Managing Impacts, risks and opportunities [IRO-1]

Description of the process to identify and assess material impacts, risks and opportunities

In the process of preparing the Sustainability Statement in accordance with the ESRS requirements for the year 2024, we conducted a double materiality assessment for the first time, in order to identify, for the Bank and the entire Pekao Group, the key stakeholder groups as well as the material impacts, risks and opportunities related to sustainability matters.

As part of the preparations for drawing up the Sustainability Statement for the year 2025, we reviewed the assumptions and updated the conclusions from the double materiality assessment. The results of the assessment form the basis for our actions and for setting the Bank’s strategic objectives for the future.

The first double materiality assessment process was carried out in 2024 by a project team representing the Bank’s key units, and the whole process was overseen by the Steering Committee, comprising the Bank’s Department Directors and representatives of the Management Board. At regular meetings, the Steering Committee monitored progress and compliance with the adopted methodology. The results were discussed and approved by the Steering Committee. The process of reviewing and updating the double materiality assessment was carried out in 2025 by a project team representing the Bank’s key units. The results of this process were discussed and approved by the ESG Council.

The assessment was conducted in accordance with the ESRS requirements and took into account two perspectives: impact materiality and financial materiality of the Group’s activities in relation to sustainability matters, as well as the impact of individual matters on our financial performance in the future. To ensure consistency with the Bank’s risk management approach, the risk area actively participated in the process and was involved in identifying and assessing risks and opportunities, including setting materiality thresholds for ESG risks and opportunities, so that in the coming years ESG risks and opportunities can be fully integrated into the Group’s existing risk management system,.

When conducting the assessment, we divided the work into four stages:

  • identifying material sectors of activity and mapping the value chain,
  • analysing existing data, including market context (benchmarking) and stakeholder dialogue, and assessing impact materiality,
  • assessing the financial materiality of risks and opportunities,
  • matrix analysis of results and updating the list of ESG topics that are material from the Pekao Group’s perspective.

We carried out the double materiality assessment using various research tools, involving:

  • the Bank’s experts, who assessed the organisation’s impacts and financial materiality,
  • key internal and external stakeholders, through a survey concerning sustainability matters,
  • selected members of the Bank’s management team, with whom structured interviews were conducted, as well as a peer benchmarking analysis, an analysis of ESG ratings, and industry reports.

The sector identification methodology was based on the latest version of the ESRS, as well as the publicly available EFRAG sector classification. To identify sectors, we assumed a threshold of >10% of revenue in the last financial year. The sector survey was constructed based on EFRAG recommendations (the Exposure Draft European Sustainability Reporting Standard SEC1 – Sector classification and General approach to sector specific ESRS).

The Group’s key stakeholders were selected based on a questionnaire survey (16 stakeholder groups), in which two parameters were assessed:

  • the impact of the Pekao Group on a given stakeholder group,
  • the interest of a given stakeholder group in the Pekao Group.

As a result of analysing the responses and mapping stakeholders, we identified nine key stakeholder groups.

The impact materiality assessment was performed in stages, starting with an analysis of sustainability reports published by peer entities, an analysis of ESG ratings and an analysis of sector reports, as well as interviews with key internal stakeholders. The materiality assessment methodology included a comprehensive examination of the Pekao Group’s impacts on its environment and the verification of:

  • the timing of the impact,
  • the scale of the impact,
  • the likelihood of the impact,
  • the scope of the impact,
  • the reversibility of the impact.

To ensure the most neutral approach possible, the analysis used a variety of data sources, including:

  • interviews with internal stakeholders,
  • a benchmarking analysis, which included:
    • benchmarking of sustainability reports published by peer entities,
    • benchmarking of sector reports,
    • benchmarking of ESG ratings,
  • an anonymous survey among stakeholders (internal and external stakeholders).

With respect to the above criteria required by the ESRS standards and based on the data obtained enabling an initial indication of potentially material topics, we carried out a final impact assessment at the Bank, under which we analysed all ESRS topical standards. However, we assumed that for topical standards whose non-materiality was confirmed in the preliminary analyses, the Group’s impact on stakeholders may be deemed non-material. For actual negative impacts, materiality was based on the severity of the impact (scale, scope, irreversibility), and for potential negative impacts – on severity and likelihood.

