Statement on application of Corporate Governance Principles for Supervised Institutions

Management Board of Bank Polska Kasa Opieki Spółka Akcyjna (hereinafter referred to as the "Bank"), being responsible for the management of the Bank together with the Bank Supervisory Board, exercising regular supervision over the Bank's activities in all its fields, guided by the Bank's proper and safe operation in carrying out its task, hereby declare readiness to apply the Corporate Governance Rules for the Supervised Institutions issued by the Financial Supervision Authority on July 22, 2014 (the "Rules"), objectively to the fullest extent possible.

The decision on the adoption of the Rules for application by the Bank the Bank Management Board took on 14 October 2014 in accordance with the Management Board's Resolution No 356/X/14 and the Bank Supervisory Board on 5 November 2014 in accordance with the Supervisory Board's Resolution No 33/14. Moreover Bank Ordinary General Meeting (“General Meeting”), which took place on 30 April 2015 took a decision no. 25/2015 on adoption of Corporate Governance Rules for the Supervised Institutions. General Meeting has declared the application of Corporate Governance Rules addressed to the Bank's shareholders.

Bank Management Board, according to the Rules, informs on it’s website about application or withdrawal from application of certain rules.

Bank Management Board and Supervisory Board, respecting binding laws, expresses the will to apply the Rules, taking into account the principle of proportionality and the "comply or explain" principle, as set out in the Rules.

Bank Management Board hereunder presents information on particular rules, which are applied partly or whose application has changed and indicates rules, that due to the nature of business and specificity do not apply to the Bank.

1. Rules that are partly applied or whose application has changed.

No.	Unit	Rule	Justification for changing partial application to full application
1.	§ 21 item. 2	A supervisory body shall have a separated function of the chairman to lead the work of the supervisory body. The selection of the president of the supervisory body shall be made on the basis of experience and ability to lead a team, taking into account the criterion of independence.	The principle specified in § 21(2) of the Principles, concerning the composition of the supervisory body, in relation to the Chairman of the Supervisory Board, was partially applied by the Bank. The selection of the Chairman of the Supervisory Board was based on criteria such as the knowledge and experience possessed, including in managing the work of a team, as well as skills that confirm the competence necessary for performing supervisory duties properly. In light of the above, the criterion of independence was waived.
2.	§ 53	A supervised institution which managed assets at client's risk should efficiently manage those assets, so as to ensure the necessary protection of clients' interests.	Compared to the analysis of the application of the Corporate Governance Principles for Supervised Institutions for 2024, the Bank considers that it applied the principle set out in § 53 of the Principles (the previous assessment indicated that the principle in question did not apply to the Bank's activities).
3.	§ 55	A supervised institution which manages assets at client's risk should avoid in its operations situations which might cause the occurrence of a conflict of interests, and in the event of the occurrence of a conflict of interests, it should be guided by the client's interest, notifying the client about the occurrence of the conflict of interests.	Compared to the analysis of the application of the Corporate Governance Principles for Supervised Institutions for 2024, the Bank considers that it applied the principle set out in § 55 of the Principles (the previous assessment indicated that the principle in question did not apply to the Bank's activities).
4.	§ 57	A supervised institution, when acquiring assets at client's risk, should act in the client's interest. The decision-making process should be properly documented.	Compared to the analysis of the application of the Corporate Governance Principles for Supervised Institutions for 2024, the Bank considers that it applied the principle set out in § 57 of the Principles (the previous assessment indicated that the principle in question did not apply to the Bank's activities).

2. Rules that do not apply to the Bank.

No.	Unit	Rule/title	Justification
1.	§ 49 item. 4	In a supervised institution, where there is no internal audit unit or compliance unit, the entitlements referred to in items 1-3 shall be held by the people responsible for performance of those functions.	There are both internal audit unit and compliance units in the Bank.
	§ 52 item. 2	In a supervised institution, where there is no audit unit or compliance assurance unit, and where no unit responsible for that area has been appointed, the information referred to in item 1 shall be submitted by the people responsible for fulfilling those functions.
2.	§ 54	1. A supervised institution should use the available corporate supervision measures over entities – issuers of securities subject to management, in particular when the level of involvement into securities is considerable or it is required by protection of clients' interests.  2. A supervised institution which manages assets at client's risk should introduce transparent principles of cooperating with other financial institutions when executing corporate supervision over entities – issuers of securities subject to management.  3. A supervised institution which manages assets at client's risk shall create and communicate to clients a policy of application of corporate supervision measures, including the procedures of participation and voting in the meetings of General Metting.	In relation to the principles specified in Chapter 9 of the Principles, in 2025, the Bank began providing portfolio management services, which include one or more financial instruments. As a general rule, the Bank applies Chapter 9 of the Principles. However, the current Rules for the provision of portfolio management services only provide for the management of investment fund units, which, according to the Act on Trading in Financial Instruments, are financial instruments that are not classified as securities. Consequently, the principles specified in § 54 and § 56 of Chapter 9 of the Principles do not currently apply to the Bank.
	§ 56	A supervised institution which manages assets at client's risk should introduce transparent principles of cooperating with other supervised institutions with respect to transactions executed at client's risk.

The Rules are available on the website of the Financial Supervision Commission under the link: PRINCIPLES OF CORPORATE GOVERNANCE FOR SUPERVISED INSTITUTIONS