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Management

Business Conduct

Ethics and responsibility are the foundation of our business operations and organizational culture. Through our business conduct policies, we commit to adhering to the highest ethical, legal, and social standards, both internally and externally.

The policies in place at the Pekao Group not only define the expected attitudes and behaviors of employees and business partners, but also outline mechanisms for monitoring, reporting, and process improvement. Their goal is to build trust, strengthen corporate governance, and ensure that decisions made within the Group are consistent with the principles of integrity, responsibility, and respect for human rights.

The effective promotion of organizational culture is supported by daily activities and regular training in areas such as corporate governance, ethical standards and the Pekao Group Code of Conduct, anti-corruption, and reporting violations.

The most important procedures in place at the Bank and the Group include:

  • Whistleblowing Procedure

    • The Bank has implemented a comprehensive Whistleblowing Procedure at Bank Pekao S.A., which aims to enable whistleblowers to report irregularities safely, confidentially, and effectively. This procedure supports a culture of ethics, compliance with the law and the Bank's internal standards, and describes the principles of reporting violations and protecting whistleblowers.

      The Whistleblowing Procedure applies to all employees, collaborators, suppliers, individuals performing work for the Bank, and other individuals who may become aware of violations in a work-related context.

      The Procedure is available on the Bank's intranet, and information about the Whistleblowing Procedure at Bank Pekao S.A. is available on our website. Individuals and legal entities applying for employment with the Bank will be familiar with it during the recruitment or negotiation phase.

  • Mobbing Prevention

    • Guided by the principles of social responsibility and concern for employee well-being, we have implemented an internal Procedure for Counteracting Mobbing, Discrimination, Harassment, and Other Undesirable Behavior. Its goal is to effectively prevent and eliminate all forms of inappropriate treatment in the workplace, including behaviors that violate personal dignity, the spirit of cooperation, and mutual respect.

      This procedure supports the Bank's organizational culture based on the values ​​of #STRAIGHTFORWARD, #TOGETHER, #BRAVE, #RESPONSIBLE, #DETERMINED, #OPEN, and #HONEST, and is a key element of the ethics and social risk management system. The document applies to all Bank employees, regardless of position, and applies in all work-related situations, both on-site and during business trips.

      The procedure does not provide for exceptions, underlining its universal nature and importance for the entire organization. The document is available on the intranet, and each employee is required to familiarize themselves with its content and confirm their acceptance with a signed declaration.

  • Corruption Prevention

    • At the Pekao Group, we firmly counteract all forms of corruption and situations that could foster its occurrence. We do not condone corrupt activities, regardless of whether they are undertaken by Bank employees or by individuals or entities solely associated with the Bank. This includes offering, promising, requesting, transferring, or accepting so-called facilitation payments (small, unofficial payments made to expedite the completion of routine activities) by employees or others.

      As part of our preventive measures, we have implemented a number of rules of conduct, including:

      • a prohibition on all corrupt activities by Bank employees,
      • a prohibition on facilitation payments,
      • an obligation to analyze corruption risks in daily operations,
      • and protection for employees who report corruption.

      The current 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 on the intranet and is available to all employees.

Supplier Relationships

Collaboration with suppliers – regardless of their scale – is crucial to us. We strive to build long-term relationships based on mutual trust and equality. Each partner is selected transparently, in accordance with our procedures, best market practices, and applicable laws.

We base our operations on the following practices:

Procurement Policy

The Bank's procurement processes are governed by three key internal documents: the Procurement Policy of Bank Polska Kasa Opieki S.A., the Principles for Procurement by the Procurement Department, and the Principles for Procurement Without the Involvement of the Procurement Department. The Procurement Department is responsible for implementing, managing, and monitoring these policies, as well as for improving procurement processes. The Procurement Policy serves as a tool for implementing the strategic vision for the development of procurement, and also ensures transparency, compliance with ESG principles, and uniform standards of procurement practices.

Supplier Code of Ethics

The Bank Pekao S.A. Supplier Code of Ethics defines the principles of cooperation with suppliers and their subcontractors. In this way, we promote social responsibility, transparency, sustainable development, respect for human rights, and business ethics. The purpose of the Supplier Code of Ethics is to ensure that suppliers act in accordance with our Bank's values ​​and support its ESG strategy.

ESG Form

By introducing the requirement to complete the ESG Form for all procurement processes, regardless of their value or the size of the potential supplier, we are clearly emphasizing the importance of promoting sustainable development, environmental protection, and respect for human rights throughout the supply chain. Enforcing this requirement demonstrates our responsibility to our business partners and the social environment, while also enabling ongoing monitoring of compliance with adopted standards without identifying significant risks in this area.

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.