For positive impacts, the basis for their assessment was the scale and scope of the impact for actual impacts, and the scale, scope and likelihood for potential impacts. For each of the above impact assessment categories, we used a scale from 1 to 5, where 1 represents the minimum value and 5 the maximum. We considered topics material if, on average, they scored more than half of the total possible points in the impact assessment and were validated through the preliminary analyses. For topics that achieved the required minimum points in the self-assessment but were not identified as material in the preliminary analyses, we re-assessed them with the project team’s judgement.

As part of the 2025 review process of the double materiality assessment, the following elements were updated:

  • benchmarking analysis of sustainability reports published by peer entities – available ESRS-compliant reports published for the year 2024 by Polish and European banks were used,
  • the Bank’s expert impact assessment – the initial long list of impacts considered was updated, among other things, to better balance the range of positive and negative impacts, as well as to include quantitative contextual information supporting the materiality assessment; the expert assessment of the materiality of impacts conducted during internal workshops was also updated. A description of how these changes affected the list of material impacts, risks and opportunities is provided in the section [Material impacts, risks and opportunities and their interrelationships with strategy and the business model (SBM-3)].

We linked the financial materiality assessment to the conclusions from the impact materiality assessment, as a result of which we determined an initial long list of risks and opportunities, where risks were defined as potential consequences of negative impacts, and opportunities as potential possibilities arising from creating positive impacts. We assessed each risk and each opportunity in terms of likelihood and its potential financial impact on the Pekao Group across three-time perspectives (in the current reporting year, up to 5 years and over 5 years, in particular at least 10 years for the assessment of the materiality of risks). The assessment was conducted during internal workshops attended by the Bank’s experts responsible for the relevant topic areas. We assumed that a given risk or opportunity is considered material if, in any of the time horizons, it achieved a score of at least 12 (expressed as the product of likelihood and financial impact, both assessed on five-point scales).

In addition, as part of the 2025 review process of the double materiality assessment, we took into account the following elements in relation to risks and opportunities:

  • the risk materiality analysis was aligned with the assumptions arising from the EBA Guidelines on ESG risk management (in particular, to reflect at least a 10-year time horizon in the analysis, to integrate financial materiality levels with the ICAAP process, and to identify ESG risk transmission channels to traditional risks indicated in the EBA Guidelines, i.e. credit risk (including concentration risk), market risk, liquidity risk, operational risk, reputational risk and business model risk),
  • the scale used to assess the financial materiality of risks and opportunities was redefined from a qualitative scale to a quantitative scale, with monetary thresholds linked to the ICAAP process,
  • the initial long list of risks and opportunities, in terms of:
    • defining risks as potential consequences of negative impacts and opportunities as potential possibilities arising from positive impacts (during workshop discussions in the DMA process, no ESG risks or opportunities unrelated to negative or positive impacts were identified),
    • including quantitative contextual information in the list to support the materiality assessment (e.g. sectoral concentration of the credit portfolio, amounts of operational losses, etc.),
    • a prudent assumption under which monetary opportunities were not identified in relation to positive impacts resulting from our regulatory / compliance activities, which primarily serve to reduce risk and the occurrence of negative impacts, and are not necessarily activities that can actively contribute to increasing the Pekao Group’s revenues.

We presented the materiality of climate-related impacts and opportunities in line with the approach described in detail in the previous section.

As part of the impact materiality assessment, we considered our impacts on climate across the value chain. In the context of analysing negative impacts, we considered in particular the sources of greenhouse gas emissions within our value chain. Taking into account the specific nature of the banking sector, we identified that a material actual negative impact is exerted through indirect greenhouse gas emissions resulting from the activities of our financed clients. With reference to the Strategy, we also identified that we exert a material positive impact related to increasing volumes of environmentally sustainable financing that supports the reduction of financed GHG emissions.

In connection with this material positive impact, we also identified a material financial opportunity under the “climate change mitigation” subtopic, relating to the expectation of increased revenues from offering financial products that support the reduction of GHG emissions and accelerate the transition of the Group’s clients to a low-carbon economy, in line with the objective set out in the Strategy.

