MANAGEMENT BOARD’S REPORT ON THE ACTIVITIES OF THE
BNP PARIBAS BANK POLSKA S.A. GROUP
2025
including Management Board’s Report on the activities of BNP Paribas Bank Polska S.A. in 2025
and the Sustainability Statement of BNP Paribas Bank Polska S.A. Group in 2025
This document is a translation from the original Polish version. In case of any discrepancies between the Polish and English versions, the Polish version shall prevail.
About us
Strategy and prospects
GObeyond strategy
implementation
Financial results
Risk and opportunities
Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
2
Table of contents
Letter from the Chairperson of the Supervisory Board 3
Letter from the President of the Management Board 4
Key data 2021-2025 5
About us 6
Profile of the Group and the Bank 7
BNP Paribas Group worldwide 9
The Bank on the Warsaw Stock Exchange 9
Key events in 2025 13
Bank in its environment 19
Macroeconomic conditions 20
Results of the banking sector 22
Stock market and investments 24
Strategy and outlook 26
GObeyond 2022-2025 business strategy 27
Accelerate 2030 business strategy 30
Outlook 32
Implementation of the strategy 35
Pillar UP 36
Segment description 37
Distribution channels 47
Operations and business support area 49
Entities of BNP Paribas Bank Polska S.A. Group 49
Pillar POSITIVE 52
Sustainable financing 52
Positive banking 58
Community involvement 60
Environmental responsibility 66
Pillar STRONGER 68
Digitalisation and innovation – IT strategy 68
Support for innovation 72
Cybersecurity 74
Pillar TOGETHER 75
Good workplace 75
Remuneration 77
Diverse and inclusive workplace 78
Financial results 79
Financial results of the Group 80
Results of the business segments 99
Financial results of the Bank 103
Risks and opportunities 114
Risk management system 115
Principal types of risk 118
Sustainability Statement 134
General Disclosures (ESRS 2) 135
Climate change (ESRS E1) 160
Own workforce (ESRS S1) 181
Consumers and end-users (ESRS S4) 201
Business conduct (ESRS G1) 212
Additional information on the entity 219
Corporate governance 245
Compliance with corporate governance principles in 2025 246
Shares and shareholders 253
Statutory bodies of the Bank 255
Remuneration of the Management Board and the Supervisory Board 274
Diversity policy 276
Internal control system (including control and risk management system for the
preparation of financial reports) 278
Information about the auditor 279
Other information 280
Legal compliance 281
Events after the balance sheet date 289
Statements of the Management Board of BNP Paribas Bank Polska S.A. 290
SIGNATURES OF THE MEMBERS OF THE MANAGEMENT BOARD OF BNP
PARIBAS BANK POLSKA S.A. 291
About us
Strategy and prospects
GObeyond strategy
implementation
Financial results
Risk and opportunities
Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
3
Letter from the Chairperson of the Supervisory Board
Dear Shareholders, Customers and Employees of the BNP Paribas Bank Polska Group,
the year 2025 was an important and successful year for BNP Paribas Bank
Polska. We successfully completed the GObeyond strategy, achieving an ROE of
18.7%, more than 6 percentage points above our target assumption. The year-
end C/I ratio was 41.2%, exceeding our expectations. I am particularly pleased
that the bank reached a sustainable financing level of PLN 13.6 billion at the end
of 2025, representing 14.6% of our portfolio, which is considerably more than our
10% target.
In 2025, despite substantial fiscal burdens, costs of provisions for CHF loans,
declining interest rates, and geopolitical and regulatory uncertainty, we achieved
record-high net banking income of PLN 8.2 billion and net profit of PLN 3.1
billion. There were several contributing factors, including an increase in business
volume, growth in the foreign exchange and trading area, higher customer
transaction rates, further improvements in efficiency (also due to the use of
technology), control of operating expenses, and a decline in the cost of risk.
In 2025, the bank paid out a dividend for 2024 to its shareholders and, in line
with our declarations, intends to remain a dividend-paying company.
Despite geopolitical disruptions on the global stage, the continuing war in
Ukraine, and disturbances in global trade relations, last year proved to be very
good for the Polish economy, which achieved record-high GDP growth compared
to other EU countries (4% in the last quarter of 2025). Investments rising in 2025
under the National Recovery Facility (KPO) and the EU Framework 2021-2027, as
well as growing household consumption, also serve as very positive predictors
for 2026.
In this favourable macroeconomic environment, the BNP Paribas Group and BNP
Paribas Bank Polska remain active in financing large strategic projects. We
support key infrastructure projects and the energy transition, including the most
ambitious project in this area: the construction of the Polish nuclear power
plant. Last year, we also financed defence projects. The overall value of gross
loans increased in both customer segments, reaching PLN 93.6 billion at the end
of 2025 – a rise of 5.9% y/y.
The bank continued its technological development, including the development of
a secure environment for working with generative artificial intelligence. In 2025,
using an internal personal chat assistant, bank employees generated more than
34.5 million queries. We are increasingly using AI and machine learning to
develop anti-fraud systems, enhancing the security of our customers in online
channels through more effective detection of suspicious activities and fraud
attempts. In 2025, we further strengthened the security of our IT infrastructure
by developing the Threat Intelligence tool and strengthening network security,
including via cloud technologies.
I feel great personal satisfaction whenever the knowledge, innovativeness and
commitment of our bank’s employees gain recognition on the market. In 2025,
we received awards in numerous prestigious competitions, including the title of
Top Employer, National Leader in Agribusiness Financing, Best Bank in Poland for
SMEs (Global Finance award), plus accolades in the Institution of the Year
contest (“Security”, “Voice of the Customer”, “Best Internet Banking”, and “Best
Personal Banking – Branch Service”), and two Golden Banker awards (“Cash
Loan” and Golden Cybersecurity Shield). Our Wealth Management team won the
Wealth Management Business category for Central and Eastern Europe at the
WealthBriefing European Awards and took first place in the Global Private
Banking Innovation Awards.
In 2026, we will be guided by the Accelerate 2030 strategy, which has been
positively received by investors and the market. It consists of three pillars:
Expand, focused on significantly growing the customer base through unique
benefits to enhance engagement; Streamline, leveraging new technologies to
improve efficiency, and Impact, continuing to support sustainable transition. The
strategic goals are ambitious, but essential to further strengthen the competitive
position of the BNP Paribas Bank Polska Group.
I would like to extend my thanks to the bank’s Management Board and
employees for their exceptional dedication and efforts in transforming the bank,
and to our customers for their continued trust.
Lucyna Stańczak-Wuczyńska
Chairperson of the Supervisory Board of BNP Paribas Bank Polska
About us
Strategy and prospects
GObeyond strategy
implementation
Financial results
Risk and opportunities
Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
4
Letter from the President of the Management Board
Dear Shareholders, Customers and Employees of BNP Paribas Bank Polska Group,
2025 was the last year when we were guided by the GObeyond strategy. We
exceeded the financial targets set at the outset of that journey. The last 12
months of the strategy’s horizon were a year of record-breaking results.
The net banking income of the BNP Paribas Bank Polska Group in 2025 was PLN
8.2 billion (+5.6% year on year), driven by growth across all the key lines. We
generated the highest profit in history at PLN 3.1 billion (+29.7% year on year);
we increased our income while keeping costs under control – net of the BFG
contribution, the costs would have dropped year on year. With a very good
quality of the loan portfolio and lower costs of CHF loans, our cost of risk
decreased.
Similar to previous year, it is the intention of the Management Board to pay a
dividend at 50% of the net profit.
In 2025, we focused on growth and steady improvement of efficiency with new
technology and process enhancements. Our loan portfolio increased to PLN 93.6
billion as at 31 December 2025 (+5.9% year on year). Importantly, financing of
corporates, including investment loans and working capital loans, increased
substantially. Loans to institutional Customers stood at PLN 59.1 billion (+6.5%
year on year) and loans to retail Customers at PLN 34.4 billion (+4.8% year on
year). Sustainable financing remains our strategic priority: it grew to PLN 13.6
billion in aggregate (+33.9% year on year). Our deposit base continued to grow
and reached PLN 140.9 billion at the year’s end (+8.0% year on year). The growth
was reported in both Customer segments.
In December, our majority shareholder BNP Paribas completed an accelerated
bookbuilding (ABB) and sold 9.2 million BNP Paribas Bank Polska shares,
representing approximately 6.2 percent of the Bank’s equity, which increased the
Bank’s free-float shares on the Warsaw Stock Exchange. The Bank’s share price
was PLN 130.5 as at the end of 2025, up by 53.2% year on year.
I believe that alongside the good results of 2025, this was supported by the
reception of the Bank’s new strategy Accelerate 2030. The strategic objectives
are very ambitious. We plan to increase the number of active retail Customers by
1 million net, to grow our market share in corporate loans to 10%, to achieve
annual average growth of income at 6%, to reduce the C/I to less than 38%, and
to generate return on tangible equity (ROTE) of 22% in 2030. The three pillars of
the Accelerate 2030 strategy are: Expand (growing the scale of operations and
the Customer base), Streamline (improving operational efficiency with new
technology), and Impact (support Customers in sustainable transition).
The key to successful implementation of the plans is our people. I am grateful for
the engagement, creativity and professionalism of our Bank’s employees, and for
their empathy. We are an organisation where values such as mutual support,
inclusion and assistance to those in need are the foundation; we believe that we
can grow our business effectively and responsibly. In 2025, our volunteering
engagement confirmed that we care for our environment. The Bank’s employees
dedicated a total of more than 19,000 hours to helping others. Thank you! I
count on your full mobilisation also this year. Under our new strategy, we will
continue to develop our business with care and empathy.
I am positive that out experience, resilience and flexibility, combined with the
invaluable support of the BNP Paribas Group, the biggest bank in the European
Union, are all the assets we need to successfully pursue the ambitious objectives
of our new strategy. The falling rate environment is not good for the banking
sector, but we see it as an incentive to grow rather than an excuse. Prevailing
geopolitical and regulatory uncertainty remains a risk whose impact on the
industry is hard to predict. Nonetheless, the growing strength of the local
economy makes me optimistic about the future. The year 2026 will bring
challenges and great opportunities for Poland and the banking sector. We want
to actively assist our Customers in seizing this opportunity.
Przemek Gdański
President of the Management Board of BNP Paribas Bank Polska
About us
Strategy and prospects
GObeyond strategy
implementation
Financial results
Risk and opportunities
Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
5
Key data 2021-2025
2025
2024
2023
2022
2021
Balance sheet (PLN million)
Total assets
180,725
167,540
161,026
150,109
131,777
Loans and advances to Customers*
91,174
85,854
86,248
88,631
86,299
Total equity
17,598
15,394
12,861
11,262
11,362
Amounts due to Customers
141,339
130,925
127,175
120,021
101,093
Statement of profit or loss (PLN million)
Net profit
3,058
2,358
1,013
441
176
Adjusted net profit**
3,058
2,415
967
1,166
176
Net interest income
5,892
5,741
5,225
3,493
3,141
Net fee and commission income
1,261
1,249
1,211
1,137
1,049
Net banking income
8,185
7,753
7,283
5,352
4,809
Result on legal risk related to foreign
currency loans
(499)
(796)
(1,978)
(740)
(1,045)
Net impairment of financial assets and
provisions for contingent liabilities
(174)
(246)
(34)
(275)
(266)
General administrative expenses,
depreciation and amortisation
(3,369)
(3,352)
(3,096)
(3,038)
(2,544)
Financial indicators (%)
Net ROE
18.7%
16.9%
8.2%
3.9%
1.5%
Net ROA
1.8%
1.5%
0.7%
0.3%
0.1%
Cost/Income (C/I)
41.2%
43.2%
42.5%
56.8%
52.9%
Adjusted net ROE**
18.7%
17.3%
7.7%
10.2%
1.5%
Adjusted net ROA**
1.8%
1.5%
0.6%
0.8%
0.1%
Adjusted Cost/Income (C/I)
without BFG and IPS**
38.8%
41.0%
41.1%
42.9%
49.9%
Net interest margin
3.46%
3.56%
3.43%
2.46%
2.51%
2025
2024
2023
2022
2021
Share of NPLs in gross loans and
advances portfolio***
2.8%
3.2%
3.0%
3.3%
3.6%
Cost of risk
(0.19%)
(0.28%)
(0.04%)
(0.30%)
(0.32%)
Total capital ratio
16.86%
17.20%
16.67%
15.55%
16.91%
Tier 1 capital ratio
13.60%
13.80%
12.51%
11.28%
12.33%
Shares
Capitalisation
(PLN million)
19,298
12,593
12,641
8,265
13,454
Number of shares (million)
148
148
148
148
148
Share price (end of period) (PLN)
131
85
86
56
91
Business information (thousand)****
Number of Bank Customers:
2,694
3,017
4,186
4,227
4,117
Retail Customers
2,371
2,688
3,831
3,877
3,810
Institutional Customers
323
329
356
350
307
ESG
Value of sustainable financing
(PLN billion)
13.6
10.2
9.6
6.5
3.1
Number of active employees in the
Group
7,255
7,512
7,740
8,020
8,048
Number of Customer Centres with
“Barrier-Free Facility” certification
144
143
131
103
77
Note: due to the change made from 1 January 2023, in accordance with IFRS 9, in the presentation of the impact of legal risk arising from court proceedings related to CHF mortgage loans, in the case of
Net assets, Loans and advances to Customers and Share of NPLs (Stage 3), the column for 2022 presents restated figures. For indicators for which we use quarterly averages, the restated figures were
adopted for all quarters of 2023. No recalculation of average values was made for previous years. Details of the definitions and assumptions used are presented in the Alternative Performance Measures
section.
* Net values, including loans measured at amortised cost and at fair value.
** Adjusted figures calculated net of the impact of credit holidays in 2022, 2023, 2024 and integration costs incurred in connection with the implementation of merger processes in 2020.
*** Refers to the portfolio measured at amortised cost. NPL defined as loans and advances in Stage 3 and POCI non-performing as presented in the note to the Consolidated Financial Statements
**** Number of retail Customers (i.e. individuals and micro-enterprises) in 2024–2025 is presented according to the new definition: Customers with an existing valid contractual relationship. The decrease
in the number of Customers results from the retail Customer base review carried out in 2025 (including the closure of inactive accounts). Data for 2021–2023 are presented in line with the definition
applicable at that time.
About us
Strategy and prospects
GObeyond strategy
implementation
Financial results
Risk and opportunities
Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
6
About us
7 Profile of the Group and the Bank
9 BNP Paribas Group worldwide
9 The Bank on the Warsaw Stock Exchange
13 Key events in 2025
About us
Strategy and prospects
GObeyond strategy
implementation
Financial results
Risk and opportunities
Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
7
Profile of the Group and the Bank
BNP Paribas Bank Polska S.A. (the Bank) is a universal bank.
Retail Customers are offered a selection of savings and investment products as well as a wide range of loans, including
housing and consumer loans. For private banking Customers, we offer a comprehensive offer including protection,
optimisation and growth of wealth. The Bank’s Customers can use our investment advisory services.
We provide micro, small and medium-sized enterprises as well as corporations with local and international financing
solutions. Our services are also addressed to enterprises in the agro-food sector. We specialise in financing agriculture, the
food economy and regional infrastructure.
We have been active in the Polish market for over a hundred years. Our ties with the global BNP Paribas financial group
enable us to apply the best international practices to meet the needs of the local market and the expectations of the Bank’s
Customers. We provide our services all over the country through a network of Bank branches, partner branches, as well as
online and mobile banking. We cooperate with partner stores and selected car dealers.
As a Bank of Green Changes, we support our Customers’ transition to a low-carbon economy and inspire them to make
responsible financial decisions. We consistently pursue a strategy of financing investments with a positive social, economic,
and environmental impact.
The Bank is part of the international BNP Paribas banking group (BNP Paribas Group).
The Bank and its subsidiaries form the BNP Paribas Bank Polska S.A. Group (the Group), which ranks sixth by total assets in
the domestic banking sector. Employment in the Group measured in active FTEs is 7.2 thousand.
The BNP Paribas Bank Polska Group operates on the basis of operating segments (each business line’s share of the Group’s
net banking income (NBI) for the 12 months of 2025 is shown below in %):
• Retail and Business Banking – serves retail Customers, including private banking Customers (Wealth Management) and
business Customers, including micro-enterprises. The largest share of NBI – 48.8%,
• Corporate Banking – offers a wide range of financial services to large and medium-sized enterprises, local governments
and entities that are part of international groups. Share of NBI – 27.4%,
• Small and Medium-sized Enterprise Banking – serves Agro and non-Agro Customers. Share of NBI -9.7%,
• Corporate and Institutional Banking (CIB) – supports the sale of Group products to Polish companies and serves strategic
Customers. Share of NBI – 5.5%,
• Other banking operations include the Asset and Liability Management Division and the Corporate Centre. Share of NBI –
8.5%.
The Bank’s head office is located in Warsaw, at 2 Marcina Kasprzaka Street.
