Policies and procedures

Corporate governance

  • Code of Conduct of the Pekao Group
    • 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 in the "Corporate Governance" tab: link
       

  • 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: link
       
       

  • 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 - Bank Pekao S.A. in the dedicated Supplier Zone and in the Integrated Procurement Tool.

       

  • Information on the Whistleblowing Procedure of Bank Pekao S.A.

    • Bank Pekao S.A. is guided by high standards resulting from legal provisions, internal regulations and ethical standards. Reporting violations allows to properly manage the problem and reduce the risk of repeat inappropriate behavior in the future.
      “Whistleblowing Procedure of Bank Pekao S.A.” defines the procedure for reporting violations, the rules for their verification and taking corrective actions, as well as the protection of the whistleblower against retaliation. 

      Currently, the Procedure adopted on 11.12.2023 by the Ordinance of the Bank's Management Board is in force. The full version of the Procedure is internal information and has not been made available to the public.
       

  • 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.
       

Employee matters

  • Mobbing Prevention Policy of Bank Polska Kasa Opieki Spółka Akcyjna

    • In the Policy, the Bank has obliged all employees to prevent mobbing and, in particular, to respond to "behavior concerning an employee or directed against an employee, consisting of persistent and prolonged harassment or intimidation of an employee, causing an employee to have a low opinion of his/her professional suitability, consisting of or intended to humiliate or ridicule an employee, isolate him/her or eliminate him/her from the team of co-workers, unethical and inappropriate behavior, Each employee is obliged to notify the Employer in writing of any manifestation of mobbing that he/she notices, and the Employer is obliged to clarify the reported complaint and, if any irregularities are found, to draw appropriate consequences in accordance with the law.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board of 20 November 2009 is in force. The full version of the policy is internal information and has not been released to the public.
       

  • Remuneration policy for members of the Supervisory Board and Management Board of Bank Polska Kasa Opieki Spółka Akcyjna
    • The Policy defines framework principles and rules governing the determination, monitoring and controlling remuneration principles and practices used by the Bank in regard to Members of its Supervisory Board and Management Board. The document identifies solutions that contribute to the Bank's business strategy, long-term interests and stability, as well as to support the Bank's sustainable development, including ensuring the Policy's consistency with the strategy of introducing risks for sustainable development into the business in the investment decision-making process.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board of 11 January 2023 is in force. The full version of the policy is internal information and has not been released to the public.

      'Description of the Bank's Remuneration Policy' is available on the Bank's website in the "Corporate Governance" tab: link
       
       

  • Procedure and process of periodic evaluation of employees of Bank Polska Kasa Opieki Spółka Akcyjna

    • The purpose of the periodic evaluation of Employees is to provide feedback on the degree and manner of completion of the tasks assigned to the Employee in a given Evaluation Period, as well as to increase the level of commitment and efficiency, through the exchange of information between the evaluated and the evaluator regarding: expectations, evaluation criteria, planned development of the Employee. The results of the Evaluation provide information in support of the effective implementation of the Bank's human resources management policy. The particular elements of the evaluation are:
      • outcome evaluation,
      • commitment evaluation,
      • conformity evaluation.
      A component of the process is a direct debriefing conversation between the employee and the supervisor. The Employee can appeal his evaluation.

      Currently, the Procedure adopted by the Resolution of the Bank's Management Board of 14 July 2021 is in force. The full version of the procedure is internal information and has not been released to the public.

  • Collective Labor Agreement

    • The Company Collective Labor Agreement of Bank Pekao S.A. specifies, among other things:

      • principles of the HR policy,
      • working time,
      • principles of the remuneration policy,
      • principles for basic pay,
      • bonus fund,
      • incentive award fund,
      • bonuses,
      • retirement and disability severance payments, severance payments related to termination of employment relationships for reasons not related to employees.

      The Agreement was concluded in Warsaw on 15 December 2005 between Bank Polska Kasa Opieki Spółka Akcyjna and the company trade unions operating in the Bank. The agreement applies to all employees employed by the Bank under an employment contract.