We present further details on greenhouse gas emissions in our value chain in subsection [E1-6].

Description of the process in relation to climate risk

We also analysed climate-related risks in detail:

Physical risk

For physical risks, the identification and assessment performed as part of the financial materiality analysis was based, in accordance with the requirements of Article 20. b) i., AR 11, on a high-emissions climate scenario (SSP5-8.5). An analysis was carried out of the concentration of Pekao Group credit exposures in locations with elevated physical risk according to ThinkHazard.org maps (where, for real estate-secured exposures, the location of the collateral was analysed, and for other exposures, the location of the borrower’s registered office). The results of the analyses concerning our (downstream) portfolio, on the basis of which we concluded that physical risk is non-material for our portfolio, are published in the reports: Information on the capital adequacy of Bank Pekao S.A. Group – these include, among other things, exposure volumes and impairment by hazard type and sector. With respect to our own operations and the upstream part of the value chain, we considered physical risk to be non-material on the basis of a qualitative analysis supported by physical risk maps that take into account prospective risk aspects arising from climate scenarios, and by empirical observations regarding operational losses due to natural disasters.

Transition risk

For transition risk, we first analysed, in accordance with the Guidelines on ESG risk management, the sectoral concentration of our portfolio in sectors A–H and L (i.e. sectors that contribute significantly to climate change), with particular focus on exposures to fossil fuel sectors. We also considered our analyses related to developing the portfolio Transition Plan in line with the requirements indicated by the EBA Guidelines on ESG risk management, as well as indicators of alignment of the high-emission sectors we finance with the Net Zero 2050 scenario. We conducted climate transition risk stress tests for the first time in Q4 2025 in line with the timetable of our internal project to implement the aforementioned EBA Guidelines. We describe the key assumptions in the disclosure concerning the resilience analysis of our strategy and business model in section [SBM-3]. The results of this forward-looking quantitative analysis confirm our conclusion that transition risk in the credit portfolio is material in the long-term time horizon. With respect to our own operations and the upstream part of the value chain, we considered transition risk to be non-material, as the Pekao Group does not operate in any of sectors A–H and L, and we also observe that our carbon footprint in this area is negligible compared to the carbon footprint resulting from our credit portfolio.

For the remaining topics, we analysed:

STANDARD ESRS MATERIALITY ANALYSIS AND JUSTIFICATION
ESRS E2
(Pollution)		 From the perspective of financial activities, the ESRS E2 subtopic relating to pollution is not material. Within our assessment processes, the Bank takes into account potential indirect impacts related to pollution generated by financed entities. At the same time, based on the assessment performed, indirect impacts in the pollution area were considered less material compared to impacts identified in other ESRS areas:

• ESRS E1 “Climate change mitigation” – through assessing the financing of activities causing greenhouse gas emissions, which are often also associated with emissions of air pollutants;
• ESRS E4 “Biodiversity and ecosystems” – through analysing pressures on ecosystems in line with the ENCORE methodology, including, among other things, emissions of pollutants to air, water and soil.

On this basis, we did not identify material impacts or material risks in the pollution area from the perspective of the Bank’s financial activities. At the same time, we did not conduct consultations with affected communities regarding pollution, because both within our own operations and across the entire value chain, the Pekao Group does not exert an impact on the local environment that would justify such actions.
ESRS E3
(Water and marine resources)		 The ESRS E3 subtopic focuses primarily on direct water consumption and wastewater discharge within companies’ own operations, particularly in manufacturing sectors. For this reason, this standard does not reflect the specifics of financial institutions, whose impact on water resources is marginal and indirect.

As part of the double materiality assessment, we confirmed that both our operational activity – covering head offices and the branch network – as well as the credit portfolio do not generate a material impact on water and marine resources, either at organisational level or across the entire value chain.Consequently, we did not conduct dedicated dialogue with local communities in relation to this topic, as the nature of our activities does not generate impacts that would justify such actions.Based on the analysis carried out, we also did not identify material risks or opportunities in the area of water and marine resources, from the perspective of both our own activities and the financial portfolio.
ESRS E4
(Biodiversity and ecosystem)		 From the portfolio perspective, we assessed how the sectors we finance may affect ecosystem services, in line with the ENCORE methodology used under the E4 standard. Based on the analysis carried out, we did not identify material impacts, risks or opportunities related to biodiversity and ecosystem functioning.