The shares of BNP Paribas Bank Polska S.A. are listed on the Warsaw Stock Exchange.
Bank’s and Group’s position in the Polish banking sector and market shares
Chart 1. Total assets of the BNP Paribas Bank Polska S.A. Group as at 31 December 2025 compared to the largest banks
(PLN billion)
According to the interim reports, which were the most up-to-date source of comparable performance information for the
banks listed on the WSE at the date this Management Report was approved for publication, BNP Paribas Bank Polska S.A.
Group was the sixth largest banking group in Poland in terms of total assets.
554,568
352,233
308,150
282,025
280,253
180,725
155,673
101,775
Bank 1 Bank 2 Bank 3 Bank 4 Bank 5 BNPP Bank 7 Bank 8
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
8
Table 1. Market shares of BNP Paribas Bank Polska
31.12.2025
31.12.2024
Loans to non-bank Customers
including:
5.65%
5.67%
Loans for retail Customers
4.69%
4.79%
Non-financial business entities
8.85%
8.82%
Deposits from non-bank Customers
including:
5.59%
5.67%
Deposits from retail Customers
4.39%
4.43%
Non-financial business entities
8.88%
9.33%
In loans to non-bank Customers, the Bank’s market share in the sector remained stable, amounting to 5.65% at the end of
2025 compared with 5.67% at the end of 2024. A slight decline in market share occurred in the category of loans to retail
Customers, but this was partially offset by an increase in the segment of loans to non-financial entities. A modest decline in
the market share in loans affected PLN mortgage loans and consumer loans as a consequence of slower growth in the
Bank’s volumes relative to the growth observed in the banking sector. It should be emphasised that the first half of 2025
brought a slow-down of decline and the second half of the year a recovery of the Bank’s market share in PLN mortgage
loans following an easing of the previous more selective and more conservative credit policy and a pronounced increase in
sales.
The Bank’s share of non-bank Customer deposits decreased modestly to 5.59% from 5.69% at the end of 2024. This was due
to a decrease in the Bank’s share of deposits from non-financial entities as their volume was growing less fast at the Bank
(compared with the end of 2024) relative to the growth observed in the banking sector.
Group structure and subsidiaries subject to consolidation
BNP Paribas Bank Polska S.A. (the Bank) is the parent entity of the BNP Paribas Bank Polska S.A. Group (the Group)
operating in Poland. The subsidiaries that are part of the Group as at 31 December 2025 (fully consolidated) are listed
below. The Bank’s share in the equity of each subsidiary is presented in percentages:
Structure of BNP Paribas Bank Polska S.A. Group as at 31 December 2025
The structure of the BNP Paribas Bank Polska S.A. Group did not change in 2025.
In addition to Group companies, the Bank held equity investments in infrastructure companies as at 31 December 2025,
including Biuro Informacji Kredytowej S.A., Krajowa Izba Rozliczeniowa S.A., VISA Inc., Mastercard Inc. and SWIFT. We held
minority, non-controlling interests, shares or convertible bonds in over a dozen medium-sized Polish companies. The value
of investments in shares and minority interests is not material in view of the scale of the Bank’s and the Group’s business
and financial performance. These investments are financed from own resources.
All transactions between the Bank and related parties resulted from ongoing operational activities and mainly included
loans, deposits, derivative transactions, income and expenses from advisory services and financial intermediation. Detailed
information on transactions with related parties is provided in Note 51 of the Consolidated Financial Statements of the BNP
Paribas Bank Polska S.A. Group for the year ended 31 December 2025.
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Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
9
BNP Paribas Group worldwide
The Bank’s strategic shareholder is the leading international banking group BNP Paribas, which operates in three key areas:
• Corporate & Institutional Banking – services for corporate and institutional Customers,
• Commercial, Personal Banking & Services – services provided by the sales network and specialised business units,
• Investment & Protection Services – savings, investment and insurance services.
The BNP Paribas Group supports retail Customers, entrepreneurs, local governments, small and medium-sized enterprises,
corporates and institutions in the implementation of projects by offering them a range of financial, investment, savings and
insurance products.
The BNP Paribas Group operates in 64 countries and employs almost 178 thousand people, including 144 thousand in
Europe.
Since 2022, the BNP Paribas Group has been implementing the GTS strategic plan for 2022-2026. The strategy is built on
three pillars: growth, technology, and sustainability.
The BNP Paribas Group’s GTS strategy ambitions:
• GROWTH – further development of a profitable business based on leading position of the BNP Paribas Group in Europe,
• TECHNOLOGY – technology supporting Customer experience and operational efficiency,
• SUSTAINABILITY – the Group’s business focuses on supporting the financing of sustainable development.
The Bank on the Warsaw Stock Exchange
Shareholding structure
As at 31 December 2025, the Bank’s shareholders included two shareholders holding at least 5% of the total number of
votes at the General Meeting: BNP Paribas and BNP Paribas Fortis SA/NV. In total, they held 75.00% of the votes. The
remainder of the Bank’s shares, i.e. 25.00% were in free float.
The Bank’s shares are listed on the Main Market of the Warsaw Stock Exchange since 27 May 2011 (the new listing of Bank
Gospodarki Żywnościowej S.A.). Following the quarterly revision of exchange index portfolios on 5 June 2025, the Bank’s
shares participate in the mWIG40 index.
Chart 2. Shareholder structure as at 31 December 2025
Total number of shares 147,880,491
In December 2025, following the settlement of block trades made on 12 December 2025 in connection with accelerated
bookbuilding addressed solely to institutional investors covering 9,214,025 Bank shares, the share of BNP Paribas SA in
total votes of the Bank decreased by approximately 6.23%. As a result, free float was 25.00% as at 31 December 2025 (up
from 18.77%), supporting the liquidity of the Bank’s shares.
BNP Paribas;
51.00%
BNP Paribas
Fortis;
24.00%
Others;
25.00%
free float
25.00%
ISIN
ticker
short name
index membership
PLBGZ0000010
BNPPPL
BNP
mWIG40 and mWIG40TR
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Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
10
Share price
The year 2025 saw an improved market on the Warsaw Stock Exchange, as reflected in all-time highs of the WIG index
which covers all WSE-listed companies.
The WIG-Banks index gained 55.3% (19,177.37 points as at 30 December 2025 vs. 12,345.94 points as at 30 December
2024). WIG-Bank hit its annual high of 19,364.67 points on 13 August 2025 and an annual low of 12,358.47 points on 2
January 2025.
The closing price of the Bank’s shares was PLN 130.5 as at 30 December 2025, up 53.2% compared to PLN 85.20 on 30
December 2024. The Bank’s shares hit an annual low of PLN 85.20 on 30 December 2024 and PLN 86.40 on 2 January 2025
and an annual high of PLN 135.00 on 22 December 2025.
The WIG-Banks index gained 33.1% in H1 2025. The key drivers of bank share performance included high interest rates up
to May 2025, generating high net interest income; improved sentiment of international investors; and higher dividends
compared to previous years.
In H2 2025, the decision to raise the corporate income tax rate for banks and five interest rate cuts by the Monetary Policy
Council (six cuts in all of 2025) adversely affected bank share prices, as reflected in lower WIG-Banks gains (16.7%)
compared to H1 2025.
In Q1 2025, positive bank share performance was driven by stable interest rates, strong earnings, expected record-high
dividends, and the comeback of international investors to the local equity market. WIG-Banks gained 29.8% in Q1 2025 and
the Bank’s share price gained 29.1% reaching PLN 110.0. The Bank’s shares hit a quarterly high of PLN 112.00 on 26 and 27
March 2025 and a quarterly low of PLN 85.20 on 30 December 2024 and PLN 86.40 on 2 January 2025.
In Q2 2025, bank share prices were impacted by the first interest rate cut after October 2023, uncertainty around potential
further rate cuts (the second cut took place on 2 July 2025), and geopolitical conditions. As a result, WIG-Banks gained only
2.5% in Q2 2025 and the Bank’s share price lost 3.2% reaching PLN 106.50. The Bank’s shares hit a quarterly high of PLN
113.00 on 1 and 2 April 2025 and a quarterly low of PLN 99.00 on 11 and 13 June 2025.
A cumulation of adverse factors in the second half of Q3 2025, including the expected raise of the corporate income tax rate
for banks, a negative outlook of public debt and deficit in 2026, and a downgrade of Poland’s outlook rating, was reflected
in WIG-Banks losing 0.4% in Q3 2025. The Bank’s share price lost 2.8% reaching PLN 103.50. The Bank’s shares hit a
quarterly low of PLN 102.00 on 11 July and 5 August 2025 and a quarterly high of PLN 118.0 on 19 August 2025.
The Bank’s share price at the end of Q4 2025 was PLN 130.50, up by 26.1% quarter on quarter. The Bank’s shares hit a
quarterly low of PLN 102.50 on 1 and 17 October 2025 and a quarterly high of PLN 135.0 on 22 December 2025. The WIG-
Banks index gained 17.2% in Q4 and closed at 19,177.37 points.
Chart 3. Bank share price and turnover from 30 December 2024 to 30 December 2025
Chart 4. Bank share price performance vs. WIG-Banks from 30 December 2024 to 30 December 2025 (30 December 2024 =
100%)
The daily average share price in each quarter of 2025 was as follows: PLN 96.27 in Q1, PLN 104.72 in Q2, PLN 106.63 in Q3,
PLN 113.69 in Q4.
The daily average turnover volume was 15,329.44 shares in Q1 2025, falling to 12,411.39 shares in Q2 2025 and 9,853.86
shares in Q3 2025. The increase in free-float shares, as mentioned above, helped the daily average turnover volume to
0
4,000
8,000
12,000
16,000
20,000
24,000
28,000
32,000
36,000
60
70
80
90
100
110
120
130
140
Value of turnover (thousand PLN)
Share price (PLN)
Value of turnover
Closing price
0%
10%
20%
30%
40%
50%
60%
BNP Paribas
WIG Banki
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grow to 17,864.94 shares in Q4 2025. The daily average turnover volume in 2025 was down 6.9% year on year (13,876
shares vs. 14,890 shares).
The daily average turnover value in each quarter of 2025 was as follows: PLN 1,521.8 thousand, PLN 1,297.5 thousand, PLN
1,044.4 thousand, and PLN 2,196.7 thousand. The turnover volume hit an annual high of 283,727 shares and the turnover
value hit an annual high of PLN 35,650.6 thousand on 12 December 2025.
Table 2. Key information on BNP Paribas Bank Polska S.A. shares
2025
2024
2023
change y/y
2025/2024
Share price at year-end (PLN)
130.50
85.20
85.60
53.2%
Average share price (PLN)
105.29
95.88
59.82
9.8%
Maximum share price (PLN)
135.00
112.00
86.20
20.5%
Minimum share price (PLN)
85.20
81.00
46.80
5.2%
WIG-Banks value at year-end (points)
19,177.37
12,345.94
11,062.01
55.3%
Number of shares at year end (# shares)
147,880,491
147,799,870
147,676,946
0.1%
Capitalisation at year-end (PLN thousand)
19,298,404
12,592,549
12,641,147
53.3%
Average turnover volume per session (# shares)
44,880.35
14,889.66
10,413.86
201.4%
Average turnover value per session (PLN thousand)
5,661.27
1,482.14
633.00
282.0%
Earnings per share (PLN)*
20.67
15.96
6.86
29.6%
P/E*
6.31
5.34
12.48
18.2%
Book value per share (PLN)*
119.00
104.15
87.09
14.3%
P/BV*
1.10
0.82
0.98
33.7%
*based on consolidated data
Ratings
At the end of 2025, the Bank had a rating from the rating agency Fitch Ratings (solicited by the Bank). The history of rating
changes by the agency can be found on the Bank’s website: https://www.bnpparibas.pl/relacje-inwestorskie/o-banku/oceny-
ratingowe.
The last rating update took place on 27 October 2025. The Bank’s credit ratings confirmed in the Fitch Ratings
communication are presented below:
Fitch Ratings
Rating
Long-Term Issuer Default Rating (LT IDR)
“A+”, outlook negative
Short-Term Issuer Default Rating (ST IDR)
“F1”
National Long-Term Rating (Natl LT)
“AAA(pol)”, outlook stable
National Short-Term Rating (Natl ST)
“F1+(pol)”
Viability Rating (VR)
“bbb”
Shareholder Support Rating (SSR)
“a+”
The Bank’s overall rating including BNP Paribas Group support (LT IDR A+) was confirmed. The Bank’s rating excluding BNP
Paribas Group support (Viability Rating) was upgraded from bbb- to bbb in view of significant reduction of the legal risk of
CHF mortgage loans. Following changes to Poland’s sovereign rating, the outlook was downgraded from stable to negative.
The Bank’s IDR and SSR ratings reflect Fitch Ratings’ belief in the potential support of the Bank’s parent entity, BNP Paribas
S.A. (BNPP, IDR of “A+”, outlook stable). According to Fitch Ratings, the Bank’s VR rating of “bbb” reflects the Bank’s
moderate franchise in the competitive Polish banking market, as well as its traditional, well-balanced business model.
ESG rating
In September 2025, the rating agency Morningstar Sustainalytics updated the Bank’s ESG Risk Rating based on changes to
its assessment methodology. As a result, the Bank recorded a score of 11.5 (the lower the score, the higher the resilience to
various types of risk), which represents an increase compared with previous years (9.8 in 2024 and 10.2 in 2023). A score at
this level corresponds to a risk category defined by the agency as “Low Risk.” In 2024, the terms of cooperation with
Morningstar Sustainalytics changed – the ESG Risk Rating for 2025 was assigned on an unsolicited basis, meaning it was
not commissioned by the Bank. Disclaimer: https://www.sustainalytics.com/legal-disclaimers.
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Investor Relations
The Bank pursues a transparent information policy aimed at guaranteeing high communication standards that take into
account the information needs of capital market participants.
The Bank, as a public company and a supervised institution, follows the principles of corporate governance when disclosing
information, in compliance with the applicable laws and regulations, and ensures that participants in the capital market
have equal access to information on the company’s current operations, activities undertaken by the company and its
financial results, by fulfilling information obligations in a manner that allows a fair valuation of the Bank’s shares.
Relations with shareholders, investors and other participants of the capital market are managed by a dedicated
organisational unit at the Bank: Investor Relations Team. Important information for investors, the Bank’s shareholders and
analysts is available on the Investor Relations website https://www.bnpparibas.pl/en/investor-relations.
In 2025, the Bank made the digital version of the annual report available for the sixth time. The report for 2024 is available
at: https://raportroczny.bnpparibas.pl/en/.
At the end of January 2026, the Bank had 8 recommendations from financial institutions: 7 “Buy" ("Overweight",
"Accumulate") and 1 “Hold”. The median target price from the recommendations was PLN 144.7 and the average target
price was PLN 144.1.
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Key events in 2025
Key corporate events
March 2025
• 14 March – Individual recommendation of the Polish Financial Supervision
Authority on the criteria of dividend payment up to 50% of 2024 net profit. In
view of the strong quality of the Bank’s loan portfolio, the possible dividend rate
was raised to 75%.
• 27 March – Information on the annual contribution the bank resolution fund at
PLN 156,118 thousand for 2025 set by the Bank Guarantee Fund for BNP Paribas
Bank Polska S.A.
April 2025
• 7 April – Issue of series M shares under a conditional share capital increase and
change of the share capital of BNP Paribas Bank Polska S.A.
According to a statement from the Central Securities Depository of Poland
(KDPW) and a resolution of the Management Board of the Warsaw Stock
Exchange (WSE), as per the Bank’s current report no. 9/2025, the following
were registered in KDPW and admitted to trading by WSE on 7 April 2025:
- 20,223 series M ordinary bearer shares of the Bank with a nominal value of
PLN 1 per share (Series M Shares), which were recorded in the securities
accounts of their holders.
The Series M Shares were issued under a conditional share capital increase of
the Bank pursuant to Resolution No. 5 of the Extraordinary General Meeting of
the Bank of 31 January 2020 as amended by Resolution No. 37 of the Annual
General Meeting of the Bank of 29 June 2020. The Series M Shares were taken
up in performance of rights attached to previously acquired individual series A5
subscription warrants, each of which conferred the right to take up one Series
M Share.
According to the second sentence of Article 451 (2) of the Commercial
Companies Code, the award of the Series M Shares took effect when the Shares
were recorded in the securities accounts of their holders.
As a result, under Article 451 (2) in conjunction with Article 452 (1) of the
Commercial Companies Code, rights were acquired in 20,223 Series M Shares
with a nominal value of PLN 20,223 and the Bank’s share capital was increased
from PLN 147,799,870 to PLN 147,820,093, divided into 147,820,093 shares
with a nominal value of PLN 1 per share.
April 2025
• 8 April – Issue of series N shares under a conditional share capital increase
and change of the share capital of BNP Paribas Bank Polska S.A.
