the Company's condition, including its internal control system, risk management, compliance and internal audit mechanisms

Based on analysis of financial statements of the Company and its Group for the year 2022 and the Management Board report on internal control, risk management, compliance and internal audit systems at CD PROJEKT S.A. in 2022, in addition to information received directly from the Management Board, the Supervisory Board concludes that the Company's condition is stable. In assessing the condition of the Company in 2022, the Supervisory Board analyzed key risks faced by the Company and did not identify any circumstances which would jeopardize continuation of the Company's activities.

Internal control and risk management systems at the Company are fully controlled by the Management Board, which, in the course of publishing its periodic reports, conducts periodic assessment of risk factors relevant to the Company during each financial year.

Internal Control System

A comprehensive control system is in place at the Company, particularly with regard to preparation of financial statements and consolidated financial statements, with the aim to ensure that the Company meets its stated goals related to operational effectiveness and efficiency, reliability of financial statement, and legal compliance.

The Management Board takes part in daily business activities at the Company and remains in contact with persons charged with managing the Company's subsidiaries. Control activities are rooted in internal regulations (including policies, procedures and manuals) which specify the duties and responsibilities of each member of the team, thereby mitigating the risk of errors in each activity area of the Company.

Regarding financials, the internal control system mandates monthly assessment of results against the background of earlier projections within each activity segment of the CD PROJEKT Group.

As part of its reporting and review scheme, the Management Board of the Company performs monthly analysis of results and how they compare to earlier estimates. These analyses are conducted in collaboration with managers of each segment. The meetings also provide an opportunity to discuss important developments affecting each segment and the likelihood of meeting projections in further months.

Approval of expenditures incurred by the Company is based on formalized approval procedures, and utilizes an electronic document flow and authorization system. The approval process also involves the Legal Department and – in selected cases – the Tax Department and the Procurement Department.

As part of the financial control and cash management procedures observed by members of the Financial Department (including financial control), a hierarchical payment authorization system is in force. All payments remitted by the Company are based on properly filed accounting documents. A document may only be filed if it meets all the applicable accuracy and justifiability criteria, and has been approved by the person appointed for this purpose in the Company's internal electronic document flow system. Validation of the above and the actual filing of the document is the responsibility of the assigned accountant. On a day-to-day basis, payments are handled by the Financial Department in collaboration with the Accounting Department. Any deviations from this rule must be approved by a representative of the Management Board.

Supervising the preparation of financial statements is the responsibility of the Chief Accountant and the Vice President for Financial Affairs.

Financial statements and consolidated financial statements are prepared in accordance with International Financial Reporting Standards (IFRS), the Accounting Act of 29 September 1994 (JL 1994, no. 121, item 591, as amended) and the CD PROJEKT S.A. Accounting Policy.

To ensure alignment between the CD PROJEKT S.A. Accounting Policy and other applicable regulations – IFRS in particular – the Policy is subject to periodic updates, the responsibility for which rests with the Management Board of the Company.

Throughout 2022 the Company's accounts were managed by its internal Accounting Department. In addition, the Department provided paid accounting services to one of the CD PROJEKT Group's subsidiaries – Spokko sp. z o.o.

The separate and consolidated financial statements of the Company are subject to reviews and audits performed by an independent licensed auditor, in line with the applicable regulations, including the Act of 11 May 2017 on licensed auditors, audit firms and public supervision (JL 2022, item 1302, as amended) and the Company's internal policy regulating selection and rotation of the entity authorized to perform audits of financial statements, and procurement of other permissible services which do not constitute audits of financial statements from the entity authorized to perform such audits.

In addition, a stock-taking instruction is in force at the Company, specifying the means of preparing, conducting, evaluating and settling assets and liabilities, along with any off-balance sheet conditional liabilities and sureties. This instruction is consistent with the provisions of the Accounting Act (JL 1994, No. 121, item 591, as amended).

In the course of carrying out its activities, the Company relies on a formal document approval system.

The Information Security Department and the IT Department are jointly responsible for maintaining the security, availability, confidentiality and integrity of information processed in the Company's IT systems.

The Company's organizational structure introduces a hierarchy of duties, minimizing the risk that economic activities might be performed by a single individual. Recruitment is organized in such a way as to ensure that the best prospective candidate is selected for each open position. The Company employs competent persons, cares for their career development and provides them with incentives to remain at the organization.

The process of discharging control obligations involves, to a large extent, the Financial Department, the Accounting Department and the HR Department, the latter of which institutes HR management policies and works to maintain the expected level of staffing. Any new internal regulations or processes are disseminated throughout the Company with help from the Internal Communication Department, which works to ensure that they remain clear and understandable for all team members.

Risk Management

A formalized Risk Management Procedure is in force at the Company, along with strategic risk management procedures based thereupon. The risk management process at the Company permits assessment of each risk, determining ways to handle risk factors, and monitoring existing risks.

The goal of the aforementioned procedure is to retain an acceptable level of risk for each identified threat, and thereby mitigate the consequences of potential events which may negatively impact the activities and financial stability of the Company.