In addition, we confirm that the Group does not have locations situated in biodiversity-sensitive areas or in their immediate vicinity. Therefore, the topic was not considered material and no dedicated dialogue with local communities was conducted in this respect.
ESRS E5
(Circular econom)		 From the portfolio perspective, we assessed impacts resulting from financing activities that may generate significant amounts of waste. However, in accordance with the ESRS E5 requirements, these matters are not considered material for financial institutions and, in our practice, are addressed through the assessment of pressures on ecosystems conducted in line with the ENCORE methodology under the ESRS E4 standard.

From the perspective of our operational activities, we generate only typical office and municipal waste, without producing hazardous or industrial waste. We consistently reduce the amount of waste, among other things, through segregation, process digitisation, the use of electronic signatures and increasing the share of payment cards made from environmentally friendly materials. As part of the double materiality assessment, we did not identify material impacts, risks or opportunities related to waste management – either at organisational level or across the value chain – therefore, we did not conduct dedicated local consultations.

Summary

As a result of the assessment, we identified:

  • the Pekao Group’s classification within a single sector: Credit institutions in the macro-sector Financial institutions;
  • 9 (nine) key stakeholder groups;
  • 4 (four) material ESRS topics (E1, S1, S4, G1) and 25 (twenty-five) material impacts, 2 (two) material opportunities and 2 (two) material risks. Most material impacts (17) relate to the social pillar and focus on aspects connected with own workforce (10) and consumers and end-users (7). Under the environmental pillar, we identified two material impacts related to climate; and under the corporate governance pillar we identified 6 (six) material impacts. Material financial opportunities relate to climate change mitigation and the accessibility of services for our customers. In turn, the material risks relate to:
    • the potentially material effect of climate-related transition risk on credit risk (including concentration risk) of our portfolio in the long-term time horizon,
    • the elevated risk of the Office of Competition and Consumer Protection (UOKiK) imposing fines as a result of practices applied by the Bank, including those related to free credit sanction and unauthorised transactions.

Disclosure requirements under ESRS covered by the undertaking’s Sustainability Statement

