Management

Business Conduct

A key element of our operations is the development of a stable organisational culture. In 2021, we defined four core values: #prosto (straightforward), #razem (together), #odważnie (boldly) and #odpowiedzialnie (responsibly), which set the standards for employee conduct and foster engagement around shared objectives.

We actively promote behaviours aligned with these values, thereby creating an increasingly positive and secure work environment. Our ESG Strategy serves as the primary governance framework for corporate governance, facilitating the integration of social responsibility principles and ethical standards. Our commitment is reflected in the policies and procedures we implement.

Effective promotion of organizational culture is supported by daily activities and regular training in the following areas:

Corporate governance
Corporate governance
Ethical standards and the Code of Conduct of the Pekao Group
Ethical standards and the Code of Conduct of the Pekao Group
Reporting violations
Reporting violations
Counteracting corruption
Counteracting corruption
Compliance
Compliance
workshops on clear communication for employees handling correspondence with clients
Workshops on clear communication for employees handling correspondence with clients

The Bank accounts for 83% of the Group's total workforce and, being the parent company, sets the standard in the area of mechanisms for reporting any violations. Other Group entities have an approach in this regard similar to the one we present below based on the Bank's policies.

The most important procedures are:

  • Whistleblowing Procedure

    • The Whistleblowing Procedure defines the principles and procedures for reporting violations of law, internal procedures, and ethical standards within the bank. Reporting violations is an important element of risk management and helps maintain the bank's positive image while avoiding legal, financial, and reputational risks.

  • Anti-Mobbing Procedure

    • Our Anti-Mobbing Procedure includes provisions prohibiting retaliatory actions, direct or indirect actions or omissions that are repressive in nature, adversely affect the legal or factual situation, or involve making threats in connection with a complaint, which violate or may violate rights or cause or may cause unjustified damage, including unjustified initiation of proceedings.

  • Anti-Corruption Policy

    • The Anti-Corruption Policy is adopted by the Bank's Management Board and applies to all Bank employees and every aspect of our business. The document is published in the intranet collection of internal regulations and is available to all employees.

  • Code of Conduct

    • The Pekao Group Code of Conduct contains principles to guide all Pekao Group employees. Its provisions indicate the need to:

      • act in accordance with the provisions of law, internal regulations, recommendations of supervisory and control authorities and generally accepted market standards,
      •  strive to improve the quality of work and standards,
      •  build long-term relationships with customers based on mutual trust and transparent cooperation principles.
      • have knowledge of the risk culture, i.e. the risk limits relating to the activities carried out, as defined by the Bank Pekao or other Pekao Group entities.

      Currently, the Code adopted by the Resolution of the Bank's Management Board of 3 December 2021 is in force.

      The Code is available on the Bank's website Corporate Governance.

Supplier Relationships

Partnerships with suppliers, regardless of the size of the partner's company, are of particular importance to us. We strive to build long-term relationships based on mutual trust and equality. Our partners are selected based on equal accessibility, in accordance with internal procedures, best practices, and applicable Polish law.

ESG forms
ESG forms
Supplier Code of Ethics
Supplier Code of Ethics
Supplier Zone
Supplier Zone

We strive to ensure that our activities are consistent with our values. We are open to relationships with suppliers who incorporate ESG criteria into their business operations. 

We focused on two main goals:

  • promoting our values while clarifying the expectations, principles, and standards that guide our relationships with our partners as a Bank;
  • defining principles for adhering to standards and principles that enable us to conduct business in a responsible, transparent, and sustainable manner, taking into account ESG criteria, which we expect from potential suppliers and subcontractors.

  • Suppliers Code of ethics of the Bank Pekao S.A.

    • Suppliers Code of ethics of the Bank Pekao S.A. (the "Code") is used in procurement proceedings to promote the values that Bank shares, at the same time indicating to our contractors the expectations, principles and standards in force in Bank Pekao S.A.

      The Code contains rules connected to environmental and natural resources protection, social principles and corporate governance principles. We want to show our contractors the patterns and direction of the Bank's development.

      The Code was adopted by the Resolution of the Bank's Management Board of 5 October 2023.

      In order to ensure appropriate communication, the Code has been published on the Bank's website: Corporate Governance in the dedicated Supplier Zone and in the Integrated Procurement Tool.

Procedures and policies

Corporate governance

  • Bank Pekao S.A.'s compliance policy

    • The Policy contains the basic principles for ensuring compliance of the Bank's operations with laws, internal regulations and market standards by all Bank Employees and explains the main elements of the compliance risk management process. Compliance risk is understood as the risk of the consequences of non-compliance with laws, internal regulations and market standards in the Bank's processes. Ensuring compliance is an integral part of conducting the Bank's business, is deeply rooted in the Pekao Group's Code of Conduct and the adopted Code of Banking Ethics, and forms the basis of the so-called compliance culture.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board of 5 April 2019 is in force. The full version of the policy is internal information and has not been released to the public.