According to a statement from the Central Securities Depository of Poland
(KDPW) and a resolution of the Management Board of the Warsaw Stock
Exchange (WSE), as per the Bank’s current report no. 11/2025, the following
were registered in KDPW and admitted to trading by WSE on 8 April 2025:
- 60,398 series N ordinary bearer shares of the Bank with a nominal value of
PLN 1 per share (Series N Shares), which were recorded in the securities
accounts of their holders.
The Series N Shares were issued under a conditional share capital increase of
the Bank pursuant to Resolution No. 39 of the Extraordinary General Meeting
of the Bank of 27 June 2022. The Series N Shares were taken up in
performance of rights attached to previously acquired individual series B2
subscription warrants, each of which conferred the right to take up one Series
N Share.
According to the second sentence of Article 451 (2) of the Commercial
Companies Code, the award of the Series N Shares took effect when the
Shares were recorded in the securities accounts of their holders.
As a result, under Article 451 (2) in conjunction with Article 452 (1) of the
Commercial Companies Code, rights were acquired in 60,398 Series N Shares
with a nominal value of PLN 60,398 and the Bank’s share capital was
increased from PLN 147,820,093 to PLN 147,880,491, divided into
147,880,491 shares with a nominal value of PLN 1 per share.
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April 2025
• 15 April – Annual General Meeting of BNP Paribas Bank Polska S.A.
The AGM passed a resolution to pay a dividend for 2024 in the amount of PLN
1,162,340,659.26 i.e. PLN 7.86 per share. The dividend covers all of the Bank’s
147,880,491 outstanding shares.
Dividend record date: 22 April 2025, dividend payment date: 9 May 2025.
• 29 April – Entry in the National Court Register of amendments to the Articles of
Association of BNP Paribas Bank Polska S.A.: increase of the Bank’s share capital
to PLN 147,880,491 as a result of acquisition of series M shares and series N
shares under Article 29a(2)(d) and Article 29b(2)(a) of the Articles of Association
of BNP Paribas Bank Polska S.A.
May 2025
• 9 May – Minimum own funds and eligible liabilities requirement (MREL) set for
BNP Paribas Bank Polska S.A.
The MREL requirement for the Bank on a separate basis was set at 15.93% of the
Total Risk Exposure Amount (TREA) and 5.91% of the Total Exposure Measure
(TEM). The Bank was obliged to meet the requirement immediately upon receipt
of the update. As at the date of receipt of the BFG update, the Bank met the
MREL requirement set therein.
June 2025
• 2 June – Issue of Tier 2 bonds
BNP Paribas S.A., Paris, accepted the offer to acquire the capital bonds referred to
in Article 27a of the Act of 15 January 2015 on Bonds (the “Bonds”), presented by
BNP Paribas Bank Polska S.A.
The total nominal value of the Bonds is EUR 160,000,000, and the nominal value of
a single Bond is EUR 100,000. The maturity date of the Bonds is 6 June 2040.
The interest rate on the Bonds was set based on the compounded daily €STR rate
plus a margin. The interest rate was determined on market terms.
The terms of the Bond issue provide for the possibility of early redemption by the
Bank after 10 years from the issue date, subject to prior approval from the Polish
Financial Supervision Authority.
On 11 August 2025, the Polish Financial Supervision Authority approved the
classification of these capital Bonds as Tier 2 capital instruments.
The funds raised from the issue of the Bonds replaced funds originating from
subordinated loans in the amounts of EUR 60,000,000, CHF 60,000,000, and EUR
40,000,000 (as previously disclosed by the Bank in current reports no. 24/2017 of
20 November 2017 and 76/2018 of 10 December 2018). The loans were subject to
prudential amortisation and were repaid in September 2025.
September 2025
• 10 September – Fitch Ratings rating action – change of the Bank’s Long-Term
Issuer Default Rating (“IDR”) outlook from “Stable” to “Negative” and
confirmation of the Long-Term IDR and Shareholder Support Rating (“SSR”) at
“A+” and “a+” respectively.
The change in the Bank’s rating outlook follows revision of Poland’s
local-currency Long-Term Issuer Default Rating outlook from “Stable” to
“Negative.” The Bank’s ratings are capped at a level two notches above
Poland’s sovereign rating (“A-/Negative”) due to the incorporation of country
risk, which, in the Agency’s view, may limit the Bank’s ability to obtain
support from its parent entity in the event of a crisis situation.
Full list of rating actions communicated by Fitch:
• Long-Term Issuer Default Rating (LT IDR) was confirmed as “A+”, outlook
negative,
• Short-Term Issuer Default Rating (ST IDR) was confirmed as “F1”,
• National Long-Term Rating (Natl LT) was confirmed as “AAA(pol)”, outlook
stable,
• National Short-Term Rating (Natl ST) was confirmed as “F1+(pol)”,
• Viability Rating (VR) was confirmed as “bbb-”,
• Shareholder Support Rating (SSR) was confirmed as “a+”.
• 12 September – Request submitted by the Polish Financial Supervision
Authority for the Financial Stability Committee to provide an opinion on
determining the level of the Other Systemically Important Institution (O-SII)
buffer for BNP Paribas Bank Polska, whose appropriate level—according to
the principles arising from the methodology established by the Polish
Financial Supervision Authority —should be set at 0.25% of the total risk
exposure amount.
The current O-SII buffer for the Bank is set at a level equivalent to 0.50% of
the total risk exposure amount.
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October 2025
• 8 October – Issue of Tier 2 Capital Bonds
BNP Paribas S.A., Paris, accepted the offer submitted by BNP Paribas Bank Polska
S.A. to acquire capital bonds referred to in Article 27a of the Act of 15 January
2015 on Bonds (the “Bonds”).
The total nominal value of the Bonds is EUR 630,000,000, and the nominal value
of a single Bond is EUR 100,000. The maturity date of the Bonds is 10 October
2040.
The interest rate on the Bonds was set on the basis of the compounded daily
€STR rate plus a margin. The interest rate was determined on market terms.
The terms of the Bond issuance provide for the possibility of early redemption by
the Bank after 10 years from the issue date, subject to prior approval from the
Polish Financial Supervision Authority (“KNF”).
On 24 November 2025, the Bank received a KNF decision dated 21 November
2025 granting approval for the classification of the capital bonds with a total
value of EUR 630,000,000, issued by the Bank on 10 October 2025, as Tier 2
capital instruments.
The Bank’s intention is for the funds raised from the issuance of the Bonds to
replace funds obtained by the Bank from subordinated loans in the amounts of
CHF 90,000,000 and PLN 2,300,000,000, as disclosed in current reports no.
25/2019 of 13 September 2019 and 38/2020 of 7 December 2020. The first of
these loans was subject to prudential amortisation and, following KNF approval,
was repaid in November 2025. The second loan, following KNF approval, was
repaid in December 2025.
The Bank’s objective is to maintain the level of Tier 2 capital and improve the
maturity structure of the instruments that comprise it.
October 2025
• 27 October – Fitch Rating rating action – upgrade of the Bank’s Viability Rating
(VR) to “bbb” from “bbb-” and confirmation of the Long-Term Issuer Default
Rating (LT IDR) as “A+”, outlook negative, and Shareholder Support Rating (SSR)
as “a+”.
The upgrade of the Viability Rating (VR) is the result of a significant and lasting
reduction in the legal risk associated with CHF mortgage loans, which no longer
has a negative impact on the Bank’s risk profile and profitability assessment.
Full list of rating actions communicated by Fitch:
• Long-Term Issuer Default Rating (LT IDR) was confirmed as “A+”, outlook
negative,
• Short-Term Issuer Default Rating (ST IDR) was confirmed as “F1”,
• National Long-Term Rating (Natl LT) was confirmed as “AAA(pol)”, outlook
stable,
• National Short-Term Rating (Natl ST) was confirmed as “F1+(pol)”,
• Viability Rating (VR) was upgraded to “bbb”,
• Shareholder Support Rating (SSR) was confirmed as “a+”.
November 2025
• 27 November – Extraordinary General Meeting of BNP Paribas Bank Polska S.A.
Resolutions amending the Bank’s Articles of Association and approving the
consolidated text.
December 2025
• 10 December –BNP Paribas Bank Polska S.A. Group’s Strategy 2026-2030
• 16 December – Information on the change in the share of total vote in BNP
Paribas Bank Polska S.A. – as a result of the settlement of block trades
concluded on 12 December 2025 in connection with the completion of the
accelerated bookbuilding covering 9,214,025 shares of the Bank
(“Settlement”), the share of BNP Paribas S.A. in the total number of votes at
the Bank’s General Meeting decreased by approximately 6.23%.
As a result of the Settlement, on the date of notification, BNP Paribas S.A.
directly holds 75,420,141 shares of the Bank, representing approximately
51.00% of the Bank’s share capital and in the total number of votes at the
General Meeting, and together with its subsidiary BNP Paribas Fortis SA/NV
holds a total of 110,910,367 shares of the Bank, representing approximately
75.00% of the Bank’s share capital and in the total number of votes at the
General Meeting. This is consistent with the previously announced intention
to increase the number of the Bank’s shares in free float to at least 25%.
Before the Settlement, BNP Paribas SA directly held 84,634,166 shares of the
Bank, representing approximately 57.23% of the Bank’s share capital and the
total number of votes at the General Meeting, and together with its
subsidiary BNP Paribas Fortis SA/NV held a total of 120,124,392 shares of the
Bank, representing approximately 81.23% of the Bank’s share capital and in
the total number of votes at the General Meeting.
Furthermore, BNP Paribas SA reported that the above transactions were
settled at a price of PLN 120 per share (resulting in a total transaction value
of approximately PLN 1.1 billion / approximately EUR 261 million). The shares
were offered through an accelerated bookbuilding process addressed
exclusively to institutional investors. BNP Paribas S.A. has committed to a
180-day lock-up on its remaining shares in the Bank, with the possibility of
waiver by the investment firms acting as intermediaries in the transaction.
Changes to the Supervisory Board and the Management Board of the Bank are
described under Corporate governance, section Statutory bodies of the Bank.
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Awards
January 2025
• Top Employer title – awarded for the 12th consecutive year, with a score of
95.93% in this year’s certification. This confirms that the Bank has adopted the
right employer strategy and demonstrates genuine care for positive employee
relations.
• In the Rzeczpospolita ranking “Customer Satisfaction Ranking of Banks,” the
Bank ranked 4th, confirming the high level of customer satisfaction and the
Bank’s strong focus on client comfort.
• The Bank’s Economic and Sectoral Analysis Department received the LSEG
StarMine Award for the 3rd time in the last 5 years in the category “Most
Accurate Forecasters in Reuters Polls” for the most accurate forecasts of the
Polish economy for 2024. The Bank achieved the highest score in the market
(4.17 points). This is the second consecutive year the Bank has taken 1st place
in the ranking of economic forecasts for Poland.
• The Brokerage Office team secured first place in all three Parkiet rankings for
the technical, investment, and dividend portfolios, confirming its ability to make
effective investment decisions in a volatile and demanding market environment.
• The Bank won third place in the OLX KNOW HOW 2025 competition for the
#UnexpectedJobs campaign – Good decisions are often unexpected. The
competition recognised HR campaigns addressing socially important issues.
• Józef Wancer, Honorary Chairman of the Bank’s Supervisory Board, was awarded
the Officer’s Cross of the Order of Polonia Restituta by the President of Poland.
Przemek Gdański, President of the Bank’s Management Board, received the Gold
Cross of Merit for outstanding achievements in fostering innovation and
enhancing the competitiveness of the Polish banking sector.
March 2025
• Global Finance, an international magazine and financial-industry portal,
recognised BNP Paribas Bank Polska as the best bank in Poland for small and
medium-sized enterprises. The Bank retained the top position it earned last
year.
• For the fourth consecutive year, the Bank received the Ethical Company title in
the Puls Biznesu ranking. The competition highlights best-in-class business
conduct. The jury awards companies for which an ethical code is not merely a
branding element but a genuine standard of behaviour.
• In the WealthBriefing European Awards, BNP Paribas Wealth Management won
in the category Wealth Management Business in Central and Eastern Europe.
The panel particularly appreciated the Bank’s unique approach to customer
relationships, professionalism, extensive experience in managing private and
business wealth, expert knowledge, and the comprehensive support BNP Paribas
provides at every stage of cooperation.
• At the European Agribusiness Financing Forum 2025, the Bank won 1st place in
the category Leader of Domestic Agribusiness Financing.
• In the annual financial-sector summary published by Home&Market, the Bank
was recognised in the categories “Credit Card” and “Private Banking.” These
awards were granted for the best financial products available on the market.
• The Bank received awards in four categories of the Institution of the Year
competition organised by the Moje Bankowanie portal, including two categories
introduced in the 10th edition of the ranking. 21 Customer Centres in fifteen
cities received individual distinctions and the title of Best Bank Branch in
Poland. The Bank earned the title Institution of the Year in the categories
“Security,” “Customer Voice,” “Best Online Banking,” and “Best Personal Banking
– Branch Service.” The Bank has held the top position in the latter category
since 2023.
• The Bank received ISO 14001:2015 and ISO 50001:2018 certifications. This
means that the Bank’s Petrus headquarters and 10 Customer Centres comply
with international standards for environmental and energy management. In the
coming years, the Bank plans to implement these standards across all
remaining branches.
April 2025
• In the 16th edition of the Złoty Bankier ranking, the Bank won in the “Cash
Loan” category and received the Cybersecurity Golden Shield, a new award
granted for exemplary standards in data protection and digital security. In
the main ranking, which evaluates the quality of multichannel customer
service, the Bank took fourth place (an improvement of one position
compared with 2024).
• In the Paperless Hero competition, the Bank received the Digital
Transformation of the Decade award. The initiative recognises leaders of
digital change among Autenti’s clients. The Bank’s CEO, Przemek Gdański,
received the title Digital Evangelist.
• Magdalena Nowicka, Vice-President of the Bank’s Management Board, was
awarded the title Innovator of the Year 2024 in the Leaders of the Financial
World competition for implementing a comprehensive digital resilience
strategy. In response to growing threats and regulatory pressure, the Bank
conducted a detailed assessment of organisational resilience, covering IT
architecture, SDLC processes, and cost management. As part of this strategy,
the Bank effectively integrates cybersecurity, risk management, cost
efficiency, and agile practices, strengthening protection and the ability to
respond quickly to change.
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May 2025
• The Bank received an award in the SS&C Blue Prism Customer Excellence
Awards 2025, being recognised in the Operational Ingenuity category for the
EMEA region. This category highlights implementations that demonstrate
exceptional operational creativity in the field of intelligent automation. The Bank
submitted its seven-year-long concept for developing robotics, managing a
robot farm (the Master & Workers model), monitoring, collecting automation
ideas, building team competences, as well as its most notable implementations
and achieved results.
• The Bank once again became a finalist in the PSIK Awards 2025 in the Financing
Bank of the Year category. For many years, the competition has promoted the
highest professional standards in the industry and recognised institutions that
support the growth of Polish companies.
• For the fifth consecutive year, the Bank was included on the Diversity IN Check
list, which awards employers most advanced in managing diversity and
inclusion in Poland. The list, created by the Responsible Business Forum, the
coordinator of the Diversity Charter in Poland, reflects the maturity of
organisations in building inclusive work environments. This year, 75 employers
qualified, of which 15, including BNP Paribas Bank Polska, achieved an excellent
score exceeding 80% of the possible points.
• For its efforts to promote equal opportunities for people of different genders in
business and society, the Bank received a nomination in the Gender category of
the Polish Diversity Awards 2025. The awards and nominations were granted by
the editorial team of My Company Polska.
June 2025
• BNP Paribas Wealth Management was recognised for the fifth consecutive year
as the best private banking provider in the international Global Private Banking
Innovation Awards. The jury emphasised that BNP Paribas Wealth Management
is a pioneer in delivering top-quality, tailor-made services and solutions. It is
distinguished by its individualised customer approach as well as strategic
wealth management and growth.
• The Bank once again became the leader in the ESG Stars category in the
prestigious “Banking Stars” ranking by Dziennik Gazeta Prawna and Boston
Consulting Group.
• The Bank was awarded 3rd place in the Climate-Friendly Banks 2025 category
in the inaugural edition of the Ranking of Banks Supporting the Transformation
of the Polish Economy, organised by Miesięcznik Finansowy Bank. The ranking
highlights banks that not only declare climate-positive actions but actively
engage in concrete projects such as financing renewable energy, issuing green
bonds, and providing sustainability-linked loans.
• As one of the first financial institutions in Poland, the Bank received the
“Neurodiversity-Friendly Workplace” certificate from the asperIT Foundation.
This distinction confirms the Bank’s readiness to hire neurodiverse persons in
2025–2027.
• The Compliance Institute awarded the Bank the Compliance Awards 2024 in the
Compliance Idea! category for its robotisation and automation of compliance
processes.
• At the Employer Branding Excellence Awards 2025, the Bank received the main
award in the “Brand Film” category for the #UnexpectedJobs campaign – Good
decisions are often unexpected – and an honourable mention in the “Internal
Campaign” category for the Taki feedback, że aż chce MiSię campaign.