STANDARD / TOPIC DISCLOSURE LOCATION IN THE REPORT (CHAPTER NUMBER) OMISSIONS AND EXPLANATIONS
ESRS 2 BP-1 General basis for preparing sustainability statements 13.1.1, 13.1.2
BP-2 Disclosures related to specific circumstances 13.1.1
GOV-1 Roles and responsibilities of the undertaking’s administrative, management and supervisory bodies 13.1.2.1
GOV-2 Information provided to the undertaking’s administrative, management and supervisory bodies on sustainability matters 13.1.2.2
GOV-3 Integration of sustainability-related performance in incentive schemes 13.1.2.3
GOV-4 Due diligence statement 13.1.2.4
GOV-5 Risk management and internal controls in sustainability reporting 13.1.2.5
SBM-1 Market position, strategy, business model, and value chain 13.1.3.1
SBM-2 Views, interests, and expectations of stakeholders 13.1.3.2
SBM-3 Interaction of influences, strategy, and business model of the company 13.1.3.3
IRO-1 Description of processes for identifying and assessing material impacts, risks, and opportunities 13.1.4.1
IRO-2 Disclosure requirements under ESRS covered by the entity’s sustainability statement 13.1.4.2
CLIMATE CHANGE
ESRS E1 GOV-3 Incorporation of sustainability-related performance in incentive schemes 13.1.2.3
SBM-3 – Material impacts, risks, and opportunities and their interconnections with strategy and business model 13.1.3.3
IRO-1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities 13.1.4.1
E1-1 Transition plan for climate change mitigation 13.1.2.1
E1-2 Policies related to climate change mitigation and adaptation 13.1.2.1
E1-3 Actions and resources related to climate policy 13.1.2.1
E1-4 Climate change mitigation and adaptation targets 13.2.2
E1-5 Energy consumption and energy mix 13.2.2
E1-6 Gross greenhouse gas emissions for Scopes 1, 2, and 3 and total greenhouse gas emissions 13.2.2
E1-7 Greenhouse gas removal and emission reduction projects financed through carbon emission units N/A
E1-8 – Internal carbon pricing N/A
E1-9 – Anticipated financial impacts of material physical risks, transition risks, and potential climate-related opportunities N/A
POLLUTION
ESRS E2 IRO-1 Description of processes for identifying and assessing material impacts, risks, and opportunities related to pollutio 13.1.4.1
E2-1 Policies related to pollution N/A
E2-2 Actions and resources related to pollution N/A
E2-3 Pollution-related targets N/A
E2-4 Air, water, and soil pollution N/A
E2-5 Potentially hazardous substances and substances of very high concern N/A
E2-6 Anticipated financial impacts of risks and opportunities related to pollution N/A
WATER AND MARINE RESOURCES
ESRS E3 IRO 1 Description of processes for identifying and assessing material impacts, risks, and opportunities related to water and marine resources 13.1.4.1
E3-1 Policies related to water and marine resources N/A
E3-2 Actions and resources related to water and marine resources N/A
E3-3 Targets related to water and marine resources N/A
E3-4 Water consumption N/A
E3-5 Anticipated financial impacts of influences, risks, and opportunities related to water and marine resources N/A
BIODIVERSITY AND ECOSYSTEMS
ESRS E4 SBM-3 – Material impacts, risks, and opportunities and their interconnections with strategy and business model N/A
IRO 1 Description of the processes to identify and assess material biodiversity and ecosystems-related impacts, risks and opportunities 13.1.4.1
E4-1 Biodiversity and ecosystem transformation plan and inclusion of biodiversity and ecosystems in strategy and business model N/A
E4-2 Policies related to biodiversity and ecosystems N/A
E4-3 Actions and resources related to biodiversity and ecosystems N/A
E4-4 Targets related to biodiversity and ecosystems N/A
E4-5 Impact metrics related to biodiversity and ecosystem change N/A
E4-6 Anticipated financial impacts of risks and opportunities related to biodiversity and ecosystems N/A
RESOURCE USE AND CIRCULAR ECONOMY
ESRS E5 IRO 1 Description of processes for identifying and assessing material impacts, risks, and opportunities related to resource use and circular economy 13.1.4.1
E5-1 Policies related to resource use and circular economy N/A
E5-2 Actions and resources related to resource use and circular economy N/A
E5-3 Targets related to resource use and circular economy N/A
