Greenhouse Gas Emissions [E1-6 – E1-9]

When calculating greenhouse gas emissions in scopes 1 and 2, we apply the GHG Protocol Corporate Standard methodology E1-6-48b]. Given the nature of our business, we are not subject to the EU Emissions Trading System. The scope of the calculation covers data for the Pekao Group. We based the calculations on internally collected data on resource consumption (e.g. electricity, petrol, mileage) and on information published by the National Centre for Emissions Management (KOBIZE), the Energy Regulatory Office (URE), the UK Department for Environment, Food and Rural Affairs (DEFRA), as well as information provided by electricity suppliers. We do not identify biogenic emissions in scopes 1 and 2. In 2025, we did not compile a breakdown enabling identification of the share of primary data in the carbon footprint calculation process for own operations. Greenhouse gas emissions are expressed in tonnes of carbon dioxide equivalent. We did not use external calculation tools for the calculations.

In the scope 3 greenhouse gas inventory prepared in accordance with the GHG Protocol Corporate Accounting and Reporting Standard guidelines, we report the following categories in 2025: 1, 2, 6, 7 and 15. The 2025 estimation performed to determine the materiality of emissions from these categories showed that only Categories 1 (purchased goods), 2 (capital goods) and 7 (employees commuting) exceeded the adopted materiality threshold of 0.05% of the share in emissions calculated for scope 3. In addition, due to observed market practice, we decided to include Category 6 (business travel) in the catalogue of reported material scope 3 emission categories, even though the share of these emissions in total scope 3 emissions did not exceed the defined threshold. We excluded the remaining scope 3 categories in 2025 due to their marginal share or lack of business materiality.

With respect to scope 3 Category 15, we identify three categories of financial assets (as presented in the consolidated financial statements) that were covered by the carbon footprint calculation: financial assets other than held for trading mandatorily measured at fair value through profit or loss, financial assets measured at fair value through other comprehensive income, and financial assets measured at amortised cost. We note that the data quality score used in the carbon footprint calculation is based on PCAF asset classes, not on the categories used in the financial statements.

• Corporate finance portfolio, including general-purpose exposures – 4.05
• Listed equity and corporate bond portfolio – 3.72
• Project finance portfolio – 4.39
• Mortgage-secured loan portfolio – commercial real estate – 2.09
• Mortgage-secured loan portfolio – retail real estate – 2.95
• Motor vehicle finance portfolio – 3.97

For the purposes of calculations relating to the sovereign bond portfolio, we used data from sources recommended by PCAF – the World Bank and a database maintained by the UN Climate Change Body (United Nations Climate Change).

We covered 83.87% of the Pekao Group’s balance sheet assets with carbon footprint calculations (in 2024, this figure was 77.82%).

We performed the calculations within the following asset classes, defined by the global greenhouse gas accounting and reporting standard for the financial industry developed by the Partnership for Carbon Accounting Financials (PCAF), of which we have been a member since July 2024. The calculation covered all asset classes defined by this standard that occur in the Pekao Group:

• corporate finance portfolio, including general-purpose exposures (business loans and unlisted equity) and purpose-specific loans (project finance),
• motor vehicle finance exposure portfolio (motor vehicle loans), which in the Pekao Group is understood as credit exposures and leasing exposures,
• mortgage-secured loan portfolio, including retail mortgages (mortgages) and commercial mortgages (commercial real estate),
• listed equity and corporate bond portfolio (listed equity and corporate bonds),
• sovereign debt finance portfolio (sovereign debt).

We carried out the calculations for individual asset classes in accordance with the global greenhouse gas accounting and reporting standard for the financial industry developed by PCAF.

We based the financial calculations of emissions related to the Pekao Group on data from internal and external sources. The scope of data obtained from external sources included, among others:

• data contained in the Central Register of Building Energy Performance Certificates maintained by the Minister of Development and Technology,
• average emissions factors contained in the European database of building emissions factors maintained by PCAF, used for the purposes of calculating financed emissions related to mortgage loans,
• reported emissions (emissions information collected directly from the borrower or the investee company),
• average emissions factors from the European building emissions database maintained by PCAF,
• financial data and data on corporate clients’ reported emissions obtained from their non-financial reports and available databases.

The share of financed greenhouse gas emissions in the Pekao Group’s portfolio calculated based on primary data (energy performance certificates and information obtained from companies’ reports) in 2025 was 22.3%^[29] (in 2024, this figure was 40%).

[29] The calculations do not include the motor vehicles financing portfolio (data not available).

With respect toscope 3 Category 1, we included emissions associated with the production of goods (i.e. tangible products) or the provision of services (intangible products) that we purchased from our suppliers in the calculations. For the purposes of calculating greenhouse gas emissions, we applied an activity- and spend-based approach, using, where possible, quantitative emissions factors (referring to the number of units of purchased products) published by the manufacturers of those goods. We excluded from the calculation for this category items that were classified to scope 1 and 2 (including services and products relating to the purchase of electricity and heat energy, fuels for vehicles in our company fleet) as well as products delivered and services provided by companies within the Pekao Group.

With respect to scope 3 Category 6, the calculations covered emissions associated with business travel in vehicles operated by third parties (i.e. air travel, rail, coach, passenger car). Emissions associated with transport in vehicles owned by, or under the control of, the Group were included in scope 1 (fuel consumption) or scope 2 (electricity consumption). For the calculations, we used DEFRA 2025 factors and Pekao Group internal data on business travel and the number of employees.

With respect to scope 3 Category 7, the calculations covered emissions arising from employee transport between their place of residence and their workplace (i.e. travel by car, bus, rail, etc.). We calculated emissions based on the results of an internal survey conducted in 2025. On the basis of these data and information on the total number of employees in the Pekao Group, we calculated total emissions in this category.

The shares of greenhouse gas emissions in the Pekao Group’s portfolio calculated on the basis of primary data for individual scope 3 categories identified as material were, respectively:

• Category 1 – 2.72%
• Category 2 – 0.02%
• Category 6 – 95.76%
• Category 7 – 18.78%
• Category 15 – 22.3%

The purpose of the disclosure on greenhouse gas removal and greenhouse gas emission reduction projects funded through carbon credits is to provide insight into the undertaking’s actions aimed at permanently removing, or actively supporting the removal of, greenhouse gases from the atmosphere, potentially contributing to future net‑zero targets. The scope of these disclosures is not relevant to our business, as neither the Bank nor the Pekao Group carries out such projects within its own operations. Even if the Bank holds an equity stake in such projects within its value chain, it does not meet the criteria for actively supporting these actions due to the lack of control over them.

This disclosure concerns whether the Pekao Group uses internal carbon pricing systems and, if so, how they support decision-making and incentivise the implementation of climate-related policies and targets. As neither the Pekao Group nor the Bank engages in carbon emissions trading, the scope of this disclosure is not applicable to our business.

In accordance with the delegated regulation adopted by the European Commission on 11 July 2025, which amends Appendix C to Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, so-called “first wave” undertakings – those reporting under ESRS in 2025 for the 2024 financial year – may omit the information set out in E1-9 in reports for 2025 and 2026. We have applied this option in the present report.