In the Management Board Report on the activities of the CD PROJEKT Group in 2022 the Company identified and described risk factors relevant to business, legal, team-related, financial and environmental areas.

A clear division of responsibilities is in place in the context of risk management. To enforce it, the Management Board has appointed a Risk Management Committee, which comprises risk owners.

Strategic risks are identified by risk owners in the framework of the Risk Management Committee, for each area of the Company's activities, acknowledging external and internal factors which may affect the Company's strategic goals. The Risk Management Committee defines risk categories and maintains a list of risks regarded as strategic, subject to approval by the Management Board.

In 2022 the Risk Management Committee held 10 meetings during which 18 strategic risks were analyzed.

Risk analysis involves determining the impact and probability of occurrence of each risk. In assessing the probability of occurrence, the effectiveness of control mechanisms is taken into account, while impact assessment focuses on potential consequences for the Company, whether financial or otherwise. The materiality of each risk is then determined as the product of its likelihood and impact, and plotted on the risk value matrix. Following analysis, the Risk Management Committee submits the collected information to the Management Board for approval. The Management Board may subsequently decide how to handle the given risk, depending on its materiality. It may decide to accept, reduce, transfer or avoid the risk. If a risk exceeds the acceptability threshold, its owner, working in collaboration with the Risk Management Committee, developers recommendations regarding control mechanisms and remedial actions.

Compliance

Compliance management at the Company is based on legal regulations, market standards, Best Practices for WSE Listed Companies, 2021 edition, and recommended compliance standards in the area of counteracting corruption and whistleblower protection for companies traded on the regulated markets of the Warsaw Stock Exchange.

In this scope, activities undertaken by the Company aim to foster a culture of compliance and minimize the risk of noncompliance. Compliance management is based on the Deming cycle (Plan, Do, Check, Act), which permits monitoring and progressive optimization.

A formal Compliance Management Policy was introduced at the Company in 2022, based on which a Compliance Program was defined.

In 2021 the Company instituted – for the first time ever – an internal ethics code for all team members and business partners of the Group – Business and Ethics Standards at the CD PROJEKT Group.

The Standards are an expression of the pledge, on the part of the Company and members of its team, to abide by ethical norms and values embraced by the CD PROJEKT Group in their daily work.

In accordance with the Compliance Management Policy, the Management Board has appointed a Chief Compliance Officer (Ewelina Jarosz-Zgoda, GC), who, together with the Privacy & Compliance team, monitors and addresses the Company's needs with regard to compliance management. Compliance

involves continually improving team members' competences through participation in training, conferences and certification (eg. Approved Compliance Expert, Approved Whistleblowing Officer).

The compliance management process also entails participation of departments and teams charged with monitoring and deploying compliance-related solutions, whether mandated by the law or based on voluntarily accepted standards. Daily activities in this regard are undertaken, in particular, by members of the following departments: Legal (Privacy & Compliance team), Administration (environmental aspects), Tax and Information Security.

Changes in the Company's regulatory environment are monitored on an ongoing basis by the Privacy & Compliance team, which analyzes draft laws and newly introduced regulations, announcements and guidelines issued by public authorities, and reports commissioned from external law firms.

The Company introduces internal regulations, including policies and procedures, as required given the scale of its activities and its specific organizational structure. Internal regulations are posted in an intranet repository available to all team members, and are subject to periodic reviews and updates. Developing internal regulations is the responsibility of the department to which the given regulation pertains. The Privacy & Compliance team issues opinions and assists in the development of new regulations to ensure that they remain consistent with the applicable laws and with other regulations in force at the Company. The following internal regulations were introduced in 2022:

• CD PROJEKT Group anti-corruption policy, together with Rules for giving and accepting gifts,
• CD PROJEKT S.A. compliance management policy,
• CD PROJEKT Group information security policy,
• CD PROJEKT S.A. business travel policy,
• CD PROJEKT S.A. environmental policy,
• CD PROJEKT S.A. procurement policy.

Two internal regulations at the Company concern whistleblowing. One of them is the Procedure for reporting irregularities at CD PROJEKT S.A., which governs reports of infringement, or suspected future infringement, of laws, ethical norms or internal regulations.

In 2022 two reports were filed under this procedure, concerning suspected irregularities in the procurement process and suspected leak of information respectively. In both cases, following investigation, no actual infringement of procedures was declared; however, preventative measures were introduced nonetheless.

In the scope of its whistleblowing procedures the Company monitors the potential for irregularities and improper conduct. When such irregularities arise, action is undertaken to mitigate their potential consequences.

Internal Audit

Internal audit has not been entrusted to a dedicated organizational unit at the Company; however, the Company aims to ensure that internal audit tasks are handled by its existing units, as appropriate.

Summary

The Supervisory Board regards the previously described internal control and key risk management procedures as consistent. The Supervisory Board furthermore believes that throughout 2022 the Company's internal control system and key risk management system operated in a satisfactory manner, significantly mitigating key risk factors faced by the Company in the course of its business activities.