E5-4 Resource inflows N/A
E5-5 Resource outflows N/A
E5-6 Anticipated financial impacts of risks and opportunities related to resource use and circular economy N/A
OWN WORKFORCE
ESRS S1 SBM-2 – Interests and opinions of stakeholders 13.1.3.2
SBM-3 – Material impacts, risks, and opportunities and their interconnections with strategy and business model 13.1.3.3
S1-1 Policies related to own workforce 13.3.1.1
S1-2 Procedures for engagement with own employees and employee representatives regarding impacts 13.3.1.1
S1-3 Processes for mitigating negative impacts and employee grievance mechanisms 13.3.1.1
S1-4 Actions taken regarding material impacts on own employees and approaches to managing material risks and leveraging material opportunities related to own workforce, as well as the effectiveness of such actions 13.3.1.1
S1-5 Targets related to managing material negative impacts, enhancing positive impacts, and managing material risks and opportunities 13.3.1.2
S1-6 Characteristics of the entity’s employees 13.3.1.2
S1-7 Characteristics of non-employee workers classified as part of the entity’s own workforce 13.3.1.2
S1-8 Scope of collective bargaining and social dialogue 13.3.1.2
S1-9 Diversity indicators 13.3.1.2
S1-10 Fair remuneration 13.3.1.2
S1-11 Social protection 13.3.1.2
S1-12 Persons with disabilities N/A
S1-13 Training and skills development indicators 13.3.1.2
S1-14 Occupational health and safety indicators 13.3.1.2
S1-15 Work-life balance indicators 13.3.1.2
S1-16 Remuneration indicators (gender pay gap and total remuneration) 13.3.1.2
S1-17 Incidents, complaints, and material impacts on human rights compliance 13.3.1.2
WORKERS IN THE VALUE CHAIN
ESRS S2 SBM-2 – Interests and opinions of stakeholders N/A
SBM-3 – Material impacts, risks, and opportunities and their interconnections with strategy and business model N/A
S2-1 Policies related to employees in the value chain N/A
S2-2 Processes for engagement with employees in the value chain regarding impacts N/A
S2-3 Processes for mitigating negative impacts and grievance mechanisms for employees in the value chain N/A
S2-4 Actions taken regarding material impacts on employees in the value chain and approaches to managing material risks and leveraging material opportunities related to employees in the value chain, as well as the effectiveness of such actions N/A
S2-5 Targets related to managing material negative impacts, enhancing positive impacts, and managing material risks and opportunities N/A
AFFECTED COMMUNITIES
ESRS S3 SBM-2 – Interests and opinions of stakeholders N/A
SBM-3 – Material impacts, risks, and opportunities and their interconnections with strategy and business model N/A
S3-1 Policies related to affected communities N/A
S3-2 Processes for engagement with affected communities regarding impacts N/A
S3-3 Processes for mitigating negative impacts and grievance mechanisms for affected communities N/A
S3-4 Actions taken regarding material impacts on affected communities and approaches to managing material risks and leveraging material opportunities related to these communities, as well as the effectiveness of such actions N/A
S3-5 Targets related to managing material negative impacts, enhancing positive impacts, and managing material risks and opportunities N/A
CONSUMERS AND END-USERS
ESRS S4 SBM-2 – Interests and opinions of stakeholders 13.1.3.2
SBM-3 – Material impacts, risks, and opportunities and their interconnections with strategy and business model 13.1.3.3
S4-1 Policies related to consumers and end-user 13.4.1
S4-2 Processes for engagement with consumers and end-users regarding impacts 13.4.1.1
S4-3 Processes for mitigating negative impacts and grievance mechanisms for consumers and end-users 13.4.1.1
S4-4 Actions taken regarding material impacts on consumers and end-users and approaches to managing material risks and leveraging material opportunities related to consumers and end-users, as well as the effectiveness of such actions 13.4.1.1
S4-5 Targets related to managing material negative impacts, enhancing positive impacts, and managing material risks and opportunities 13.4.1.2
BUSINESS CONDUCT
ESRS G1 GOV-1 Roles and responsibilities of administrative, management, and supervisory bodies of the company 13.5.1
