Bank Pekao S.A. Supplier Code of Ethics

We are committed to ensuring that our activities reflect our core values: #together and #responsibly. We welcome collaboration with suppliers who integrate ESG criteria into their business operations. To reinforce this commitment, we introduced the Bank Pekao S.A. Supplier Code of Ethics, adopted by the Bank’s Management Board in 2023 as an integral part of our procurement processes.

The Code of Ethics serves two primary objectives:

Promoting our values while clearly outlining the expectations, principles, and standards that govern our relationships with business partners;
Defining rules for conducting business responsibly, transparently, and sustainably, incorporating ESG criteria that all suppliers and subcontractors are expected to comply with.

Holding valid permits, licences, declarations, contracts, and decisions related to environmental protection;
Timely payment of environmental fees for the use of natural resources;
Compliance with environmental reporting requirements;
Minimising negative environmental impacts;
Efficient resource management;
Reducing material and raw material consumption;
Waste management in accordance with applicable legal regulations;
Implementing measures to reduce greenhouse gas emissions within their organisation and supply chain and ensuring transparency in emissions reporting;
Promoting environmental protection initiatives.

Prohibition of forced labour, child labour, and workplace discrimination;
Right to terminate employment at any time;
Timely salary payments and compliance with wage deduction regulations;
Prevention of workplace mobbing;
Right to freely associate, engage in collective bargaining, and elect representatives in accordance with the law;
Monitoring and assessing employee exposure to health and safety risks, including exposure to hazardous chemicals, biological agents, physical factors, and ergonomic risks;
Providing personal protective equipment and informing employees about occupational health and safety (OHS) risks and fire safety regulations.

Protection of legally protected information;
Timely fulfilment of financial obligations;
Anti-corruption compliance;
Prevention of money laundering, terrorist financing, and criminal activities;
Consumer protection;
Confidentiality of business and trade secrets;
Personal data protection;
Antitrust prevention;
Ensuring fair competition;
Avoiding conflicts of interest;
Intellectual property protection, technology transfers, and know-how management.

It should be emphasized that Bank Pekao S.A. Supplier Code of Ethics is a guiding document; we use the ESG Form to verify sustainability criteria.

By establishing clear supplier requirements and expectations in the ESG Questionnaire, we actively manage and reduce our exposure to climate-related risks, including Scope 3 greenhouse gas emissions within our supply chain. In line with the Code of Ethics, we expect suppliers to comply with environmental protection regulations and take proactive steps to mitigate their environmental impact. The Procurement Department (Finance Division) is responsible for managing the Code of Ethics, as outlined in the Bank’s internal regulations. External stakeholders are not involved in shaping these regulatory frameworks. Relevant sections of the Supplier Code of Ethics are publicly available on the Bank’s website.

Bank Pekao S.A. Supplier Code of Ethics

The Code of Ethics serves two primary objectives:

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