IV.4. Assessment of the discharge, by the Management Board, of duties specified in Art. 380¹ of CCC; assessment of the means by which the Management Board prepares or submits to the Supervisory Board information, documentation, reports and clarification sought in accordance with Art. 382 § 4 of CCC; information on the total remuneration payable by the Company in association with audits commissioned by the Supervisory Board during the given financial year, as specified in Art. 382¹ of the CCC

According to § 14 section 2 of the Company Articles, as approved by the Ordinary General Meeting on 28 June 2022, the Management Board is obligated to notify the Supervisory Board of the Company of the Company's condition, including with regard to its assets, along with any notable developments related to the Company's affairs, transactions or other events or circumstances which have, or may have, a significant impact on the Company's material status, including its profitability or liquidity, as well as of changes in information previously provided to the Supervisory Board, if such changes have, or may have, a significant impact on the Company's condition. With regard to subsidiaries, the aforementioned obligation of the Management Board is limited to information in possession thereof, which may be regarded as significant in the context of the Company's material status. Such notifications may be provided in any form listed in the Management Board Regulations and Supervisory Board Regulations as an appropriate means of communication between the Management Board and the Supervisory Board, including in electronic form, as well as orally, during Supervisory Board meetings. The disclosure obligations specified in Art. 380¹ § 1 and 2 of the Commercial Companies Code are excluded from the scope of § 14 section 2 of the Company Articles.

Throughout 2022 the Management Board provided the Supervisory Board with ongoing disclosures specified in § 14 section 2 of the Company Articles, as well as with all requested information, documentation, reports and clarifications related to the Company and particularly to its activities or assets, including in the context of subsidiaries and affiliates.

The Supervisory Board did not commission any audits under Art. 382¹ of the CCC.

IV.5. Assessment of expenditures incurred by the Company and its Group in the context of supporting culture, sports, charities, media, NGOs and trade unions

The Company does not have a separate policy regulating sponsorships and charitable activities.

CD PROJEKT works to have a positive effect on its social environment, integrate employees around a shared set of values and assist others with the resources and skills at its disposal. The Company engages in social projects, national charity drives and global activities which aim to assist the needy – this is done through material donations, financial support or knowledge sharing. The Company also implements projects addressed at the youth, helping participants gain skills and experience in the gaming industry.

In 2022 a total of 1 210 611 PLN was donated to charity. Beneficiaries included the Polish Humanitarian Action, Tech to the Rescue (enlisting companies from the technology sector to assist Ukrainian nonprofit organizations by delivering digital solutions with the aim to preserve the integrity of Ukraine in the face of war), the Central Clinical Hospital of the Ministry of Interior and Administration, and a CD PROJEKT female employee who took part in a wheelchair fencing competition. The figure also includes scholarships paid out to participants of the Girls in the Game! mentoring program.

The Supervisory Board of the Company regards the Company's actions in this regard as commensurate with its resources and justifiable given the Company's social involvement.

IV.6. assessment of the observance, by the Company, of corporate governance policies and discharge of disclosure obligations related thereto, as specified in the Stock Exchange Regulations and regulations concerning current and periodic disclosures required from issuers of securities

Throughout 2022 the Company carried out its activities in compliance with regulations applicable to public companies, including its declared Corporate Governance Principles. In the Supervisory Board's opinion in 2022 the Company discharged its disclosure obligations related to corporate governance policies in an appropriate manner.

Resolution no. 2 of 9 May 2023 of the Supervisory Board of CD PROJEKT S.A. concerning approval of the CD PROJEKT S.A. Supervisory Board report on remuneration of members of the Management Board and Supervisory Board in 2022

Acting under Art. 90g section 1 of the Act of 29 July 2005 on public offering, conditions for introducing financial instruments to organized trading and public companies (JL 2022, item 2554), the Supervisory Board has decided the following:

§ 1

• 1. The Supervisory Board hereby approves the CD PROJEKT S.A. Supervisory Board report on the remuneration of members of the Management Board and Supervisory Board in 2022 ("Remuneration Report") as annexed to this resolution (Annex 1), and submits the Remuneration Report to Grant Thornton Polska PSA with a registered seat in Poznań ("the Auditor") for an assessment of the completeness of the disclosures provided, as specified in Art 90g of the Act on public offering, conditions for introducing financial instruments to organized trading and public companies.
• 1. The Supervisory Board declares that the Remuneration Report is complete under the applicable legal regulations, i.e. contains all disclosures listed in Art. 90g sections 1-5 and 8 of the Act on public offering, and covers all Members of the Management Board and Supervisory Board, along with persons closely related thereto, and all components of their respective remuneration packages.
• 1. The Supervisory Board hereby approves the Supervisory Board statement addressed to the Auditor concerning the responsibility of the Supervisory Board for preparation and completeness of disclosures contained in the Remuneration Report, as annexed to this resolution (Annex 2).
• 1. The Supervisory Board submits the Remuneration Report to the General Meeting for approval following the Auditor's assessment, as specified in section 1 above.

§ 2

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

Disclaimer: This English language translation has been prepared solely for the convenience of English speaking readers. Despite all the efforts devoted to this translation, certain discrepancies, omissions or approximations may exist. In case of any differences between the Polish and the English versions, the Polish version shall prevail. CD PROJEKT, its representatives and employees decline all responsibility in this regard.