G1-1 Corporate culture and business conduct policies 13.5.1
G1-2 Management of relationships with suppliers 13.5.1
G1-3 Prevention, detection, and mitigation of corruption and bribery 13.5.1
G1-4 Confirmed incidents of corruption or bribery 13.5.2
G1-5 Political influence and lobbying activities N/A
G1-6 Payment practices 13.5.2
DISCLOSURE REQUIREMENT AND RELATED DATA POINT REFERENCE TO THE REGULATION ON SUSTAINABILITY-RELATED DISCLOSURES IN THE FINANCIAL SERVICES SECTOR (CHAPTER NO.) REFERENCE TO PILLAR 3 (2) REFERENCE TO THE BENCHMARKS REGULATION (3) REFERENCE TO THE EUROPEAN CLIMATE LAW (4)
ESRS 2 GOV-1
Gender diversity of the Management Board members (point 21(d))		 13.1.2.1 Annex II to Commission Delegated Regulation (EU) 2020/1816 (5)
ESRS 2 GOV-1
Percentage of independent Management Board members (point 21(e))		 13.1.2.1 Annex II to Commission Delegated Regulation (EU) 2020/1816
ESRS 2 GOV-4
Due diligence statement (point 30)		 13.1.2.4
ESRS 2 SBM-1
Participation in fossil fuel-related activities (point 40(d)(i))		 13.1.3.1
ESRS 2 SBM-1
Participation in chemical production activities (point 40(d)(ii))		 N/A
ESRS 2 SBM-1
Participation in controversial weapons-related activities (point 40(d)(iii))		 N/A
ESRS 2 SBM-1
Participation in tobacco cultivation and production activities (point 40(d)(iv))		 N/A
ESRS E1-1
Plan transformacji służący osiągnięciu neutralności klimatycznej do 2050 r. pkt 14		 13.1.2.1 Article 2(1) of Regulation (EU) 2021/1119
ESRS E1-1
Transition plan to achieve climate neutrality by 2050 (point 14)		 13.1.2.1 Article 449a of Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453, Template 1: Banking portfolio – Climate change transition risk: credit quality of exposures by sector, issue and residual maturity Article 12(1)(d)-(g) and 12(2) of Delegated Regulation (EU) 2020/1818
ESRS E1-4
Entities excluded from the scope of Paris Agreement- aligned benchmarks (point 16(g))		 13.2.2 Article 449a of Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453, Template 3: Banking portfolio – Transition risks associated with climate change: measures of adaptation Article 6 of Delegated Regulation (EU) 2020/1818
ESRS E1-5
Greenhouse gas emission reduction targets (point 34)		 13.2.2
ESRS E1-5
Energy consumption from fossil sources disaggregated by source (applies only to sectors with significant climate impact), point 38		 13.2.2
ESRS E1-5
Energy consumption and energy mix, point 37		 13.2.2
ESRS E1-6
Energy intensity associated with activities in sectors with significant climate impact, points 40–43		 13.2.2 Article 449a of Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453, Template 1: Banking portfolio – Climate change transition risk: credit quality of exposures by sector, issue and residual maturity Article 5(1), Article 6, and Article 8(1) of Delegated Regulation (EU) 2020/1818
ESRS E1-6
Gross greenhouse gas emissions for Scopes 1, 2, and 3 and total greenhouse gas emissions, point 44		 13.2.2 Article 449a of Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453, Template 3: Banking portfolio – Transition risks associated with climate change: measures of adaptation Article 8(1) of Delegated Regulation (EU) 2020/1818
ESRS E1-7
Gross greenhouse gas emission intensity, points 53–55		 13.2.2 Article 2(1) of Regulation (EU) 2021/1119
ESRS E1-9
Portfolio reference exposure to physical climate risk, point 66		 13.2.2 Annex II to Delegated Regulation (EU) 2020/1818, Annex II to Delegated Regulation (EU) 2020/1816
ESRS E1-9
Disaggregation of monetary amounts by acute and chronic physical risk, point 66(a)ESRS E1-9
Location of significant asset components subject to substantial physical risk, point 66(c)		 13.2.2 Article 449a of Regulation (EU) No 575/2013; points 46 and 47 of Commission Implementing Regulation (EU) 2022/2453; Template 5: Banking portfolio – physical risk related to climate change: exposures subject to physical risk
ESRS E1-9
Breakdown of book value of real estate by energy efficiency classes, point 67(c)		 13.2.2 Article 449a of Regulation (EU) No 575/2013; point 34 of Commission Implementing Regulation (EU) 2022/2453; Template 2: Banking portfolio – Transition risk related to climate change: real estate-collateralised loans – energy efficiency of collateral