July 2025
• The Bank won three categories in this year’s Global Transaction Banking
Innovation Awards 2025, organised by the prestigious publication The Digital
Banker. The Bank’s SME and Corporate Banking division was recognised for
its innovative approach to foreign exchange services, trade finance, and the
use of technology in payments.
September 2025
• The Bank received two awards in the POLSIF Awards competition in the
categories Best Sustainable Financing and Best Sustainability-Linked (SL)
Financing for the projects Park Szczecin VI Logistics Centre and ESG-Linked
Factoring. The competition is organised by the Sustainable Investment Forum
Poland and is the only award in the country dedicated entirely to sustainable
finance.
• The Bank’s campaign “Good decisions are often unexpected
#UNEXPECTEDJOBS” received three awards in the international EBMAwards,
which recognise excellence in employer branding. In cooperation with the
agencies Be About | Hybrid Agency, the Bank received three awards granted
by the Employer Brand Management Awards and Communicate Magazine: –
Gold – Best Employer Brand Management from the financial sector, Bronze –
Best integration of the employer brand in communication strategy, Bronze –
Best communication of the employer brand to the external audience.
• The Moje Konto Premium account ranked first in the Bankier.pl ranking of the
best premium accounts.
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October 2025
• The Bank’s 2024 Annual Report was awarded for the seventh time by the Institute
of Accounting and Taxes in the prestigious “The Best Annual Report” competition.
In the 20th anniversary edition, the Bank received the special award “The Best of
The Best,” recognizing the report’s high standards, reliability, and exemplary
quality.
• The Bank was named a winner of the Forrester’s Security & Risk Enterprise
Leadership Award 2025, an honour granted to organisations that excel in
combining innovation, transparency, and effective risk management. Forrester
experts highlighted the Bank’s integrated security program, its collaborative
culture built around “security champions,” and its strategic approach to data
protection and incident management.
• In the second edition of the Forbes Ranking of Banks for Affluent Clients, the Bank
once again placed third, achieving a score of 87.88%.
• The Bank ranked 4th in the Forbes “Business-Friendly Bank” Ranking. Across the
evaluated criteria—service quality, client acquisition, remote contact channels,
and branch characteristics—the Bank earned 90% of the possible points.
• In the Newsweek Friendly Bank 2025 Ranking, the Bank achieved 5th place in the
Remote Banking module (an improvement of five positions compared with the
previous year). In the Bank for Everyman module, the Bank ranked 7th.
November 2025
• The Bank’s Fishing For Data #WPŁYWOWI campaign received one of the most
prestigious marketing awards in Poland – the Silver Effie Poland in the ESG
category. Another Bank initiative, “Good decisions are often unexpected”
#UnexpectedJobs, was nominated for an Effie Poland award in the PR &
Employer Branding category.
• During the 2025 Diversity Charter Gala, organised by the Responsible Business
Forum, the Women on Boards Awards were presented. These distinctions honour
leaders who inspire meaningful change in the business environment. Among the
award winners were two leaders from our organisation: Lucyna
Stańczak-Wuczyńska, Chairperson of the Supervisory Board, and Bożena
Leśniewska, Member of the Supervisory Board. Both were recognised for their
exceptional contributions to promoting inclusion, inspiring others, and
consistently paving the way for women in the corporate sector and leadership
roles.
• In the 8th edition of “The Best of Moto” plebiscite by gazeta.pl, the mamGO
platform and flexible car-financing options – including Arval Flex – received a
distinction in the Financial Product of the Year category.
December 2025
• The ESG Angels 2025 ranking by My Company Polska showcasing 25 leaders
of sustainable business recognised Lucyna Stańczak-Wuczyńska, Chairperson
and Independent Member of the Bank’s Supervisory Board.
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Bank
in its environment
20 Macroeconomic conditions
22 Results of the banking sector
24 Stock market and investments
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Macroeconomic conditions
GDP
In 2025, Poland’s Gross Domestic Product increased by 3.6% according to preliminary data. The main driver of economic
activity was domestic demand, which grew by 4.0%, including a 3.7% increase in household consumption expenditure and a
4.2% rise in gross fixed capital formation. As a result, the contribution of foreign trade to GDP remained negative, although
export data indicate some revival in foreign trade sales. Estimates published by Statistics Poland (GUS) show that in the
fourth quarter of 2025 alone GDP increased by 4.0% year on year in unadjusted terms (and by 1.0% quarter on quarter and
3.6% year on year after seasonal adjustment). The acceleration of economic growth in the second half of 2025 was likely
driven to a large extent by investments – both in the public sector and among enterprises. However, detailed data on the
structure of national accounts for the last quarter of the year will be published by GUS only on 2 March.
Chart 5. GDP growth
Economic activity
According to data for October–December, economic activity in Poland remained relatively strong. Industrial production
increased by 3.2% year on year (compared with 3.8% year on year in Q3), while construction and assembly output rose by
2.9% year on year (following a 2.0% decline in July–September). Real retail sales grew by 4.6% year on year (versus 4.9%
year on year in the previous quarter). Household consumption was supported by stable wage growth. In October–December,
the average nominal wage in the enterprise sector rose by 7.5% year on year. Adjusted for inflation, wages in firms
employing more than nine people increased in real terms by approximately 4.9% year on year.
The registered unemployment rate rose slightly compared with the beginning of the year and stands at 5.7%, while
employment in the enterprise sector declined by around 0.7% year on year. Leading economic indicators suggest that
further economic recovery will be driven mainly by industries benefiting from the inflow of new capital in the form of funds
from the National Recovery Plan. The improvement in manufacturing and exports should also be supported by faster
growing foreign demand, particularly in Germany.
Inflation
In the fourth quarter of 2025, CPI inflation in Poland continued to decelerate. In October–December, consumer prices
increased on average by 2.6% year on year, compared with 3.0% year on year in July–September. Excluding food and energy
prices, inflation in Q4 amounted to 2.8% year on year, i.e. 0.4 percentage points lower than in Q3 2025 (3.2% year on year).
In the coming months, core inflation is expected to continue gradually easing, supported by the appreciation of the zloty
and slowing wage growth. Labour costs are likely to rise at a slower pace in the near term, as indicated, among other
things, by business surveys. Energy prices will also play an important role in shaping CPI inflation in 2026. We forecast that
CPI inflation this year will average 2.1% year on year and will remain below the National Bank of Poland’s 2.5% inflation
target for much of the year.
Chart 6. Registered unemployment rate
0.3%
12.2%
6.7%
8.7%
8.9%
6.3%
4.1%
2.5%
-0.5%
-0.5%
0.6%
1.2%
2.3%
3.4%
2.8%
3.5%
3.2%
3.3%
3.8%
4.0%
-8%
-6%
-4%
-2%
0%
2%
4%
6%
8%
10%
12%
14%
I II III IV I II III IV I II III IV I II III IV I II III IV
2021 2022 2023 2024 2025
Individual consumption Public consumption
Accumulation Net export
GDP y/y
7.1%
6.8%
6.4%
5.9%
5.6%
5.1%
5.5%
5.0%
5.1%
5.4%
4.9% 4.9%
5.4%
5.2%
5.4%
5.6%
5.7%
4%
5%
6%
7%
8%
1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12
2021 2022 2023 2024 2025
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Monetary policy
In December 2025, the Monetary Policy Council (RPP) decided on a further adjustment of the reference rate, lowering it by
25 basis points to 4.00%. In 2025, the RPP cut interest rates six times, by a total of 175 basis points. We believe that the
monetary policy easing cycle that began last year in Poland has not yet come to an end. This was explicitly stated by NBP
Governor Adam Glapiński, who noted during his January and February press conferences that there is still room for further
interest rate cuts in Poland. The outlook for inflation – which, according to the head of the central bank, has declined in
a lasting manner – supports the case for continued downward rate adjustments. In this context, we expect the reference
rate to be reduced to 3.50% this year, although we see some risk of a slightly deeper adjustment (75 basis points) in the
coming months. At present, the market is pricing in a decline in the main policy rate to 3.25–3.50% this year.
Chart 7. Inflation and interest rates
Bond market
In the final months of 2025, the yield on Poland’s 10-year government bonds gradually declined, reaching around 5.0% in
December compared with approximately 6% recorded at the beginning of the year. This decrease was driven mainly by
improving macroeconomic conditions, including slowing inflation alongside stable economic growth. Additionally, the
National Bank of Poland was in a monetary policy easing cycle, lowering interest rates, which also translated into reduced
government financing costs. However, the fiscal premium embedded in bond yields remains elevated. The significant
budget deficit and the resulting substantial borrowing needs – and thus the large supply of government bonds on the
market – contribute to higher sovereign debt yields relative to swap rates.
FX market
Chart 8. PLN exchange rate (monthly average)
In 2025, the zloty remained very stable against the euro, trading within a very narrow range of 4.20–4.25 for most of the
year. The stability of the EURPLN exchange rate at low levels was supported by the structure of the balance of payments
(a small current account deficit and a significant inflow of foreign capital into the Polish financial market), accelerating
economic growth in Poland, and relatively high real interest rates (with inflation falling faster than nominal interest rates).
Due to the weakening of the US dollar on global markets, the zloty appreciated strongly against the U.S. currency.
The USDPLN exchange rate fell from around 4.00 in the first quarter to below 3.60 at the end of 2025.
0.10%
0.10%
1.25%
2.25%
3.50%
5.25%
6.50%
6.75%
Reference rate; 4,00%
6.75%
6.00%
5.75% 5.75% 5.75%
5.00%
4.75%
4.00%
0.51%
1.30%
4.55%
6.05%
6.80%
Rediscount rate; 4,05%
6.80%
6.05%
5.80%
5.80%
5.80%
5.80%
5.30%
4.55%
4.05%
0.50%
1.00%
2.75%
5.75%
7.00%
7.25%
7.25%
Lombard rate; 4,50%
7.25%
6.25%
6.25%
6.25%
5.75%
5.00%
4.50%
-2%
2%
6%
10%
14%
18%
1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12
2021 2022 2023 2024 2025
Inflation rate
Reference rate
Rediscount rate
Lombard rate
4.53
4.60
4.52
4.57
4.65
4.55
4.74
4.77
4.80
4.74
4.46
4.51
4.33
4.30
4.28
4.33
4.17
4.27
4.26
4.25
4.22
3.73
3.72
3.86
4.07
4.02
4.40
4.68
4.79
4.42
4.23
4.11
4.02
4.27
3.97
4.01
4.02
3.85
3.96
4.10
3.87
3.70
3.66
3.60
4.20
4.16
4.12
4.29
4.42
4.92
4.74
4.57
4.80
4.72
4.66
4.57
4.41
4.49
4.54
4.58
4.43
4.55
4.55
4.54
4.58
4.53
3.3
3.5
3.8
4.0
4.3
4.5
4.8
5.0
1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12
2021 2022 2023 2024 2025
EUR/PLN USD/PLN CHF/PLN
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Results of the banking sector
Key lines of banks’ profit and loss account
In 2025, the net profit of the banking sector in Poland, according to preliminary data from the National Bank of Poland
(NBP), amounted to PLN 48.7 billion and was higher by PLN 8.6 billion, i.e. by 21.5%, compared with 2024.
The increase in the sector’s net profit was driven primarily by several factors: growth in net interest income, an almost
twofold increase in other net income (from banking activities), and an improvement in the negative result on impairment
of financial assets and total provisions. A positive contribution came with a relative improvement in other income, and a
modest improvement in net fee and commission income. The main negative factor affecting year-on-year growth in the
sector’s net profit was an increase in total operating expenses (including depreciation, amortisation and the bank tax),
accompanied by a much smaller nominal increase in income tax expense (whose growth rate was much lower than the
growth rate of profit before tax).
Net interest income increased by PLN 3.6 billion year on year, i.e. by 3.4%, although its growth rate gradually slowed
throughout the year. This was driven by interest rate cuts by the Monetary Policy Council, which lowered NBP rates by
a total of 1.75 percentage points in 2025, ultimately bringing the average NBP reference rate down by 0.65 percentage
points year on year. The most recent cuts, implemented in Q4 2025 (a total of 0.75 percentage points), have not yet been
fully reflected in the slowdown of net interest income growth year on year due to the delayed repricing of the variable-rate
portion of the loan portfolio. Moreover, the cumulative NBP rate cuts in 2025 had a smaller-than-expected impact on
slowing net interest income growth. This was mainly due to the sector’s persistently high excess liquidity (limiting price
competition for deposits) and the high share of fixed-rate assets on banks’ balance sheets – one of the highest in recent
years. Particularly important were the high share of fixed-rate government bonds and the growing share of mortgage loans
with periodically fixed interest rates.
The upward trend in net interest income was also supported by a clear acceleration of lending activity in 2025 in the
non-financial customer segment, especially in high-margin consumer loans for individuals and in loans to non-financial
corporates, while volumes of generally less profitable loans to central government institutions remained stable. In addition
to business factors, net interest income growth was partly due to a low base in 2024, when some banks recognised the cost
of the second edition of the mortgage loan holiday programme in interest income (the final sector-wide cost did not exceed
PLN 1.1 billion and was significantly lower than initially estimated and booked by banks in H1 2024).
The nearly twofold increase in other net income (from banking activities), by PLN 4.2 billion year on year, resulted mainly
from a decline in legal risk provisions related to foreign currency mortgage loans (reported in this item by some banks).
Banks’ operating costs (including depreciation, amortisation and the bank tax) increased by PLN 4.2 billion year on year,
i.e. by 7.3%, driven mainly by comparable increases in personnel costs (up PLN 2.1 billion, or 7.6% year on year) and
general administrative expenses (up PLN 1.9 billion, or 8.2% year on year). Depreciation costs increased at a much slower
pace (2.5%) and by a marginal amount (just over PLN 0.1 billion). The fastest growth in general administrative costs was
driven by a sharp increase in regulatory costs, resulting from the reinstatement – starting in Q1 2025 – of mandatory
contributions to the Bank Guarantee Fund (BFG), amounting to PLN 893 million for the sector, and an increase in the
resolution fund contribution by PLN 250 million to PLN 1,813 million. The continued, though moderating, increase in
personnel costs was linked to ongoing wage increases (largely inflation-indexed) and, in some banks, higher provisions for
annual bonuses due to improved financial performance.
The charge to the banking sector’s results arising from the negative balance of impairment charges on financial assets and
total provisions decreased markedly year on year (an improvement of as much as PLN 3.9 billion, i.e. 20.2%). This was
driven primarily by an improvement – significant in value terms in recent years – in the negative balance of provisions by
PLN 3.5 billion, or 26.2%, resulting in particular from a decline in provisions for legal risk related to foreign currency
mortgage loans (reported in this item by some banks). The negative result on impairment charges for financial assets
improved by PLN 0.4 billion year on year, or 7.0%, accompanied by a clear improvement in the quality of banks’ receivables
from non-financial sector customers, as measured by the falling NPL ratio.
The sharp year-on-year improvement in other income – which had been strongly negative in 2024 – was driven by a strong
improvement in the negative net allowances for non-financial assets. It was helped to a lesser extent by improvement (of
over PLN 0.1 billion year on year) in still prevailing losses on modifications (which had been largely understated in 2024
due to banks recognising part of the cost of the mortgage loan holiday programme in this category).
The growth rate of income tax (by PLN 1.0 billion) was less than a half of the growth rate of profit before tax. This was
partly due to a one-off positive effect from the revaluation of deferred tax assets and liabilities in Q4 2025, following an
increase in corporate income tax rates applicable to banks in the coming years (as a specific category of legal entities).
Chart 9. Key lines of bank’s profit and loss account (PLN billion)
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Key lines of banks’ balance sheet
In 2025, solid economic growth and declining interest rates supported demand for bank credit across the main market
segments. According to NBP data (MONREP methodology), the volume of loans to non-bank customers amounted to PLN
1,557 billion at the end of 2025, an increase of PLN 81.3 billion, or 5.5%, compared with the end of 2024 (in 2024, the
volume of loans to non-bank customers increased by PLN 73.8 billion, or 5.3%).
Loan volumes increased across all four major customer segments, with the strongest growth recorded in loans to
non-financial corporates – up by nearly PLN 35.2 billion, or 7.1% year on year, to PLN 532.6 billion. The volume of loans to
private individuals also increased in 2025, reaching PLN 742.8 billion – up by PLN 34.7 billion, or 4.9%. Loan volumes for
central and local government institutions and for non-bank financial institutions also grew last year, by PLN 7 billion (6.2%
year on year) and PLN 4.5 billion (2.9% year on year), respectively. In both of these segments, however, loan growth was
slower than in 2024, both in nominal and percentage terms.
Chart 10. Loans to non-financial Customers (year on year change)
Source: NBP
The strong growth in loans to non-financial corporates was driven by rapidly increasing demand from non-financial
enterprises, supported by accelerating economic activity and the beginning of a new investment cycle in the corporate
sector. The volume of these loans increased in 2025 by nearly PLN 36.5 billion, or 9.0% year on year, reaching PLN 442.9
billion (compared with an increase of PLN 20.5 billion, or 5.3%, in 2024). Within this total, working capital loans grew by
7.2% in 2025, while investment loans rose by 10.1%.
