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Integrated Report 2024

Material Impacts, Risks, and Opportunities and Their Interrelation with Strategy and Business Model [SBM-3]

As a result of the double materiality analysis, we identified 26 topics aligned with ESRS and four additional topics (not covered under ESRS) that Pekao Group significantly impacts (impact materiality) or that significantly affect the Group’s operations (financial materiality).

In assessing impacts, we considered:

  • type of impact (positive/negative);
  • place of impact occurrence (value chain – mainly through the credit portfolio/organisation);
  • time of impact occurrence – actual (currently occurring) / potential (possible future occurrence);
  • three time horizons covering periods:
    • short-term (1 year);
    • medium-term (1 to 5 years);
    • long-term (over 5 years).
26
26 topics aligned with ESRS

We conducted the financial materiality analysis regarding opportunities and risks related to the business model, value chain, strategy, and decision-making process in:

  • three time horizons covering periods:
    • short-term (1 year);
    • medium-term (1 to 5 years);
    • long-term (over 5 years);
  • divided by place of impact occurrence (value chain – mainly through the credit portfolio/organisation).

The analysis also examined potential financial consequences related to the materialisation of risks concerning the Group’s financial position.

In the current reporting year, we identified an increased risk associated with the imposition of fines by the UOKiK resulting from practices employed by Bank Pekao S.A. related to enhanced consumer protection. In the medium-term horizon, we do not foresee any indications of events that could lead to significant financial consequences for the Bank or its ability to generate cash flows. We identified one potential risk related to tax transparency, namely increased credit risk arising from financing companies that do not adhere to international transparency standards.

Based on the results obtained, we do not identify any material risks to the Bank’s business model, strategy or value chain. We also do not expect the related financial effects in the current reporting year or the materialization of risks that could result in a material adjustment of the carrying amounts of assets and liabilities in the next year. With regard to medium and long periods, we also do not see any indications indicating the possibility of events materializing. As part of conducted analysis, we did not assess the resilience of the strategy and business model in the context of climate change. The analysis of climate risks conducted does not indicate threats to resilience.

A detailed list of impacts, risks, and opportunities is presented in the table below

IDENTIFIED ISSUES IN MATERIALITY ASSESSMENT IMPACT MATERIALITY FINANCIAL MATERIALITY
TYPE PLACE CATEGORY OUTLOOK TYPE PLACE OUTLOOK
Adaptation to Climate Change Positive Impact: We support climate adaptation initiatives primarily through financing infrastructure projects designed to withstand extreme weather events and other effects of climate change. DOWNSTREAM Actual
and Potential
Medium-term Opportunity: Increased revenues related to offering financial products or financing projects aimed at climate adaptation. DOWNSTREAM Long-term
Climate Change Mitigation

 

 

 

 

 

 

 

 

 

 

Positive Impact: We engage in financing projects that directly contribute to mitigating climate change (e.g., investments in renewable energy sources). DOWNSTREAM Actual Opportunity: Increased revenues

associated with offering financial products or financing projects aimed at mitigating climate change, such as investments in renewable energy and energy efficiency.

DOWNSTREAM Medium-term

Long-term

Negative Impact: In relation to our credit portfolio. We maintain exposure to high-emission sectors, including real estate and energy production. ORGANISATION

DOWNSTREAM

Actual
Sustainable finance
(additional issue)
Positive Impact: We engage in numerous projects aimed at improving corporate customers’ energy efficiency, implementing ecological initiatives, financing renewable energy sources, and supporting social projects. We have published a Sustainable Finance Framework defining the eligibility of investments financed from proceeds of EMTN bonds issued by the Bank. DOWNSTREAM Actual
IDENTIFIED ISSUES IN MATERIALITY ASSESSMENT IMPACT MATERIALITY FINANCIAL MATERIALITY
TYPE PLACE CATEGORY OUTLOOK TYPE PLACE OUTLOOK
Secure Employment Conditions Positive Impact: We have a positive impact on employment security. The majority of our employees are employed under employment contracts. However, in response to market needs and evolving expectations regarding employment flexibility, we also offer various types of contracts, including fixed-term and permanent employment contracts, civil law contracts (contract for specific work and contract of mandate), as well as consultant agreements under body leasing arrangements. ORGANISATION Actual No material opportunities or risks identified.
Negative Impact: The automation and implementation AI-based solutions may present a risk of job stability. ORGANISATION Potential Medium-term  
Employee Working Hours Positive Impact: We regulate employees’ working hours through appropriate systems; we apply work time recording principles and monthly work schedules within settlement periods. We have signed an “Agreement on Remote Work Principles” with Trade Unions. ORGANISATION Actual No material opportunities or risks identified.
Fair Employee Remuneration Positive Impact: We ensure fair remuneration for employees, considering both legal requirements and market conditions.  We implement incentive systems that support the Bank’s strategy execution. ORGANISATION Actual No material opportunities or risks identified.