  • Corruption Prevention Policy of the Bank Pekao S.A. Group

    • The policy sets out the basic principles of conduct aimed at counteracting corruption; defines the general assumptions and competencies for corruption risk management and defines the anti-corruption program at Bank Pekao S.A., in particular with regard to the main areas of this risk, i.e:

      • cooperation with intermediaries,
      • giving/accepting gifts and offering/accepting entertainment,
      • recruitment policy,
      • cooperation with counterparties,
      • donations and sponsorships,
      • mergers and acquisitions,
      • significant investments;
      • the Bank’s participation in public procurement procedures.


      Currently, the Policy adopted by the Resolution of the Bank's Management Board of 17 September 2020 is in force.

      'Important provisions of the Anti-Corruption Policy in the Bank Pekao S.A. Group - information for intermediaries and counterparties' is available on the Bank's website in the Corporate Governance tab.

  • Bank Pekao S.A. Group's policy on counteracting practices restricting competition and practices that violate the collective interests of consumers

    • The policy defines the basic rules for the Bank’s employees to act in accordance with antitrust and unfair market practice regulations and the main tasks of the Bank’s organizational units in this regard. The policy obliges employees to act in accordance with generally applicable laws and to protect the good name and reputation of the Bank. Each employee of the Bank shall immediately inform the relevant internal unit of any reasonable doubt about possible violations of antitrust and unfair market practices.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board on 5th September 2023 is in force. The full version of the policy is internal information and has not been released to the public.

  • Pekao Group conflict of interest management policy

    • The policy sets out the principles for managing conflicts of interest and defines the circumstances that cause or may cause conflicts of interest in the Bank's operations. The Bank applied the methodology for managing conflicts of interest that makes it possible to identify and assess compliance risk connected with a specific conflict, choose appropriate measures to prevent or minimize negative consequences, eliminate conflicts of interest and monitor them. The Bank defines circumstances in which conflicts of interest are most frequently identified, taking into consideration both areas potentially at risk of a conflict of interest and types of relations concerning the Bank, employees, entities from the Pekao Group and third parties, especially customers and trading partners of the Bank.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board on 5th September 2023 is in force. The full version of the policy is internal information and has not been released to the public.

  • Policy of corporate governance of Subsidiaries and with participation of Bank Polska Kasa Opieki Spółka Akcyjna

    • The purpose of the Policy is to ensure corporate governance of Subsidiaries. This oversight takes into account the nature and scale of operations, as well as the size and profile of the risks to which Pekao Group subsidiaries are exposed. Specifically, the Policy addresse 

      • supervision of the Companies in which the Bank holds shares, including corporate governance,
      • representing the Bank at general meetings and shareholders' meetings of the Companies in which the Bank holds shares,
      • keeping records relating to the Companies in which the Bank holds shares and interests,
      • submission of information and documents by the Companies to the Corporate Governance Team,
      • exercising supervision over the Pekao Foundation.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board of 27 February 2022 is in force. The full version of the policy is internal information and has not been released to the public.

Administration and organization

  • Principles for granting donations and sponsoring by Bank Polska Kasa Opieki Spółka Akcyjna

    • The Ordinance defines the authority to make decisions on granting sponsorships and donations and introduces thresholds for accepting expenses incurred. In addition, the ordinance:

      • defines the rules of operation of the Commission on Sponsorship and Donations, including defining the rules of procedure of the commission;
      • introduces standardized templates for sponsorship/donation agreements, sponsorship application and donation application, containing basic information about the organizer, the project and the benefits offered to the Bank in exchange for a certain financial commitment;
      • introduces a sponsorship report/ of the donation awarded, which each beneficiary is required to prepare after the project is implemented;
      • clears up issues related to GDPR.

      Currently, the Principles adopted by the Resolution of the Bank's Management Board of 14 July 2022. are in force. The full version of the Principles is internal information and has not been released to the public.

  • Procedure for applying financial sanctions at Bank Polska Kasa Opieki Spółka Akcyjna

    • The purpose of the Procedure is to ensure the Bank's compliance with regulatory and legal requirements, to define the principles and rules for limiting business contacts with countries, entities and individuals that are subject to financial sanctions imposed by, among others, European Union, the United States of America through the U.S. Treasury Department's Office of Foreign Assets Control, the United Nations, and protecting the Bank's reputation. Application of the Procedure excludes the possibility of the Bank taking actions contrary to national and international financial sanctions.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board of 13 January 2021 is in force.  The full version of the Procedure is internal information and has not been released to the public.

  • Procedure for prevention of money laundering and financing of terrorism at Bank Polska Kasa Opieki Spółka Akcyjna

    • Procedure sets out the Bank's prevention of money laundering and financing of terrorism policies based on national, international regulations and banking standards. The procedure applies to all organizational units of the Bank involved in the process of servicing customers and their transactions. In particular, required to comply with its requirements are:

      • all employees of the Bank
      • Agents, Sales Partners and other entities to the extent specified in the agreements concluded with the Bank, which are involved in the process of servicing customers.

      Procedure is applied in every business activity undertaken by the Bank.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board 3 March 2023 is in force. The full version of the Procedure is internal information and has not been released to the public.