Loan volumes for non-commercial institutions and individual farmers also increased last year, although only slightly in
nominal terms – by PLN 436 million (5.2%) and PLN 501 million (1.5% year on year), respectively. In contrast, the volume of
loans to sole proprietors continued to decline, falling by PLN 2.2 billion (4.5% year on year) to PLN 47.1 billion at the end of
2025.
Chart 11. Loans to retail Customers (year on year change)
Source: NBP
The volume of loans to retail customers increased in 2025 by PLN 34.7 billion, or 4.9%, reaching PLN 742.8 billion – a faster
pace than in 2024, when it grew by PLN 27.9 billion, or 4.1%. Last year’s acceleration was driven primarily by stronger
growth in consumer loan volumes, which rose by PLN 17.6 billion, or 8.4%, to PLN 226.8 billion. Demand for consumer
credit was supported by solid household income growth, declining interest rates, and a shift in the structure of household
spending – with a significant increase in the share of durable consumer goods, which are more often financed with credit
than basic goods or services. According to BIK data available through November 2025, cash loans grew particularly rapidly
– by 10.6% year on year – and their share in total consumer loan volumes approached 82%. Instalment loans increased by
only 3.6% year on year in November, while credit card debt rose by 1%.
In nominal terms, the volume of PLN-denominated mortgage loans also increased more strongly in 2025 than in 2024 – by
PLN 34.7 billion compared with PLN 33.8 billion – reaching PLN 474.1 billion. However, in percentage terms, last year’s
growth was slightly weaker than in 2024 (7.9% vs. 8.3%). Meanwhile, the volume of foreign currency mortgage loans
declined in 2025 by roughly the same amount as in 2024 – by PLN 17.7–17.8 billion – falling to PLN 40.6 billion. If this pace
of decline continues in the coming years, foreign currency mortgage loans will disappear entirely from banks’ balance
sheets by mid-2028.
-10%
-5%
0%
5%
10%
15%
20%
I II III IV I II III IV I II III IV I II III IV I II III IV
2021 2022 2023 2024 2025
Individual clients Non-financial business entities
-40%
-30%
-20%
-10%
0%
10%
20%
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2021 2022 2023 2024 2025
Consumer loans PLN mortgage FX mortgage
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Chart 12. Deposits of non-financial Customers (year on year change)
Source: NBP
The volume of deposits from non-bank customers amounted to PLN 2,435 billion at the end of 2025 and increased by
nearly PLN 211 billion, or 9.5%, compared with the end of 2024. Although in percentage terms deposits grew more slowly
than in 2024 (10.0%), in nominal terms the increase was larger (in 2024, deposits from non-bank customers rose by just
under PLN 202 billion). The persistently higher growth of deposit volumes compared with loan volumes in recent years
reflects the rising net borrowing needs of central government institutions and the increase in net foreign assets (capital
inflows from abroad, including EU funds).
Last year’s increase in deposits from non-bank customers was driven primarily by two segments: private individuals (up by
nearly PLN 103 billion, or 8.5% year on year) and non-financial corporates (up by more than PLN 83 billion, or 12.0% year
on year). Within the latter, the strongest contribution came from deposits of non-financial enterprises, whose volume rose
by PLN 75.5 billion, or 14.4% year on year.
Deposits of central and local government institutions increased in 2025 by nearly PLN 22 billion (8.8% year on year), while
deposits of non-bank financial institutions grew by PLN 3.2 billion (4.3% year on year).
The strongest driver of last year’s growth in household deposits was current accounts, whose volume increased by nearly
PLN 86 billion, or 10.6% year on year. Term deposits grew by just under PLN 17 billion, or 4.2% year on year. The monetary
policy easing cycle that began in May 2025, and the resulting decline in term deposit rates, reduced the attractiveness of
term deposits. Their share in total household deposits fell to 31.5% at the end of 2025, compared with 32.8% at the end of
2024.
Chart 13. Deposits of retail Customers (year on year change)
Source: NBP
Stock market and investments
In 2025, the WIG index covering all companies listed on the Warsaw Stock Exchange (WSE) reached its highest level in
history in December. After declines in H2 2024, the first three months of 2025 brought an increase of more than 20% in
performance. In April, the market experienced a V-shaped correction of over 15% from end-March levels. However, still in
April, the WIG rebounded to levels higher than those recorded before the correction. The following months saw a steady
upward trend, interrupted only by short periods of pullback, none of which exceeded 8–9%. Ultimately, the WIG index
gained more than 47% over the year, ending 2025 at historic highs around 117,000 points. Across the twelve months of
2025, returns varied across company segments, although the dispersion was smaller than in previous periods. Between 30
December 2024 and 30 December 2025, all four major WSE indices recorded strong positive returns. The best performers
were the WIG (broad market) and WIG20 (largest companies), each gaining more than 45%. The weakest performer was the
sWIG80 (smallest companies), which nevertheless rose by 25.4%.
The performance of the WSE indices was broadly aligned with global equity markets, although ultimately the former fared
better. For example, the U.S. S&P 500 delivered a 16.4% return in 2025, while Germany’s DAX gained 23.0%. Among major
European benchmarks, France’s CAC40 performed relatively weaker, gaining 10.4% over the same period.
-5%
5%
15%
25%
35%
I II III IV I II III IV I II III IV I II III IV I II III IV
2021 2022 2023 2024 2025
Individual clients Non-financial business entities
-50%
-20%
10%
40%
70%
100%
I II III IV I II III IV I II III IV I II III IV I II III IV
2021 2022 2023 2024 2025
Current deposits Term deposits
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Table 3. WSE main index performance
Index
31.12.2025
31.12.2024
31.12.2023
change
2025 vs. 2024
change
2024 vs. 2023
WIG
117,240
79,577
78,460
47.3%
1.4%
WIG20
3,184
2,192
2,343
45.3%
(6.4%)
mWIG40
8,182
6,122
5,785
33.6%
5.8%
sWIG80
29,590
23,595
22,904
25.4%
3.0%
Source: Bloomberg
Several factors drove the performance of the Warsaw Stock Exchange in 2025, including:
• persisting geopolitical risks in the region due to the ongoing war in Ukraine and uncertainty regarding potential scenarios
for its conclusion;
• macroeconomic data that remained slightly weaker than expected, including PMI leading indicators, which led to
downward revisions of GDP growth forecasts; on the other hand, expectations grew regarding the disbursement of EU
funds, including those from the National Recovery Plan;
• market expectations regarding the interest-rate paths of the Fed and the ECB, amid differing inflation conditions and
macroeconomic data across regions;
• expectations concerning the monetary policy stance of the Monetary Policy Council (RPP) and comments made by its
members;
• capital inflows into the domestic equity market, supported by lower risk aversion, depreciation of the U.S. dollar, and
rotation of funds from the United States to other regions in response to U.S. trade policy, as well as announcements of
large investment programmes in Europe (infrastructure, defence);
• capital inflows into the bond market, supported by improving performance of fixed-income funds and expectations of
interest rate cuts by the RPP;
• low valuations of domestic companies relative to emerging and developed markets, combined with a strong improvement
in corporate earnings and increased investor interest following the successful IPOs of Diagnostyka and Arlen;
• uncertainty surrounding the outcome of Poland’s presidential election and concerns about a potential political deadlock
between the president and the government.
The year 2025 brought a downward trend in Polish government bond yields, with the largest declines occurring in the first
months of the year. Ultimately, yields on 10-year Polish government bonds ended 2025 at around 5.15%, compared with
approximately 5.90% at the beginning of January. Volatility, however, was substantial. In just the first days of April, yields
fell from around 5.75% to 5.20%. This was driven partly by capital inflows into Europe amid uncertainty surrounding U.S.
trade policy and the dovish stance of the European Central Bank. At the same time, this coincided with a significant shift in
the RPP’s tone, from hawkish to dovish, regarding future interest rate cuts. After reaching 5.15% in April, yields on 10-year
Polish government bonds rose again over the next two months toward 5.65%. This reflected global factors – notably the
postponement of expected Fed rate cuts – and domestic factors, including a reassessment of how much monetary easing
the RPP might deliver in 2025 and concerns about the scale of future budget deficits. In the second half of the year, yields
gradually returned toward 5.15%, supported by subsequent interest rate cuts by the RPP. At the end of the reporting period,
the reference rate stood at 4.00%.
Table 4. Number of companies, market capitalisation and turnover on WSE
31.12.2025
31.12.2024
31.12.2023
change
2025 vs. 2024
change
2024 vs. 2023
Number of companies
399
411
413
(2.9%)
(0.5%)
Capitalisation of domestic companies
(PLN million)
1,122,897
731,906
760,213
53.4%
(3.7%)
Equity turnover value (PLN million)
491,899
344,757
282,061
42.7%
22.2%
Futures turnover volume
(thousand)
12,214
13,367
14,418
(8.6%)
(7.3%)
Source: WSE
In 2025, three companies were newly listed on the WSE Main Market, including one transferred from the NewConnect
market, while 15 companies were delisted. On the NewConnect organised market, seven issuers were newly listed over the
12-month period, while ten were delisted. On the Catalyst bond market, a total of 847 bond series were listed, and the
value of outstanding issues exceeded PLN 1,717 billion.
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26
Strategy
and outlook
27 GObeyond 2022-2025
30 Accelerate 2030
32 Outlook
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27
GObeyond 2022-2025 business strategy
The main objective of the GObeyond Strategy for 2022–2025, adopted by the Bank’s Management Board and Supervisory
Board in March 2022, was the dynamic development of the Bank as an efficient institution with engaged employees and
satisfied Customers, while simultaneously positioning itself as a leader in the area of sustainable development. After
several years of multi-stage scale-building through acquisitions, the GObeyond Strategy focused on organic growth, while
maintaining a responsible approach to risk management.
The key targets of the GObeyond Strategy through 2025 included:
The strategic directions set out in the GObeyond Strategy were built on solid foundations and on the Bank’s sustainable and
diversified business model. The Strategy was developed internally by a broad group of employees representing all key areas
of the Bank, as well as representatives of its subsidiaries.
Pillars of the GObeyond Strategy
Pillar UP
The GObeyond Strategy was a growth strategy aimed at increasing the number of Customers served, strengthening market
position, and growing revenues.
Retail Banking and Personal Finance
Achieving high Customer satisfaction, enabling the Bank to increase the number of Customers (by 0.5 million to 4.5 million)
through innovative products (including those beyond traditional banking), personalised communication, and broad access
to the Bank’s offering through remote channels.
SME, Corporate and CIB Banking
Strengthening the Bank’s position among international Customers and large domestic corporates (including supporting
their international expansion). The goal was to increase the base of active Customers served through digital solutions. A key
objective was the deep optimisation and shortening of the credit decision process.
Pillar POSITIVE
The Bank aims to be a leader in sustainable finance by expanding its product and service offering across all business lines.
It consistently pursues its own climate neutrality and supports its Customers in doing the same. Relationships with
Customers are guided by responsibility, accessibility, transparency and ethics. Actions addressed to local communities, as
well as engagement in education and public debate, contribute to strengthening the Bank’s brand
Pillar STRONGER
The Bank places strong emphasis on improving internal processes, transforming the IT area using state-of-the-art
technologies, and accelerating the implementation of new solutions. Planned investments in this area were set at PLN 1.5
billion by 2025. Fast and efficient scalability was intended to form the foundation of a modern digital Bank. Key goals
included: supporting business development through advanced analytical tools; maintaining a safe and optimal capital and
liquidity position; and initiating dividend payments during the strategy period.
Pillar TOGETHER
The Bank believes that engaged and satisfied employees are the foundation of high Customer satisfaction. The
organisational culture – supporting employee development, activity and creativity – encourages bold decision-making. In
2022, the Bank began operating under the Agile@Scale model. Key initiatives included ensuring work-life balance,
supporting mental health, promoting the development of women, and fostering diversity.
Implementation of the strategy in 2025
According to NBP data, the assets of the banking sector increased by 9.6% year on year at the end of 2025 (to PLN 3,634
billion), accompanied by a 13.0% rise in equity (to PLN 322 billion) and an 8.3% year on year increase in deposits from the
non-financial sector (to PLN 2,104 billion). At the same time, the volume of loans to the non-financial sector on banks’
balance sheets grew by 6.1% year on year (to PLN 1,267 billion). On the one hand, the sector continues to operate with
record-high excess liquidity (approaching 60%), due to conditions and policy actions during and after the pandemic, as well
as high exposure to public debt and a relatively low degree to which the economy is financed by the Polish banking sector
compared with GDP, especially in relation to EU peers. On the other hand, this represents a solid potential for financing
business growth in the coming periods.
Despite the continuation of the monetary policy easing cycle, the relatively elevated level of interest rates – combined with
ongoing optimisation efforts within financial institutions – enabled the sector to generate a record net profit in 2025 (PLN
48.7 billion, +21.5% year on year, according to NBP data). The sector continued to face negative pressures from legal and
regulatory burdens, such as the tax on certain financial institutions, the cost of provisions related to CHF mortgage loans,
rising labour costs, and higher contributions to guarantee funds. Nevertheless, the sector delivered a double-digit return on
equity, which confirms the effectiveness of its sustained focus on improving operational efficiency.
• Return on equity (ROE): ~12%
• Cost/income ratio: max. 48%
• Share of sustainable financing: 10%
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Despite the decline in NBP interest rates (a total of 175 basis points in 2025), the sector recorded a 3.4% year-on-year
increase in net interest income. According to forecasts and macroeconomic commentary, the cycle of interest rate cuts is
expected to continue in the current year.
In 2025, the market operated under exceptional macroeconomic uncertainty related to global trade conditions and
geopolitical developments. Economic sentiment in Western Europe showed only limited improvement – though solid
compared with 2024 – while domestic producers and exporters were burdened by stagnation in the German economy.
Domestic demand, including internal consumption, had a positive impact, supported by the stable financial situation of
households and favourable prospects for the coming periods. The registered unemployment rate stood at 5.7% as at 31
December 2025, and the average gross wage in the enterprise sector increased by 8.0% year on year in 2025, with average
CPI inflation at 3.6% year on year (GUS data). This had a direct impact on the development of lending in 2025 – there was a
strong increase in the sale of cash loans (+26.6% year on year according to BIK) and mortgage loans (+20.9% year on year).
At the same time, a noticeable rise can be seen in the share of refinancing of fixed-rate mortgage loans within new loan
production.
While preserving its universal business profile in 2025, the Group focused particularly on strengthening relationships with
affluent and private banking Customers, as well as with large corporates in the corporate banking segment. There was also
a further increase in mortgage loan sales while maintaining a selective approach to acquisition (the 35%
Debt-Service-to-Income ratio remained in force).
As a result, the Bank’s activity was recognised in the market with numerous awards, including third place in the “Affluent
Client Ranking” and fourth place in the “Business-Friendly Bank” ranking by Forbes, as well as the title of Best Private Bank
– Eastern Europe in the Global Private Banking Innovation Awards. The value of the offering dedicated to higher-end
Customer segments was further confirmed by recent rankings of accounts and credit cards (including Moje Konto Premium
which took first place in the September edition of Bankier.pl’s “Best Premium Accounts” ranking). Within the Konto Otwarte
na Ciebie portfolio, Customers could still choose from the account with the Karta dla Wpływowych and the Film Card, now
complemented by a refreshed Tennis card and the Pupil (my Pet) card designed for animal lovers. The Bank also
introduced a new service – GOdreams, offering flexible saving plans and the account Konto Pełne Marzeń. As the first bank
in Europe, the Bank launched a prestigious biodegradable Mastercard Business World Elite card for business Customers,
offering exclusive benefits and functionalities.
The Bank continues to introduce and expand value-added services. The mamGO car financing platform (awarded in the
Financial Product of the Year category in Gazeta.pl’s “The Best of Moto 2025” competition) was also made available in a
physical format at the Bank’s branches. Moreover, as the first financial institution in Poland, the Bank – as part of a pilot
project in cooperation with InPost – installed InPost Parcel Lockers in selected Customer Centres.
In the Corporate Banking area, the transformation of the service model continued with the implementation of a lean
operating model in SME and Corporate Banking, as well as the simplification of the sales network structure. As part of
expanding its offering for companies, the Bank introduced the Green Investment Loan, available to both existing and new
Customers in the micro-enterprise segment. For SME Customers, new product packages (Classic, Comfort and Premium)
were launched, reflecting a modern approach to Cash Management. E-commerce companies, which since late 2024 have
been able to integrate their business on the Shoper platform with the Axepta BNP Paribas payment gateway, received a
new functionality – as part of the continued development of the Bank’s cooperation with Shoper, merchants can now
enable instalment payments. The Bank also entered into a strategic partnership with Ryanair, Europe’s leading airline, to
support payment processing in the Polish market. Thanks to the Axepta BNP Paribas payment gateway, Polish Ryanair
passengers can pay for flights and all additional services included in their original booking in PLN using BLIK. Based on an
agreement signed this year with the European Investment Fund (EIF), the Bank introduced a new financing solution for SME
and Small MidCap companies – the InvestEU-backed loan, designed to support investments in modern technologies. In
appreciation of the quality of its services and its commitment to developing the Polish SME sector, the Bank received the
Global Finance’s Best SME Bank Award. The Bank also continued to strengthen its relationships with the innovative
business ecosystem. In 2025, the Bank became a partner in the Startup Booster by Huge Thing acceleration programme
under the Industry Test track, which enables new technology companies to test their solutions in cooperation with large
organisations.