 

Social Dialogue with Employees Positive Impact: We engage in dialogue with employees through internal communication channels such as intranet, chats, and regular meetings with the Management Board. We maintain dialogue with all trade union organisations operating within the Bank. ORGANISATION Actual No material opportunities or risks identified.

 

Freedom of Association, Works Councils, and Employees’ Right to Information, Consultation, and Participation Positive Impact: Trade union organisations operate within the Bank. We maintain dialogue with all trade union organisations and provide them with dedicated intranet pages for communication with employees. ORGANISATION Actual No material opportunities or risks identified.

 

Collective Bargaining, Including Percentage of Employees Covered by Collective Agreements Positive Impact: Over 70% of employees are covered by a collective agreement. ORGANISATION Actual No material opportunities

or risks identified.

Work-Life Balance Positive Impact: We offer flexible working models and participate in health campaigns related to mental health and physical activity. ORGANISATION Actual No material opportunities or risks identified.
Occupational Health and Safety Positive Impact: We undertake health and safety initiatives, including training, employee health surveys, and information campaigns. ORGANISATION Actual No material opportunities or risks identified.
Gender Equality and Equal Pay for Work of Equal Value Positive Impact: We have implemented an equality and diversity policy aimed at ensuring gender equality and preventing workplace discrimination. We consider gender balance in management and succession planning. ORGANISATION Potential Medium-term No material opportunities or risks identified.
Negative Impact: There is a gender pay gap in the Bank. As part of the ESG Strategy 2021-2024, the Bank is taking measures to reduce this disparity. ORGANISATION Actual
Employee Training and Skills Development Positive Impact: We offer our employees access to a variety of training formats, including webinars, mentoring, coaching, and e-learning courses. ORGANISATION Actual No material opportunities or risks identified.
Measures to Prevent Workplace Violence and Harassment Positive Impact: We have implemented the “Procedure for Counteracting Mobbing, Discrimination, Harassment, or Other Undesirable Behaviour at Bank Polska Kasa Opieki Spółka Akcyjna”, which serves as a mechanism for handling employee complaints, including issues related to workplace violence and harassment. We provide communication channels that allow employees to report unethical practices, such as harassment and violence. ORGANISATION Actual No material opportunities or risks identified.
Workplace Diversity Positive Impact: Our recruitment processes are based solely on assessing the experience and competencies of candidates and their alignment with the job requirements.

We implement initiatives that support diversity for all employees and provide managerial training on diversity management.

ORGANISATION Actual No material opportunities or risks identified.
Employee Privacy Positive Impact: We adhere to personal data protection principles through technical and organisational measures that ensure secure data processing. We take appropriate actions to secure sensitive information, ensuring full compliance with GDPR. We invest in data protection technologies, as well as the development and implementation of procedures and training programs, aimed not only at securing employee privacy but also at building trust and promoting a positive organizational culture. ORGANISATION Actual No material opportunities or risks identified.
IDENTIFIED ISSUES IN MATERIALITY ASSESSMENT IMPACT MATERIALITY FINANCIAL MATERIALITY
TYPE PLACE CATEGORY OUTLOOK TYPE PLACE OUTLOOK
Consumers and End Users Privacy Positive Impact: We  are implementing measures aimed at safeguarding consumers through the introduction of technological, systemic and organizational solutions. These include, in particular, educational campaigns that raise awareness about potential threats, frauds prevention methods, and ways to mitigate risks, as well as new transitions monitoring functionalities and updates to banking systems. ORGANISATION Actual No material opportunities or risks identified.
Access to High-Quality Information Positive Impact: We maintain active and effective communication with all stakeholders through various channels. We prioritise transparency in sales processes and the provision of accurate product information. ORGANISATION Actual No material opportunities or risks identified.
Personal Safety of Consumers and/or End Users Positive Impact: We implement numerous measures to protect customer data and financial assets. ORGANISATION Actual No material opportunities or risks identified.
Negative Impact: Due to the nature of our activities, we influence consumers’ financial security. Failure to comply with internal procedures may expose customers to financial loss and/or deterioration of their financial situation and that of their families. DOWNSTREAM Potential Medium-term
Non-discrimination Positive Impact: The Group takes the obligation of non-discrimination towards consumers very seriously and assesses its impact in this regard as unequivocally positive. This is reflected in a survey conducted among key external stakeholders, in which as many as 30% of respondents indicated a very positive impact (4 or 5 on a 5-point scale), while only 6% of respondents reported a negative impact on a similar scale. The Pekao24 online service provides the option of consulting with an advisor in sign language for the hearing impaired. ORGANISATION Actual No material opportunities or risks identified.
Access to Products and Services Positive Impact: We offer a wide range of financial services, including modern transaction banking products, settlement and treasury products, custodian services, and depositary banking. We support Polish micro, small, and medium-sized enterprises. Additionally, we provide an application that facilitates the acquisition and parametrisation of products for new customers. ORGANISATION Actual   Risk: The heightened risk associated with potential fines by UOKIK  as a result of practices employed by Bank Pekao, including issues related to sanctions on free credit and unauthorized transactions, has been identified. Due to the increasing activity of clients and consumer protection efforts by the regulator, which has initiated proceedings against the bank, there is a probability of risk materializing in 2025. DOWNSTREAM Short-term
Responsible Marketing Practices Positive Impact: Every employee of the Bank serves as an ambassador for the products and services offered by Pekao Group. Our marketing and advertising activities are conducted in accordance with the New Product Introduction Policy and the Marketing Communication Creation Principles, in line with the Corporate Governance Principles for Supervised Institutions issued by the Polish Financial Supervision Authority (KNF). ORGANISATION Actual No material opportunities or risks identified.
Financial Education