  • Procurement Policy of Bank Polska Kasa Opieki Spółka Akcyjna

    • The Procurement Policy sets forth the overarching principles applicable to Bank Polska Kasa Opieki Spółka Akcyjna in the implementation of procurement processes. The regulation takes into account the description of the roles of key stakeholders in the process, the principles of purchasing category management, purchasing planning, as well as the main principles accompanying supplier selection and procurement execution in the Bank. In addition, the Policy defines methods for monitoring and reporting on the effectiveness of purchasing processes and the scope of cooperation with Group entities. The Purchasing Policy is detailed in the regulations: Rules for the implementation of purchases by the Purchasing Department and Rules for the implementation of purchases without the participation of the Purchasing Department.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board 30 November 2022 is in force. The full version of the Policy is internal information and has not been released to the public.

  • Fraud management process

    • Bank Pekao has an ordinance - Fraud Management Process introducing the Business Instruction - Fraud Management Process at Bank Polska Kasa Opieki S.A.. The Business Instruction specifies:

      • what is fraud and what categories of fraud may affect the Bank in the course of its business;
      • who (which organizational unit of the Bank and which employee of this unit) is obliged to implement actions in the event of a fraud incident;
      • how exactly fraud should be countered (catalog of activities to be carried out).

      In addition, the duties and responsibilities of the Financial Security Office in Bank Pekao’s Security Department, which performs tasks related to the central coordination of financial crime prevention in the Bank, are defined.

      The Fraud Management Process and the implemented Business Instruction impose duties and powers on each Bank employee related to countering financial crime to the detriment of the organization itself and the Bank’s customers.

      Currently, the Process adopted by the Resolution of the Bank's Management Board 24 March 2021 is in force. The full version of the Process is internal information and has not been released to the public.

Accounting, reporting and planning

  • Bank Capital Management Policy

    • The policy defines the roles, process and methodologies of capital management in the Bank. These policies include two main categories: capital allocation and capital management. In addition, it defines the process for managing a capital crisis and defines the rules for managing capital in the event of capital shortfalls. The goal of capital management is to maximize value for shareholders by managing capital adequacy and managing the profitability of capital. Each year, a "Capital Management Strategy" is developed, which sets out the Bank's and the Group's capital management objectives and key indicators for the year. 

      Currently, the Policy adopted by the Resolution of the Bank's Management Board of  12 May 2023  is in force. The full version of the Policy is internal information and has not been released to the public.

  • Information on Bank Pekao S.A.'s ongoing tax strategy

    • In carrying out the tax function, Bank Pekao is guided by its tax strategy, the main premise of which is that Bank Pekao adheres to the principles of social justice by paying tax liabilities in proportion to its profits. The purpose of Pekao Bank's tax strategy is to set the overarching principles of operation and decision-making that affect Pekao Bank's approach to tax issues and the organization of the tax function at the Bank in a way that allows the Bank to properly perform its obligations under tax law, including, in particular, the correct (in the correct amount and manner) and timely declaration of tax bases and payment of tax dues. The information is compiled annually.

  • Principles of information policy of Bank Polska Kasa Opieki Spółka Akcyjna in the area of contact with investors and sell-side market analysts, media and clients

    • The primary objective of the Policy is to ensure the conditions for effective communication of the Bank with the external environment and to provide securities market participants with universal and equal access to information about the Bank. Information on the Bank is made available in a manner that guarantees decision-making by reasonable investors and in accordance with the requirements of applicable law. The exchange of information with representatives of the media and the Bank's Customers is carried out in an effective manner, ensuring that high standards of communication are maintained. The Bank provides access to information on its current operations and financial situation.

      Currently, the Policy adopted by the Resolution of the Bank of 24 February 2025 is in force.

      This information is publicized, among others, on the www.pekao.com.pl website under the “Information for investors” tab.

      Link to the Policy on the Bank's website.

Market codes

  • Best Practices of WSE Listed Companies 2021

    • The Best Practices of Companies Listed on the WSE 2021 is a set of corporate governance principles to which issuers of shares listed on the WSE's Main Market have been subject since 2002, based on the provisions of the Rules of the Warsaw Stock Exchange. The Good Practices take into account the current state of the law and the latest corporate governance trends, as well as the demands of market participants attaching importance to improving corporate governance standards in listed companies. The Good Practices include requirements related to the ESG area, including issues of sustainability, diversity in the composition of corporate bodies and equal pay.

      The Best Practices of Companies Listed on the WSE 2021 were adopted for application by the resolution of the Bank's Management Board of 3 August 2021.

      A statement on the company's compliance with the corporate governance principles contained in Best Practice for GPW Listed Companies 2021 of 13 March 2025

  • Canon of Good Financial Market Practices

    • The Canon of Good Financial Market Practices, adopted by the Financial Supervision Commission, articulates the basic values and ethical ideals guiding financial entities, and all the principles of the Canon form an integral, complementary whole. At the same time, the Canon leaves financial entities and their self-regulatory organizations the freedom to shape and evaluate the application of ethical standards in accordance with the peculiarities of the various market sectors and different organizational arrangements, as well as their track record in creating and improving principles of good practice.