Administration and organization

  • Policy of corporate governance of Subsidiaries and with participation of Bank Polska Kasa Opieki Spółka Akcyjna
      1. 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 addresses:
        1) supervision of the Companies in which the Bank holds shares, including corporate governance,
        2) representing the Bank at general meetings and shareholders' meetings of the Companies in which the Bank holds shares,
        3) keeping records relating to the Companies in which the Bank holds shares and interests,
        4) submission of information and documents by the Companies to the Corporate Governance Team,
        5) 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.

  • 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:
      1. All employees of the Bank
      2. 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.

  • Bank Pekao S.A. Group's policy on health and safety at work
    • The purpose of the Policy is to carry out the tasks and responsibilities under occupational health and safety regulations, as well as to ensure the exchange of knowledge, experience, best practices and standards, and expert support in the field of occupational health and safety between the Bank and the Subsidiaries. Among other things, the Policy includes the basic rules of conduct for Bank employees, as well as the responsibilities and division of tasks in the field of health and safety.

      Currently, the Policy adopted by the Resolution of the Bank's Management Board 21 September 2022 is in force. The full version of the Policy is internal information and has not been released to the public.

  • Information Security Policy
    • The Bank's goal in terms of information security is to ensure an adequate level of information security, in particular, customer data and customer transactions processed in information systems, as well as to provide access to Information to appropriate authorized parties. The policy applies to the Bank's information systems, processing information in both traditional and electronic form, owned or merely administered by the Bank. 

      Currently, the Policy adopted by the Resolution of the Bank's Management Board 23 February 2023 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.

  • Risk culture principles at Bank Polska Kasa Opieki Spółka Akcyjna
    • The Principles define norms, attitudes and behaviours of the Bank relating to its risk awareness, risk-taking and risk management as well as control mechanisms shaping risk decisions within the risk appetite adopted by the Bank.

      The principles of the risk culture in particular relate to:
      1. Development of desirable attitudes in this area by presenting relevant examples,
      2. Responsibility of employees related to their function in the context of promoting key values and compliance with the risk appetite adopted by the Bank,
      3. Incentive schemes of not only financial nature,
      4. Way of communication,
      5. Training employees to take account of employees' risk-taking and management responsibilities.

      The Principles are an integral element of the risk management process at the Bank.

      The Principles were adopted by a resolution of the Bank's Supervisory Board of 13 December 2021. The full version of the Principles 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.

Relationships with stakeholders

  • 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.

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

      Currently, the Policy adopted by the Resolution of the Bank's Management Board of 14 February 2019 is in force.

Climate and environment

  • Credit Risk Policy
    • Credit Risk Policy 2022 defines the strategy and risk appetite for the Bank's and Pekao Group's lending activities as part of prudent risk management. The content of the Policy is based on the Bank's experience, good risk management practices, regulatory requirements and the projected macroeconomic scenario. The Credit Risk Policy reflects the assumptions of the Bank's ESG Strategy, taking into account the following:
      • increasing the bank's involvement in financing green projects,
      • limiting the bank's involvement in high-carbon activities,
      • the bank's support for the transformation of Poland's energy sector.

      The Credit Risk Policy is approved annually by the Bank's Supervisory Board.

  • Policy on optimization of energy consumption at Bank Polska Kasa Opieki S.A.
    • The policy sets forth principles and rules regarding standards and guidelines for optimizing the Bank's energy consumption in terms of environmental protection based on a commitment to properly monitor and prevent, as far as possible, any negative environmental effects of its operations. The principles outlined in the Policy are guidelines for each employee to influence awareness of the environmental issue by optimizing energy consumption. They should be applied with reasonable flexibility, taking into account the specific situations of each job.

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

Market codes

  • Code of Banking Ethics (Principles of Best Banking Practices)
    • The Code of Banking Ethics is a set of rules of good banking practices, expected standards and ethical requirements of particular importance in shaping the ethical conduct of banks, indicating the proposal of a standard for the banking sector. The principles of the Code apply apply to banks, persons employed by them and persons through whom banks perform banking activities, respectively.

      Ethical principles are a guideline for the proper conduct of banks. They contribute to eliminating unacceptable behavior and shaping an environment conducive to ethical behavior and strengthening the bank's ethical culture and promoting adopted ethical standards.

      The current Code of Banking Ethics was adopted by resolution of the XXXVI General Meeting of the Polish Bank Association on April 19, 2023.

  • 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

  • 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.