Own Workforce [ESRS S1]

Employee development is at the core of our ESG Strategy. By fostering diversity, encouraging open communication, and maintaining ongoing dialogue, we create an attractive and inclusive workplace that enhances job satisfaction and employee engagement. Our values – #prosto (straightforward), #razem (together), #odważnie (boldly), and #odpowiedzialnie (responsibly) – are the pillars of our organisational culture, shaping both our approach to business and preferred working style. Similarly, the 10 Key Principles of Team Management, designed for the Bank’s managerial staff, define our leadership ethos.

Our workforce comprises:

• Employees who are significantly impacted by the Bank: those employed under an employment contract (both fixed-term and indefinite);
• Individuals working under civil law contracts (e.g., contracts for specific work or contracts of mandate);
• Non-employees providing services under B2B agreements or contracts.

Through our double materiality assessment, we have identified material impacts related to our own workforce.

The Bank operates under labour law regulations aligned with applicable legislation, ensuring equality before the law and non-discrimination in employment. These regulations, in the form of policies, procedures, guidelines, and internal rules, primarily apply to employees under employment contracts and those engaged under civil law contracts (e.g., contracts for specific work and contracts of mandate).

These regulatory frameworks are designed to support effective organisational management and oversee material impacts, risks, and opportunities associated with our workforce. The President of the Management Board is responsible for implementing these policies and supervises the Human Resources Division.

As a public trust institution, we conduct our business in compliance with applicable laws, supervisory recommendations, and best market practices. While the Bank’s internal policies and regulations do not explicitly reference prohibitions on human trafficking, forced labour, or child labour, we do not tolerate or permit any such practices within our organisation. The Pekao Group Code of Conduct (hereinafter: the “Code of Conduct”) is our key human rights policy. It serves as a comprehensive document outlining the core values and principles governing all areas of the Bank’s operations, subsidiaries, organisational culture, and value system.

All Pekao Group employees, regardless of position, tenure, location, or working hours, are expected to respect human rights. We promote this commitment by*:

• Raising employee awareness and continuously improving our approach to human rights protection in both internal and external relations; fostering a workplace free from practices that violate human rights;
• Maintaining open dialogue (in the form of internal communication, training, employee surveys, notifications, requests, communication on social media channels, business and intra-organizational meetings in various types of councils, committees, workshops etc.) with all stakeholders, enabling us to optimise our activities, including those related to human rights.

The Bank is not able to disclose all MDR requirements due to the fact that policies, activities and objectives were prepared before the CSRD/ESRS came into effect.

Our ethical and responsible business standards extend to intermediaries, counterparties, and suppliers, ensuring a sustainable and fair value chain. Each employee is responsible for maintaining a cooperative and ethical workplace atmosphere. We actively promote openness and direct communication.

The Code of Conduct of Pekao Group indirectly implements the UN Guiding Principles, emphasising: accountability, human rights compliance, integrity in employee relations, ethical conduct, dignity and respect for others, grievance mechanisms and access to remedies, as well as sustainable development initiatives and continuous dialogue with stakeholders

Additionally, as a member of the United Nations Global Compact, we fully embrace its 10 Principles, supporting its initiatives in human rights protection, improving labour conditions, environmental sustainability, and anti-corruption.