The Bank continues to automate and implement modern technologies that enhance efficiency and process integrity across
the organisation. A key process improvement supporting business activity was the introduction of a decision engine into the
SME credit process across all SME Customer Centres. During the reporting period, the Bank also launched the One Click
cloud platform, which accelerates and simplifies database space management, as well as the Autenti mass qualified
signature service, enabling users to sign dozens of documents in a single session.
The Bank continued its research and development of artificial intelligence-based solutions, including the organisation-wide
Knowledge Chatbot “GENiusz”, a GenAI-based tool enriched with content in the areas of HR, ESG, Customer Care, Digital
Accessibility and Operations. The Bank also supports the SME sector’s digital transition by joining the Polish Development
Fund’s “Cyfrowa Wyprawka” initiative
The volume of sustainable financing reached PLN 13.6 billion at the end of 2025. In addition to further syndicated
transactions, including Sustainability-Linked Loans, the Bank strengthened its capacity to provide loans for energy
efficiency and renewable energy investments up to a total of EUR 100 million as a result of uncapped portfolio guarantees
received from the EBRD; the agreement represents the EBRD’s first financial sector transaction in Poland under the EU
InvestEU programme. The Bank also signed an agreement with the Polish Academy of Sciences to jointly promote
regenerative agriculture and support the transformation of the agricultural sector, in line with its Food & Agro transition
agenda. Companies cooperating with the Bank gained access to new ESG management tools: Corporate Customers
participating in the EU ETS can buy and sell CO₂ emission allowances through the Bank, while SME Customers were given
access to the Envirly platform for carbon footprint calculation and emissions management. In the area of social inclusion,
41.5% of the Bank’s Customer Centres now operate with the “Barrier-Free Facility” certificate, confirming accessibility for
people with reduced mobility. The Bank’s commitment to sustainable transition and to socially and environmentally
significant goals was once again recognised with numerous awards, including being named the leader in the ESG Stars
category in the “Banking Stars” ranking by Dziennik Gazeta Prawna and Boston Consulting Group.
A fundamental principle of the GObeyond Strategy under the Together pillar is “People First: we put people at the centre.”
In 2025, the Bank continued to support development programmes and carried out initiatives aimed at improving employee
well-being, including further editions of #University – offering training in new technologies, programming, agile project
management and the use of AI – as well as initiatives such as “Two Hours for Health” and Parenting Days. A key
organisational priority remains to unlock employee potential through fostering team diversity and adapting to the needs of
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29
people with disabilities and neurodivergent individuals. The Bank’s engagement and positive outcomes in these areas were
confirmed by receiving the “Neurodiversity-Friendly Workplace” certificate from the asperIT Foundation and distinctions
such as the “Ethical Company” title awarded by Puls Biznesu. In line with ongoing organisational and work model
transformation, the Bank also implemented a new Beyond Agile management style in the Retail and Business Banking
network and in Personal Finance, combining Agile practices with team self-organisation.
In April 2025, the Annual General Meeting of BNP Paribas Bank Polska S.A. adopted a resolution on the payment of a
dividend for 2024, which was distributed on 9 May 2025, thereby fulfilling one of the strategic objectives set out in the
GObeyond Strategy for 2022–2025.
Achievement of strategic financial targets in 2025
Indicator
Strategic target 2025
Implementation 31.12.2025
Return on equity (ROE)
~12%
18.7%
Cost/income ratio (C/I)
max 48%
41.2%
Share of sustainable financing
10%
14.6%
Actions under the strategy in 2025
PILLAR
KEY ACHIEVEMENTS 2025
#UP
High-quality banking and non-bank
products and services are the key to
expanding the Customer base in an
omnichannel environment, with the Bank
focused on creating an excellent Customer
experience through the design of
personalised Customer journeys.
• New products and services:
Pupil (My Pet) Card – a themed card for animal lovers, along with a
refreshed edition of the special offer for tennis fans: the Visa Tennis Card
GOdreams – a service offering flexible saving plans together with the
account Konto Pełne Marzeń, combining savings tools with support for
Customers in achieving their financial goals
Green Investment Loan – available to new and existing Customers in the
micro-enterprise segment
product packages for SMEs (Classic, Comfort and Premium)
InvestEU-backed loan – a new market solution for SME and Small MidCap
companies to finance modern technologies, research and development
expanded cooperation with Shoper – enabling merchants to offer
instalment payments through the Bank
mamGO car financing service available in Bank branches, with display
vehicles in 20 selected locations
PILLAR
KEY ACHIEVEMENTS 2025
biodegradable Mastercard Business World Elite card for business
Customers, offering exclusive benefits and functionalities (the first such
card introduced by a bank in Europe)
• Modern solutions:
Kantox Dynamic Hedging® – innovative and unique solution on the Polish
market for Corporate Banking Customers conducting cross-border
operations, enabling effective currency management and foreign-exchange
risk mitigation
GOwadia Plus – an application integrated with GOonline Biznes for
handling tender settlement processes
Development of the GO Biznes ecosystem – a new version of the
application featuring an additional module for managing debit,
multi-currency, charge and credit cards
• New partnerships:
pilot launch of a new value-added service in Customer Centres – InPost
Parcel Lockers installed in 24/7 accessible zones
cooperation with Ryanair – payment processing enabled through the
Axepta BNP Paribas payment gateway, allowing passengers to pay using
BLIK
financial cooperation with the retail chains RTV Euro AGD and Media
Expert
partnerships with AFG Electric Motors (a Chinese automotive company
responsible for vehicle distribution and sales) and Astara (the distributor of
the Nissan brand)
#POSITIVE
A responsible and trusted financial partner
supporting the positive and sustainable
development of Customers, businesses and
society, and a guide for Customers in the
world of digital and sustainable transition.
• PLN 13.6 billion in sustainable financing at the end of 2025 (based on Bank’s
internal classification, see chapter Pillar Positive)
• guarantee agreement with the European Bank for Reconstruction and
Development, enabling the Bank to provide loans totalling EUR 100 million for
pro-environmental investments by retail Customers (the first EBRD financial
sector transaction in Poland carried out under the EU InvestEU programme)
• Sustainability-linked financing – selected transactions:
Green Loan – Polish Logistics (UK) LLP (EUR 31 million), Accolade (EUR
33.5 million)
Sustainability-Linked Loan – for the Woodeco Group (PLN 155 million) and
the Iglotex Group (PLN 84.9 million, with BNP Paribas holding a 50% share)
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30
PILLAR
KEY ACHIEVEMENTS 2025
ESG-Linked Factoring – cooperation on the agreement concluded by BNP
Paribas Faktoring with Raben Logistics Polska (PLN 140 million)
• Expansion of the beyond banking offering – cooperation with EcoVadis, Envirly
and Klim
• CO₂ emission allowance transactions under the EU ETS for Corporate
Customers
• 144 Customer Centres certified as “Barrier-Free Facility”
#STRONGER
The global strength of the BNP Paribas
Group, combined with dynamic
technological development and end-to-end
process optimisation, forms the foundation
for organic growth and high Customer
satisfaction.
• Automation and modern technologies enhancing the Bank’s operational
efficiency:
implementation of the One Click cloud computing solution for database
space management
launch of the mass qualified signature service on the Autenti platform
expansion of GENiusz, the Bank’s GenAI-based knowledge tool, to include
new areas: HR, ESG, Customer Care, Digital Accessibility and Operations
continued development of GenAI solutions within the IT area
• Partner of the Startup Booster by Huge Thing acceleration programme,
enabling start-ups to test and develop breakthrough solutions using partner
infrastructure
• First market implementation of e-receipts, available in Planet Cash ATMs and
cash-deposit machines located in Customer Centres
• “Cyfrowa Wyprawka” – joining the Polish Development Fund initiative
supporting the SME sector in digital transition
• 250 active robots supporting processes in Customer operations, risk and
compliance, HR and internal services (35 new deployments in 2025)
• 50% of the Bank’s 2024 net profit allocated to dividend distribution, DPS: PLN
7.86
#TOGETHER
People First: we put people at the centre. An
engaged and satisfied employee is the
foundation of high Customer satisfaction.
Agile@Scale and a new organisational
culture form the basis for a diverse and
inclusive work environment built on trust,
courage and creativity.
• Implementation of the Beyond Agile work model in the Retail and Business Banking
network and in Personal Finance, combining Agile practices with team
self-organisation
• 26.6 thousand hours of employee volunteering in 2025 (Capital Group)
• Support for children and young people in financial and cybersecurity education
through the new edition of the Mission Education programme
• Employee well-being initiatives: “Two Hours for Health” campaign and Parenting
Days
• Strategic partnership with the Szlachetna Paczka initiative (for the eighth time)
PILLAR
KEY ACHIEVEMENTS 2025
• Top Employer Poland 2025 title and the “Neurodiversity-Friendly Workplace”
certificate awarded by the asperIT Foundation
• Inclusion for the fifth consecutive year in the Diversity IN Check list, recognising
employers most advanced in DEI practices
Accelerate 2030 business strategy
On 10 December 2025, the Bank’s Supervisory Board approved the BNP Paribas Bank Polska S.A. Group Strategy for 2026–
2030, “Accelerate 2030”. In the new Strategy, the Bank focuses on profitable, dynamic growth and improving operational
efficiency. At the same time, as a trusted financial partner, it responds to local needs while opening global opportunities.
The Group’s key ambitions for the next five years include significantly increasing the scale of operations (expanding the
number of Customers served and strengthening its share in the loan and deposit market) while maintaining a prudent
approach to risk and a strong focus on profitability, as well as enhancing the way it operates through further digitalisation
and strict cost discipline.
The new Strategy defines the following key ambitions by the end of 2030:
1. compound annual growth rate
2. Return on Tangible Equity (ROTE) – calculated as net profit or loss divided by the average level of tangible equity, defined as total equity minus the planned dividend from the current year’s result,
intangible assets and AT1 instruments.
• net loans: +7% (CAGR
1
2024-2030)
• income: +6% (CAGR
1
2024-2030)
• cost/income ratio (C/I), net of bank tax: <38%
• ROTE
2
: 22%
• dividend payment ratio: 75% in 2030
• +1 million retail Customers
• 10% market share in corporate loans
• PLN 25 billion new sales of sustainable loans
•
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Pillars of the Accelerate 2030 Strategy
Pillar EXPAND
Significant expansion of the Customer base, particularly in everyday banking, volumes and cross-selling. Enhancing the
Customer experience as the foundation of all our activities.
Pillar STREAMLINE
Improving efficiency through the use of new technologies while continuing the achievements to date in reducing service
costs.
Pillar IMPACT
Focusing on playing a leading role in the sustainable transition of our Customers and accelerating positive change at the
national level.
The new Strategy addresses the challenges and opportunities facing the banking sector across all areas of the Bank’s
operations. It sets out the following priorities:
• achieving a market share of over 5% in current accounts and increasing the retail Customer base by 1 million net
Customers, through:
a significant enhancement of the value proposition and brand recognition in the highest-potential segments,
particularly Generation Z (ages 18–30) and families,
strengthening Customer relationships and improving profitability through deposits and cross-selling,
developing activities in the leading segments of Private Banking and Affluent Customers;
• strengthening the Bank’s leadership position in Corporate Banking and reaching 10% market share in corporate lending,
leveraging the BNP Paribas corporate DNA through:
further development of the multinational Customer (MNC) segment,
unlocking the full potential of Polish corporate Customers by utilising BNP Paribas Group solutions,
maintaining stable and efficient operations in the SME segment;
• improving efficiency through targeted investments:
in Retail Banking: a mobile-first distribution model with an optimised role for the branch network,
in Corporate and SME Banking: operational excellence to deliver the best Customer service model,
increasing efficiency through the use of AI,
ensuring uninterrupted service availability and secure, scalable foundations of key technological infrastructure to
support the Bank’s objectives,
optimising the jaws ratio (the difference between annual revenue and cost growth) and achieving net cost savings
while continuing to invest;
• strengthening the Bank’s leadership in sustainable finance by:
financing, at scale, a broad range of decarbonisation investments,
supporting and financing the transformation of agriculture and all related sectors of the economy.
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32
Outlook
The key external factors that, in the Bank’s assessment, may affect the Group’s results in the coming periods include:
• Geopolitical and international factors. In the coming months, the macroeconomic and market environment may be
influenced by persistent geopolitical tensions and shifts in international relations among key global economic players.
The situation in the Middle East, including relations between the United States and Iran, remains a source of elevated
uncertainty, particularly in the context of commodity market stability and global energy prices, which may translate into
inflationary pressures. At the same time, discussions concerning security, access to strategic raw materials, and the
growing importance of Arctic regions, including Greenland, may, over the longer term, affect resource policies and trade
relations between the United States and Europe. Additionally, relations between the United States, Denmark, and
Greenland continue to impact the political and economic stability of the region as well as global energy markets. Taken
together, these factors may lead to heightened uncertainty, shifts in capital flows, and a more cautious approach to risk,
indirectly affecting banking sector operating conditions, customer activity, and funding costs.
• War in Ukraine. At the outset, the war in Ukraine had a strong impact on the Polish economy, primarily through higher
energy prices, disruptions in trade, and a large inflow of refugees. At present, the direct effects of the war appear to have
been largely mitigated. Energy prices, although still higher than before the war, remain stable, and Polish industry and
labour market have largely adapted to the new operating environment. The war continues to influence fiscal policy. As in
the previous year, defence spending in 2026 is expected to remain close to 5% of GDP.
• Global economic conditions. According to the January edition of the IMF’s World Economic Outlook, global GDP growth is
projected at 3.3% in 2026 and 3.2% in 2027, slightly higher than in the October forecast. The latest IMF report anticipates
a modest acceleration of growth in the United States, from 2.1% in 2025 to 2.4% in 2026, and a slight slowdown in the
euro area, where real GDP growth is expected to ease from 1.4% in 2025 to 1.3% this year. At the same time, the IMF
expects inflation to move closer to central bank targets. Price dynamics are projected to return to desired levels earlier in
advanced economies than in emerging and developing economies. For Poland, the IMF forecasts GDP growth of 3.5% in
2026, followed by a slowdown to 2.7% year on year in the subsequent year. Meanwhile, average annual inflation is
expected to decline to 2.8%, compared with 3.7% recorded in 2025.
• Monetary policy of major central banks. In addition to geopolitical developments, the key factor influencing the pace of
global recovery is the policy stance of the world’s most important central banks. In June 2025, the European Central Bank
(ECB) paused its monetary-easing cycle, and the accompanying communication suggested that, after rate cuts totalling
200 basis points, the easing cycle in the euro area is nearing its end. In the United States, the Federal Open Market
Committee (FOMC) implemented three interest rate cuts in 2025, totalling 75 basis points, lowering the federal funds
target range to 3.50–3.75% in response to weaker labour market data. Market forecasts for 2026 point to a slower pace of
easing, with expectations centred on one or two rate cuts this year. Changes in U.S. trade policy under President Donald
Trump have significantly increased uncertainty regarding the pace of economic growth and inflation in the United States.
FOMC members are currently divided on the future course of monetary easing. At the most recent meeting, three officials
voted against a rate cut, while two preferred to keep rates unchanged altogether.
• Actions of the National Bank of Poland. In December 2025, the Monetary Policy Council (RPP) decided on another
adjustment of the reference rate, cutting it by 25 basis points to 4.00%. In total, the RPP cut interest rates six times in
2025, by a cumulative 175 basis points. We also believe that the monetary policy easing cycle that began last year in
Poland has not yet come to an end. This was explicitly confirmed by NBP Governor Adam Glapiński during his January
press conference, where he stated that the Council currently maintains a dovish stance and that there is still room for
further interest rate cuts in Poland. The outlook for inflation – which, according to the central bank governor, has
declined in a lasting manner – supports continued monetary easing. In this context, we expect the reference rate to be
lowered to at least 3.50% this year, although we see a material risk of a deeper adjustment (by 25–50 basis points) in the
coming months. At present, the market is pricing in a decline of the main policy rate to 3.25% this year.
• Behaviour of the zloty against key currencies. In the second half of 2025, external shocks (including further
announcements on tariff changes) and domestic shocks (such as the presidential election) eased noticeably. As a result,
the zloty stabilised against major currencies in the later part of the year. In Q3 2025, the EUR/PLN exchange rate moved
within a narrow range of 4.24–4.29, and in Q4, it strengthened to 4.21. Solid data from the Polish economy supported the
appreciation of the domestic currency toward year-end. Given the favourable economic growth outlook and the monetary
easing cycle approaching its end, we expect the EUR/PLN exchange rate to remain stable, fluctuating around 4.20. The
main upside risk to this forecast stems from geopolitical factors that could influence capital flows into emerging markets.