(additional issue)

Positive Impact: We conduct educational programmes, workshops, and information campaigns for a broad audience on the use of banking products, investment strategies, household budget management, and saving. ORGANISATION Actual No material opportunities

or risks identified.

ESG TOPICS IDENTIFIED ISSUES IN MATERIALITY ASSESSMENT IMPACT MATERIALITY FINANCIAL MATERIALITY
TYPE PLACE CATEGORY OUTLOOK TYPE PLACE OUTLOOK
G1: BUSINESS CONDUCT Corporate Culture Positive Impact: We foster an organisational culture based on mutual respect, openness to dialogue, and collective pursuit of organisational goals. The fundamental values and principles underlying our corporate culture are outlined in our internal documents. We conduct educational and awareness initiatives for employees and monitor their implementation through employee opinion surveys and engagement tracking. ORGANISATION Actual No material opportunities or risks identified.
Whistleblower Protection Positive Impact: We have implemented the Bank Pekao S.A. Whistleblowing Procedure, which sets out the principles and procedures for reporting irregularities and ensures protection for individuals reporting potential misconduct. ORGANISATION Actual No material opportunities or risks identified.
Supplier Relationship Management, Including Payment Practices Positive Impact: We enforce the Bank Pekao S.A. Supplier Code of Conduct, outlining expectations regarding environmental protection, social factors, and corporate governance standards. The Code is used in procurement processes, and each supplier is required to declare compliance and the completion of the ESG Form regarding the verification of its activities in terms of considering ESG factors. We verify outsourcing agreements in accordance with banking law and EBA guidelines. ORGANISATION Actual No material opportunities or risks identified.
Corruption Prevention and Detection, Including Training Positive Impact: We maintain and regularly communicate the Anti-Corruption Policy. Every employee is required to complete anti-corruption training and pass an assessment test. ORGANISATION Actual No material opportunities or risks identified.
Corruption and Bribery Incidents Positive Impact: We monitor compliance with internal anti-corruption regulations, implement preventive measures, and have established procedures for handling such incidents.

 

ORGANISATION Actual No material opportunities or risks identified.
  Tax Transparency
(additional issue)
Positive Impact: We collaborate with tax authorities in exchanging information and complying with international tax information exchange regulations (CRS, FATCA). ORGANISATION Actual   Risk:
Increased credit risk due to financing enterprises that do not adhere to international tax transparency standards.
DOWNSTREAM Long-term
Cybersecurity and Data Protection

(additional issue)

Positive Impact: The bank, ensuring a high level of data and system protection, contributes to the stability of the banking sector and the privacy protection of its clients. Investing in modern technologies, conducting audits, and applying best market practices not only minimizes threats to the bank and its stakeholders but also supports trust in the financial sector as a whole. The bank conducts continuous cybersecurity risk analysis, and the risks identified during this process are appropriately mitigated. ORGANISATION Actual No material opportunities or risks identified.

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