ESRS E1-9
Degree of portfolio exposure to climate-related opportunities, point 69		 13.2.2 Annex II to Delegated Regulation (EU) 2020/1818
ESRS E2-4
Quantity of each pollutant listed in Annex II to theRegulation on the European Pollutant Release andTransfer Register (E-PRTR) emitted into air, water, and soil, point 28		 N/A
ESRS E3-1
Water and marine resources, point 9		 N/A
ESRS E3-1
Specific policy, point 13		 N/A
ESRS E3-1
Sustainable practices in the field of seas and oceans, point 14		 N/A
ESRS E3-4
Total volume of water recycled and reused, point 28(c		 N/A
ESRS E3-4
Total water consumption in m³ per net revenue from own operations, point 29		 N/A
ESRS 2 IRO1-E4 point 16(a)(i) N/A
ESRS 2 IRO1-E4 point 16(b) N/A
ESRS 2 IRO1-E4 point 16(c) N/A
ESRS E4-2
Sustainable land/agriculture practices or policies, point 24(b		 N/A
ESRS E4-2
Sustainable ocean/marine practices or policies, point 24(c)		 N/A
ESRS E4-2
Policies for deforestation prevention, point 24(d)		 N/A
ESRS E5-5
Non-recycled waste, point 37(d)		 N/A
ESRS E5-5
Hazardous and radioactive waste, point 3		 N/A
ESRS 2 SBM-3-S1
Risk of forced labour cases, point 14(f)		 13.3.1.1
ESRS 2 SBM-3-S1
Risk of child labour cases, point 14(g)		 13.3.1.1
ESRS S1-1
Commitments regarding policies on human rights respect, point 20		 13.3.1.1
ESRS S1-1
Due diligence strategies concerning issues covered by core International Labour Organization Conventions No. 1–8, point 21		 13.3.1.1
ESRS S1-1
Procedures and measures for preventing human trafficking, point 22		 13.3.1.1 Annex II to Commission Delegated Regulation (EU) 2020/1816
ESRS S1-1
Policy or management system for accident prevention at work, point 23		 13.3.1.1
ESRS S1-3
Complaint-handling mechanisms, point 32(c)		 13.3.1.1
ESRS S1-14
Number of work-related deaths and the number and rate of work-related accidents, point 88(b)-(c)		 13.3.1.2 Annex II to Commission Delegated Regulation (EU) 2020/1816
ESRS S1-14
Number of days lost due to injuries, accidents, fatalities, or illnesses, point 88(e		 13.3.1.2
ESRS S1-16
Unadjusted gender pay gap, point 97(a)		 13.3.1.2
ESRS S1-16
Excessive CEO pay level, point 97(b)		 13.3.1.2 Annex II to Commission Delegated Regulation (EU) 2020/1816
ESRS S1-17
Cases of discrimination, point 103(a)		 13.3.1.2
ESRS S1-17
Non-compliance with UN Guiding Principles on Business and Human Rights and OECD Guidelines, point 104(a)		 Annex II to Delegated Regulation (EU) 2020/1816, Article 12(1) of Delegated Regulation (EU) 2020/1818
ESRS 2 SBM-3-S2
Significant risk of child labour or forced labour in the value chain, point 11(b)		 N/A
ESRS S2-1
Commitments regarding policies on human rights respect, point 17		 N/A
ESRS S2-1
Policies related to employees in the value chain, point 18		 N/A
ESRS S2-1
Non-compliance with UN Guiding Principles on Business and Human Rights and OECD Guidelines, point 19		 N/A
ESRS S2-1
Due diligence strategies concerning issues covered by core International Labour Organization Conventions No. 1–8, point 19		 N/A
ESRS S2-4
Human rights-related issues and incidents related to the upstream and downstream value chain, point 36		 N/A
ESRS S3-1
Commitments regarding policies on human rights respect, point 16		 N/A
ESRS S3-1
Non-compliance with UN Guiding Principles on Business and Human Rights, ILO standards, or OECD Guidelines, point 17		 N/A
ESRS S3-4
Human rights-related issues and incidents, point 36		 N/A
ESRS S4-1
Policy concerning consumers and end-users, point 1		 13.4.1.1 Annex II to Delegated Regulation (EU) 2020/1816, Article 12(1) of Delegated Regulation (EU) 2020/1818
ESRS S4-1
Non-compliance with UN Guiding Principles on Business and Human Rights and OECD Guidelines, point 17		 13.4.1.1
ESRS S4-4
Human rights-related issues and incidents, point 35		 13.4.1.1
ESRS G1-1
United Nations Convention against Corruption, point 10(b)		 13.5.1
ESRS G1-1
Whistleblower protection, point 10(d)		 13.5.1
ESRS G1-4
Fines for breaches of anti-corruption and anti-bribery regulations, point 24(a)		 13.5.2
ESRS G1-4
Standards on anti-corruption and anti-bribery, point 24(b)		 13.5.2 Annex II to Commission Delegated Regulation (EU) 2020/181
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