• Economic activity in Poland. In 2025, Poland’s Gross Domestic Product increased by 3.6% according to preliminary data.
The main driver of economic activity was domestic demand, which grew by 4.0%, including a 3.7% increase in household
consumption expenditure and a 4.2% rise in gross fixed capital formation. As a result, the contribution of foreign trade to
GDP remained negative, although export data indicate some revival in foreign trade sales. Estimates published by
Statistics Poland (GUS) show that in the fourth quarter of 2025 alone GDP increased by 4.0% year on year in unadjusted
terms (and by 1.0% quarter on quarter and 3.6% year on year after seasonal adjustment). This year, we forecast a slight
acceleration in economic growth, to 3.7%, compared with 3.5% in the previous year. We expect that, in the short term
during 2026, GDP growth may temporarily exceed 4%, supported in part by inflows of EU funds (including the National
Recovery Plan). For 2026, we anticipate a historically unprecedented inflow of EU investment funds to Poland, potentially
amounting to around EUR 40 billion. A particularly strong impulse for investment should come from National Recovery
Plan funds, especially grants. Under the grant component of the National Recovery Plan, Poland is expected to receive a
total of approximately PLN 108 billion, which implies that transfers in the current year could reach nearly PLN 70 billion.
Polish producers should also benefit from an anticipated improvement in economic conditions in Western Europe. Despite
slowing nominal income growth (due to more moderate wage increases), household consumption is expected to
strengthen as inflation and debt servicing costs decline, continuing the trend observed last year. All these factors point to
rising demand for credit in the new year, both from households and businesses.
• Inflation trajectory. In Q4 2025, CPI inflation in Poland continued to slow down. Between October and December, price
growth reached 2.6%, compared with 3.0% in July–September. Net of food and energy prices, core inflation stood at 2.8%
year on year, i.e., 0.4 percentage points lower than in Q3 2025 (3.2% year on year). In the coming months, core inflation
will continue to gradually ease, supported by solid but not overly rapid GDP growth and a slowdown in wage dynamics.
Labour costs are expected to rise at a slower pace, as indicated, among others, by business surveys. Energy prices will
also play an important role in shaping CPI in 2026. A decision by the Energy Regulatory Office will reduce household gas
tariffs starting in July. In addition, developments in commodity markets, particularly crude oil, as well as the USD/PLN
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33
exchange rate have significantly eased import price pressures. As a result, we expect limited upward pressure on goods
prices. We forecast that CPI inflation this year will average 2.1% year on year, remaining slightly below the National Bank
of Poland’s inflation target of 2.5% for much of the year.
• Imbalance in public finances. According to Statistics Poland (GUS), Poland’s general government deficit in 2024 increased
to around 6.5% of GDP, compared with 5.3% of GDP in 2023. The Ministry of Finance estimates that in 2025 the general
government sector deficit will amount to approximately 7% of GDP. The widening deficit relative to previous years is
driven, among other factors, by higher defence spending, increased social benefit expenditures, and wage increases in the
public sector. Poland is currently subject to the Excessive Deficit Procedure (EDP) imposed by EU institutions, which
obliges the government to reduce the budget gap to 3% of GDP by 2028. According to the European Commission,
persistently high fiscal deficits combined with slower nominal GDP growth will push the public-debt-to-GDP ratio higher
in the coming years from 55.3% in 2024 to 69.2% in 2027. The rising debt ratio will serve as an additional argument for
maintaining fiscal discipline in the years ahead.
• Sentiment in major financial markets. In the near term, sentiment across global financial markets will remain sensitive to
expectations regarding monetary policy in the world’s largest economies, particularly the United States and the euro
area, as well as to incoming macroeconomic data shaping assessments of economic growth momentum and inflation.
Another important factor will be the volatility in equity, bond and currency markets, driven by asset valuations, the cost
of capital, and investors’ willingness to take on risk. In addition, persistent geopolitical tensions and uncertainty
surrounding commodity markets may influence capital flows and prompt more cautious behaviour among market
participants, indirectly affecting financing conditions and the activity of the banking sector.
• Loans indexed to WIBOR. The dispute over loans indexed to the WIBOR benchmark gained media attention at the end of
2022. In July 2023, the Polish Financial Supervision Authority (UKNF) published a statement emphasising that, in its
assessment, there are no grounds to question the credibility or legality of WIBOR, particularly in the context of its use in
PLN-denominated mortgage agreements. On 11 June 2025, a hearing was held before the Court of Justice of the European
Union (CJEU) regarding questions referred on whether national courts may assess loan agreement provisions referring to
WIBOR under Directive 93/13. On 11 September 2025, the CJEU Advocate General issued an opinion confirming that courts
cannot challenge the methodology for determining WIBOR, as it is governed separately by the EU Benchmarks Regulation
(BMR), and that banks fulfilled their required disclosure obligations. On 12 February 2026, the CJEU announced its
judgment in the case, confirming the preceding opinion. For the first time in history, the WIBOR benchmark – the key
reference rate for PLN-denominated variable-rate loans – was removed from a loan agreement by a court in Suwałki on 4
October 2024 (non-final judgment). According to experts, including the Polish Bank Association (ZBP), this judgment does
not pose a risk to the established line of case law. In all cases concluded with final judgments to date, the rulings have
been favourable to banks.
• Draft of the new “Swiss-franc loan” act. On 30 January 2025, the Ministry of Justice published a draft Act on special
solutions for handling cases concerning loan agreements denominated or indexed to CHF concluded with consumers.
Following comments raised in the public consultation and the CJEU judgment of 19 June 2025 in case C-396/24
(Lubreczlik), a new draft Act was published dated 30 June 2025. The goal of the draft law is to accelerate court
proceedings concerning loan agreements denominated or indexed to CHF. The key mechanisms set out in the draft
include:
protection of consumer interests (Article 3 of the draft) – once an action lodged by a consumer is served on the
defendant or once a counterclaim lodged by the consumer is served on the defendant, the obligation of the consumer
to perform the benefits arising from the loan agreement is suspended by law until the proceedings are closed with a
final judgment;
plea of offset (Articles 5 and 18 of the draft) – change to the time limitation for the option of raising the plea of offset
in the proceedings (until the proceedings are closed in second instance);
counterclaim (Article 8 of the draft) – change to the time limitation in civil proceedings (under the general procedure,
no later than in the statement of defence) – allowing for a counterclaim to be lodged until the hearing is closed in first
instance.
The draft law was tabled to the Sejm on 2 October 2025. The Sejm held the first reading of the draft on 16 October 2025,
after which the draft was referred to the Committee for Justice and Human Rights (and the Committee for the Economy
and Development). Both Committees started to work on the draft on 17 December 2025 at a joint meeting. The work on
the draft is scheduled to continue in 2026.
• “Free credit sanction”. At its meeting on 21 March 2025, the Financial Stability Committee identified the application of
Article 45 of the Consumer Credit Act, known as the free credit sanction, as a new systemic risk in the domestic financial
system. One of the key issues related to free credit sanction is the lack of proportionality, despite the fact that the
violations listed in the Consumer Credit Act vary significantly in nature and severity. The number of court cases
concerning free credit sanction has been rising rapidly. As of the end of 2025, the number of pending cases stood at
21,600. Work is underway on a new Consumer Credit Act, scheduled to enter into force in November 2026, which is
expected to provide a clearer regulatory framework for free credit sanction.
• Digital operational resilience. According to a report by Check Point Software Technologies, the financial sector ranks as
the second most frequent target of cyberattacks in Poland. With the growing importance of digital channels in customer
interactions, banks are particularly exposed to cyber risk. This risk intensified following the outbreak of the war in Ukraine
in February 2022. In response to rising cyber threats, the European Commission’s Digital Operational Resilience Act
(DORA) entered into force in 2023. The regulation aims to mitigate systemic risk posed by providers of critical ICT services
to the financial sector. It consolidates regulatory requirements and introduces direct supervision of ICT service providers
by European financial supervisory authorities. Analyses conducted by the Polish Bank Association (ZBP) indicate that the
banking sector is well prepared for the implementation of the regulation. The obligations imposed by DORA became fully
applicable on 17 January 2025.
• Transformational pressure. According to the latest Deloitte reports, financial sector institutions will continue to face
pressure to accelerate the scaling of technologies that until now have remained in testing or pilot phases. This applies in
particular to solutions in the areas of data architecture and artificial intelligence, where investment payback periods
remain long while ambitions continue to grow. At the same time, a global trend is emerging toward the increasing role of
digital forms of money and the development of regulatory framework governing this space.
• Changes to CIT for banks. In November 2025, President Karol Nawrocki signed legislation increasing the corporate income
tax (CIT) rate for banks. The act provides for a rise in the income tax rate from 19% to 30% in 2026, 26% in 2027, and 23%
from 2028 onwards. At the same time, the act reduces the rate of tax on certain financial institutions for banks from the
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
34
current 0.0366% of the tax base to 0.0329% in 2027 and 0.0293% from 2028. According to the regulatory impact
assessment, the CIT increase is expected to generate an additional PLN 6.6 billion in budget revenues in 2026.
In 2026, both the Bank and the sector as a whole enter the year well-capitalised and well-prepared to support the Polish
economy. For the Bank, this marks the first year of implementation of the new strategy – Accelerate 2030.
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
35
Implementation
of the strategy
36 Pillar UP
37 Segment description
47 Distribution channels
49 Operations and business support area
49 Entities of BNP Paribas Bank Polska S.A. Group
52 Pillar POSITIVE
52 Sustainable financing
58 Positive banking
60 Community involvement
66 Environmental responsibility
68 Pillar STRONGER
68 Digitalisation and innovation – IT strategy
72 Support for innovation
74 Cybersecurity
75 Pillar TOGETHER
75 Good workplace
77 Remuneration
78 Diverse and inclusive workplace
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
36
Pillar UP
Pillar description
The GObeyond strategy was a growth strategy. The aim was to increase the number of Customers served, strengthen our
market position and increase revenue. The Bank saw potential for development in all Customer segments.
Retail Banking and Personal Finance
The priority of retail banking and PF was to achieve high Customer satisfaction (Top 3 NPS in the market), thanks to which
the Bank would increase the number of Customers (by 0.5 million to 4.5 million) and increase their engagement in the
relationship with the Bank. Listening to the opinions of its Customers and employees, the Bank implemented innovative
products and services, often in cooperation with internal partners (companies from the BNP Paribas Group) and external
partners, and planned to make even greater use than before of personalised communication based on advanced CRM and
data analytics. Further digitalisation of Customer processes was planned, together with remote access to the Bank’s experts
as part of a newly created omnichannel sales and Customer service model (over 90% of key processes for retail Customers
were to be available in remote channels, and sales via digital channels are expected to exceed 50%). The Bank planned to
offer Customers services that go beyond traditional banking, such as open banking solutions, contextual financing in e-
commerce, or offering products and services related to the Sustainable Development Goals. Finally, the Bank planned
active but sustainable growth in the main areas of retail banking, i.e. achieving a 7% share in the market of new sales of
accounts, cash loans, and mortgage loans.
SME, Corporate and CIB Banking
The Bank aimed to be number 1 for international Customers (increase in the number of active Customers by over 22% vs.
2021) by leveraging the position of the BNP Paribas Group as a leader in Europe with a broad global presence and global
solutions, products and expert knowledge. The Bank strived to be the first-choice bank for large corporations with tailored
solutions and an excellent service model. The Bank provided service to Customers from the Polish corporations and SME
segment using remote and digital solutions, while supporting the international expansion of our Customers based on
experiences from other countries. The Bank expected to increase the base of active Customers served in the SME and
corporate banking segment by over 18% compared to 2021 and to reach operational excellence to build positive Customer
experiences. One of the key goals in this area was to optimise and shorten the credit process. The Bank leveraged its
leading market position in the agricultural segment and its unique competences in this area to strengthen its market
position among food processors.
Strategic commitments and their implementation
Indicator
Strategic objective 2025
Implementation 2025
NPS – Retail Banking and Personal Finance
TOP 3
6
th
place
% of key processes for the retail Customer
available through remote channels
90%
87%
Number of Customers (retail Customers and micro
businesses)
4.5 million
3.7 million
Sales through digital channels (retail Customers)
>50%
65%
Market shares in new sales (ROR accounts,
cash loans, mortgages)
7%
ROR – 4.4%
cash loans – 3.3%
mortgage loans – 4.5%
Number of active micro companies
340 thousand
275 thousand
Number of micro companies active in digital channels
230 thousand
193 thousand
Maintaining leadership in the farmers’ segment
(market share in loans)
>25%
22%
NPS – SME Banking
TOP 3
8th place
Increase in the number of active food processors
[vs. 2021]
+30%
+30%
Increase in the number of active Customers
(corporate and SME banking) [vs. 2021]
>18%
+5%
Increase in the number of active international
Customers [vs. 2021]
>22%
+31%
Number of Customers active in digital channels
(corporate and SME banking)
37 thousand
31 thousand
Increase in credit volumes
(corporate and SME banking)
+6%
CAGR [2025-2021]
+5%
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
37
Segment description
Retail and Business Banking & Personal Finance Area
Characteristics of the area
The Retail and Business Banking area provides services to retail Customers, Private Banking services, and serves business
Customers (micro-businesses). The following Customer segments are served within Retail and Business Banking:
Retail Customers:
• Mass Customers,
• Premium Banking Customers, i.e., placing assets of at least PLN 100,000 in the Bank or through its intermediation, or
having the inflow of funds of at least PLN 10,000 per month,
• Private Banking (Wealth Management) Customers, i.e., placing assets of at least PLN 1 million through the Bank. A
"Family Fortunes" sub-segment is identified under Private Banking – Customers who place assets of at least PLN 10
million through the Bank.
Business Customers:
• non-Agro, not keeping full financial reporting according to the principles defined in the Accounting Act, meeting the
criterion of net annual income for the previous year below 2.5 million euros,
• non-Agro, keeping full financial reporting, whose net sales income for the previous financial year was less than PLN 4
million, and credit exposure does not exceed PLN 1.2 million,
• Agro, not conducting full financial reporting, meeting the criterion of net annual income for the previous financial year
below 2.5 million euros, conducting activities classified according to selected PKD 2025 codes,
• professionals: entrepreneurs not conducting full financial reporting in accordance with the principles of the Accounting
Act, conducting professions defined in a separate internal document,
• individual farmers, for whom the Bank’s credit commitment to the Customer is less than PLN 3 million,
• individual farmers, for whom the Bank’s credit commitment to the Customer is in the range from PLN 3 million to below
PLN 4 million, when the collateral on agricultural land covers at least 50% of the credit exposure,
• non-profit organisations (e.g., foundations, associations, trade unions, etc.),
• cooperatives, housing communities, property managers.
Private Banking – BNP Paribas Wealth Management offers an individual approach to each Customer and additional holistic
and relational approach, i.e., the "family approach", which also includes close family members or assets gathered in private
companies and other investment vehicles. BNP Paribas Wealth Management benefits from 40 years of experience in serving
affluent Customers, market position and best practices of the BNP Paribas Group, which is number 1 in Wealth
Management in the eurozone.
For over 10 years, BNP Paribas Wealth Management in Poland has been supporting Customers in matters related to wealth
planning and collaborates with Customers’ legal and tax advisers in succession planning – it is a forerunner of the family
office service on the Polish market. It offers one of the richest product and service portfolio available for Family
Foundations – including entities in organisation, i.e. yet to be registered by the court.
Customers of BNP Paribas Wealth Management are served by an experienced and qualified team - all advisers are EFPA
certified at the EFA level and the highest EFP level. Holding an EFPA certificate is crucial and required for a Wealth
Management adviser position. At the same time, Wealth Management advisers are the first in Poland to achieve EFPA ESG
certification in the area of sustainable development.
Personal Finance Banking is responsible for the product offer and management of consumer loans distributed through the
Retail and Business Banking branch network and external distribution channels. This area offers Customers the following
product groups: cash loans, credit cards, instalment loans, car loans, leases (operational and finance leases) and leasing
loans (mainly in cooperation with BNP Paribas Leasing Services Sp. z o.o.) and long-term vehicle rental (offered in
cooperation with Arval Service Lease Polska Sp. z o.o.).
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38
Implementation of key strategic initiatives in 2025
INITIATIVE
BNP Paribas - my main Bank
INITATIVE
DESCRIPTION
More attractive products, implementation of an omnichannel environment and changes in the approach
to building lasting relationships. Optimisation of digital UX, enhanced personalisation of Customer
experiences and synchronisation of data source use. Increase in BNP Paribas brand awareness among
Customers
ACHIEVEMENTS
• New services and offers made available to Customers:
• GO Dreams – a service that helps Customers manage their budgets in a more thoughtful and balanced
way. It enables simple, convenient and personalised regular saving towards personal goals and dreams.
• Pupil (My Pet) Card – an acquisition project aimed at pet lovers, offering a package of discounts and
benefits
• “Lucky Sevens – 3×7%” offer – a triple benefit for opening an account: 7% interest on the savings
account, 7% cashback on card payments, and 7% interest on the “Konto Pełne Marzeń” savings product.
• “Pay conveniently and win prizes” competition – for holders of Mastercard debit cards, offering a
chance to win a voucher for a contactless payment ring and 1% moneyback on mobile transactions for
nine months
• Launch of the new “Dobra Karta” product – featuring highly attractive pricing conditions related to card
servicing and instalment plan costs
• “Deposit for You” offer – dedicated interest rates for Customers using GOonline and GOmobile.
• option to block and unblock subscription-based card payments during a phone call or a visit to a
Customer Service Centre
• Customer Appreciation Day initiative – an action recognising Customers for their transactional activity
and charitable transfers, including the waiver of fees for instant transfers
• improvements to the remote account opening process, including enhancements to the system handling
ID document photos and video verification
• partnership with Media Expert – making the Bank’s financial offer available in 150 of the brand’s
physical stores (target: 600 stores)
• expansion of the “Cash Loan for Green Changes” offer, including new goals related to electromobility.
• optimisation of the lease agreement activation process for vehicle financing – reducing the time from
verification of leasing documentation to contract activation by 22%.
KEY FIGURES
• +16% year-on-year growth in cash loan sales
• +15% year-on-year growth in investment product sales
• +258% year-on-year growth in mortgage loan sales
INITIATIVE
Development of sales in the digital and omni-channel model
INITATIVE
DESCRIPTION
Sale of all consumer loans and mortgages through digital channels or omni-channel model. Widespread
use of pre-approved offers and open banking solutions. Increase in sales to the Customer base based on
data analytics, AI and personalisation. Expansion of product offerings available in digital channels
ACHIEVEMENTS
• improved efficiency of the mortgage process through simplification and standardisation of
documentation requirements for loan applications, partial and full repayments, and the process of
updating insurance policies in Goonline; new remote-channel processes: shortening the loan tenor
period after an overpayment and enabling tranche disbursement to developers
• launch of the cash loan application process using Open Banking for new Customers on mobile devices,
via the telephone application path and in Goonline; extension of the maximum loan tenor in electronic
channels
• introduction of the consolidation loan sales process in electronic channels
• enabling entrepreneurs to open business accounts if they already have access to the Bank’s electronic
channels
• display of debit card fee information and option to submit applications under the “Active Parent”
programme in online banking
• enhancements to foreign transfers, tax transfers and transaction history to help Customers better
identify and analyse their spending
• optimisation of the document submission process for car loans
• launch of a paperless instalment loan agreement signing process for Customers without an email
address, eliminating the need for paper contracts.
• strengthening security in electronic channels through:
the “Panic Button” feature in the GOmobile app, enabling instant blocking of online banking access,
two-step login and dual authorisation for changes to transaction limits,
enhanced behavioural security protection,
verification of files uploaded by Customers for security and electronic-signature compliance.
• GOmobile enhancements:
simple and fast activation of the Currency Exchange service, option to update ID document details
and to add BNP Visa cards to digital wallets,
access to GO Dreams, enabling simple and convenient regular saving towards personal goals,
improvements to the instalment loan agreement signing process.
KEY FIGURES
• 70.3 million BLIK transactions in 2025, +17% year-on-year
• 354 million mobile banking logins in 2025, +8% year-on-year
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
39
INITIATIVE
Growing sales in a digital and omnichannel model
INITATIVE
DESCRIPTION
Bank as a modern platform using APIs to offer products and services from external partners. Supporting
the creation of sustainable, secure and innovative services tailored to Customers’ needs. The API enables
contextual services to be offered at selected Customer touch points outside the banking ecosystem
ACHIEVEMENTS
• opening a Business Account independently by sole proprietors who already have retail Customer access
to GOonline or GOmobile, using a fully remote process
• Start TwojeGo Biznesu - an offer for Customers entering the market available from May 2024. A
programme of comprehensive support in every aspect of setting up a business, it includes, among
others, assistance in registering for VAT and ZUS, access to professional business and accounting tools
in the GOksięgowość service and training with a market value of PLN 5,000
• GOksięgowość - online accounting services for Customers running their own business (including a debt
enforcement services module). The service is available 24/7, and registration and signing of the
contract take place without a visit to an accountant’s office or an institution
• GOdealer – a currency exchange application with 24/7 transaction processing. Business Customers can
also use bi-currency deposits
• Axepta – a payment gateway for Customers, with access to various forms of payment, i.e. quick transfer,
BLIK, card payments, including electronic wallets (Apple Pay and Google Pay)
• cooperation with BNP Paribas Leasing Solutions – a comprehensive financing offer based on fixed or
variable interest rates, enabling the implementation of projects supported by European Union subsidy
programmes (including photovoltaic installations, heat pumps, charging stations and energy-storage
systems)
• cooperation of the Bank and BNP Paribas Leasing z FinTech Monevia (leader in online micro factoring) -
an offer of complete factoring solutions on preferential conditions, regardless of the industry, size or
market seniority of the company
• cooperation with Elavon - wide range of payment terminals (including softPOS application). Option to
order a terminal in GOonline remotely
• Carbon Footprint Calculator – service made available in partnership with Envirly, supported by artificial
intelligence algorithms - enables easy calculation and management of carbon footprints
KEY FIGURES
• GOdealer: activation of the system by more than 2,300 micro-Customers in 2025; execution of more
than 130,000 transactions with a total volume of PLN 1.2 billion
• Micro Leasing: PLN 384 million of financed contracts in 2025
BNP Paribas Bank Polska S.A. Brokerage Office
The BNP Paribas Bank Polska S.A. Brokerage Office (Brokerage Office) mainly serves retail Customers. The Brokerage Office’s
services complement the Bank’s range of investment products. The Brokerage Office also has an offering for selected
institutional Customers, including Open Pension Funds (OFE), Investment Fund Companies (TFI) and other entities that
manage assets entrusted to them. In addition, the Brokerage Office manages portfolios and provides investment advice for
Customers of the Premium Banking and Wealth Management segments.
The Brokerage Office offers a wide selection of investment funds managed by reputable Polish and foreign investment fund
companies.
Brokerage in figures for 2025:
• conducting sales of more than 715 funds managed by 19 companies,
• PLN 14 billion - the value of Customers’ assets in investment funds distributed by the Brokerage Office at the end of
December 2025,
• PLN 892 million - the value of investment certificates issued in 2025 for the Brokerage Office’s Customers in cooperation
with the BNP Paribas Group (+13% year on year),
• PLN 142 million - revenue from brokerage services and distribution of investment products (+24% year on year),
• a 62% year on year increase in assets in the portfolio management service for Wealth Management Customers,
• a 9% year on year increase in commission income from stock exchange transactions of the Brokerage Office’s Customers,
• increase in results of investment advisory services and portfolio management well above their benchmark indices.
Table 5. Share of the Bank’s Brokerage Office in turnover on the WSE
31.12.2025
31.12.2024
volume
share
volume
share
Shares
PLN million
5,920.37
0.60%
4,154.84
0.60%
Bonds
PLN million
706.29
5.13%
281.43
2.91%
Contracts
units
212,236
0.87%
170,468
0.64%
Investment certificates
PLN million
0.94
1.35%
0.15
0.19%
Options
units
17,689
4.37%
21,373
5.05%
Structured products
PLN million
212.30
3.22%
291.71
5.45%
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40
SME and Corporate Banking area
Characteristics of the area
The Corporate Banking area directs its offer to large and medium-sized enterprises and local government units with annual
net sales revenues equal to or greater than PLN 80 million, and also to entities that are part of international capital groups.
Corporate Banking Customers are divided into four main groups:
• Polish corporations with annual net sales revenue of between PLN 80 and 600 million,
• International Customers (companies belonging to international capital groups),
• the largest Polish corporations with net sales revenues exceeding PLN 600 million,
• public sector entities and financial institutions.
These groups include Agro and non-Agro Customer subsegments.
The Small and Medium-sized Enterprise (SME) Banking area serves three main Customer subsegments:
• Agro Customers who maintain full financial reporting with net sales revenues for the previous financial year from PLN 8
million to PLN 80 million. This subsegment also includes groups of agricultural producers,
• Non-Agro Customers – a sub-segment for entities with full financial reporting and net sales revenues for the previous
financial year of PLN 8 million to PLN 80 million. This sub-segment also includes churches and other religious
organisations and their dependent entities,
• Farmers (i.e., corporate Customers running agricultural production) maintaining full financial reporting, with net revenues
for the previous financial year up to 60 million, as well as individual farmers not maintaining full financial reporting, if
their credit exposure is up to PLN 6 million, and individual farmers, regardless of their credit exposure level, provided
they reach a significant scale of production as defined in the detailed rules (including, among others: field crops above
220 hectares, ground-grown fruit and vegetables above 50 hectares, greenhouse cultivation above 1 hectare).
Implementation of key strategic initiatives in 2025
Corporate Banking
INITIATIVE
New approach to the Customer using the strength and potential of the Group
INITATIVE
DESCRIPTION
A leader in the international Customer sector and in developing cooperation with largest Polish
corporations. Unique approach based on the strong position of the BNP Paribas Group, especially in
terms of global relations and product platform
ACHIEVEMENTS
• strengthening the Bank’s position on the international Customer market
• acquisition of new international Customers in cooperation with the BNP Paribas Group
• supporting Customers in their green transition through an ecosystem of products and services as part
of the beyond banking offering featuring innovative sustainability solutions including, among others, a
carbon footprint calculator and ESG rating
KEY FIGURES
• increase in the number of active international Customers by 4% year on year (+137 year on year)
• dynamic growth in loans to international Customers of 18% year on year
• 23% year on year increase in the value of the sustainable financing portfolio
INITIATIVE
New Customer service model
INITATIVE
DESCRIPTION
Sales area transformation by providing Customers with the widest range of self-service solutions and
providing a centralised and dedicated after-sales service
ACHIEVEMENTS
• increasing the level of automation and use of the GO Business ecosystem in Customer relationships:
module for Cards in GOmobile Biznes, performance improvements for instant mass payments, and the
release of new versions of the Administrator Panel and Import Letters of Credit modules
• implementation of applications
GOwadia Plus – a modern tool enabling Customers to comprehensively manage settlements related
to tender processes
FX Pl@net – a new version of the currency exchange platform, now also available in English
• implementation of changes to the operating model (including, among others, the centralisation of
support functions) and a new KYC process model for Customers in the Polish corporate segment (up to
PLN 600 million in turnover)
• further specialisation in servicing sector Customers (food & agro, public sector entities) and
optimisation of the sales network
• continued growth in the use of self-service solutions by Customers
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
41
INITIATIVE
New Customer service model
KEY FIGURES
• increase in the number of active Customers by 2% year on year
• increase in lending volumes in Corporate Banking of 11% year on year
• credit process duration reduced by 24% year on year
Small and Medium-sized Enterprises
INITIATIVE
New Customer service model
INITATIVE
DESCRIPTION
Sales area transformation by providing Customers with the widest range of self-service solutions and
providing centralised and dedicated after-sales service
ACHIEVEMENTS
• year on year increase in gross profit of SME Banking thanks to maintenance of good quality of the loan
portfolio and low cost of risk combined with lower revenue due to lower interest income
• for SME Customers: continuation of changes to the operating model in the area of sales support
(including the development of the digital Customers portfolio), implementation of a new KYC process
model, and centralisation of support functions
• specialisation in servicing sector Customers and optimisation of the sales network
• further expansion of the Digital Customer Team dedicated to Customers who prefer active remote
contact with the Bank
• implementation of a credit process using an automated decision engine for SME Customers, including
Farmers
KEY FIGURES
• 22% of SME Customers served by the Digital Customer Team
• growth in new loan production and a 43% year-on-year reduction in credit process duration
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42
Other initiatives of the business line
INITIATIVE
ACHIEVEMENTS
INNOVATIVE PRODUCTS AND SERVICES
KEY FIGURES
CASH MANAGEMENT
• development of cash management product and
service offering
• continued migration to new payments
communication format XML_ISO20022
• payments: improved performance of mass transfers (including instant Express Elixir transfers)
• cards: introduction of a new prestigious Mastercard Business World Elite business card offering advanced features and
benefits, while also being environmentally friendly (made from biodegradable material)
• new product packages (Classic, Comfort, Premium) designed to meet the diverse needs and stages of development of
SMEs
• automation of foreign payments
• enhancements in ongoing post-sales customer service in the Customer Service Office, including:
automated phone connection with the dedicated Customer Service Advisor assigned to a specific Customer, enabled
through NIP (tax ID) recognition
launch of a chat-based virtual assistant (powered by internal GenAI models) that supports Customer Service
employees in their daily phone and email interactions with Corporate and SME Banking Customers
• GOwadia Plus – launch of a new, modern tool for Customers to comprehensively manage finances related to tenders
and projects. The application gathers information on all ongoing tenders and payments, and automates the process
of receiving and returning funds, ensuring transaction security and saving time.
• increase in the number of incoming transactions
(incoming transfers + cash deposits) by 2% year on year
• increase in the volume of incoming transactions
(incoming transfers + cash deposits) by 3% year on year
FINANCING
CORPORATE
CUSTOMERS
• continued improvements in the credit process
through the creation of an efficient and automated
credit workflow that will support credit growth and
asset enhancement with an optimal level of credit
risk
• expansion of the implementation of the credit
process for SME Customers using an automated
decision-making engine to all SME Customer
Centres
• implementation of a credit process with a decision
engine for Farmers
• implementation of regulatory changes and
adjustments to sales processes resulting from the
CRR3
• introduction of changes to the loan disbursement
process
• implementation of automatic import of companies’ annual financial statements from eKRS into the Bank’s systems
(in April)
• launch of a new credit process for Farmers with an automatic decision engine for credit decisions up to 4 million PLN
(in October). The new credit process will enable:
faster credit decision-making
elimination of unnecessary steps in the process
ultimately, full automation of the credit process for selected transactions of individual farmers
• changes and automation in electronic credit applications (eWnioski) for SME and Corporate Banking Customers – further
adjustments aligned with changes in credit processes
• introduction of changes to the loan disbursement process – optimisation of documentation verification before loan
disbursement for SME and Corporate Customers (in December)
• over 10,600 credit decisions made in the new credit
process, and 60,000 orders processed by credit
administration
• 23% of SME credit decisions made using the automatic
decision engine
• 8,300 financial statements automatically retrieved from
eKRS and published internally (verified and approved as
a source for further internal processes)
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
43
INITIATIVE
ACHIEVEMENTS
INNOVATIVE PRODUCTS AND SERVICES
KEY FIGURES
E-BANKING
• Development of the GO Biznes ecosystem:
• release of new versions of GOonline Biznes
modules: Administrator Panel, GOonline Biznes user
onboarding process, and Import Letters of Credit
• release of a new version of the GOmobile Biznes
mobile app featuring a new card module for
handling debit, multi-currency, charge, and credit
cards
• increasing the level of automation and the use
of the GO Biznes ecosystem in interactions with
Customers
GOonline Biznes:
• launch of the new Administrator Panel, enabling management of system user permissions, including:
adding, removing, and temporarily blocking users, as well as general user management
modifying permissions for accounts and functionalities
setting time and IP address restrictions for using GOonline Biznes
adding, modifying, and deleting approval schemes (for transfers, applications, counterparties, trade finance requests)
handling administrator instructions
access to reports and the history of actions performed in the Administrator Panel
• release of a new onboarding process for GOonline Biznes users, with added functionalities, including:
archiving attachments and generating KDO
storing identity document expiry dates
an application for non-residents
automatic approval of applications for existing users whose data is complete and correct
• launch and enhancement of the Import Letters of Credit module - new interface and new functionalities, including:
a new intuitive layout and navigation that simplifies order completion (through validations and hints)
a summary view of all open letters of credit (broken down by currency)
display of available limits on the module’s main screen
access to key information and actions directly from the lists of letters of credit, orders, and payments
flexible search and additional filters (e.g., by user)
adding SWIFT field numbers to the names of individual fields in orders
option to add new fields in orders, such as country of origin of goods or comments for the Bank
option to edit counterparties directly in the Import Letters of Credit module
• launch of the new Cards module, enabling:
viewing the list of cards, card transactions, and available limits
card management (card activation, card blocking, PIN setup, etc.)
• increase in mobile banking users by 17% year on year
CUSTOMER LIFECYCLE
• continued automation of onboarding and post-sales
processes
• expanding the range of Customers eligible for fully digital onboarding and implementation of new tools for remote
identification
• expansion of the scope of instructions in the self-service module, resulting in a significant increase in submitted
requests
• optimised re-segmentation process between the Micro-enterprise segment and the SME segment
• new digital process for adding users and managing their permissions in GOonline Biznes
• new onboarding process for Customers using only a leasing product
• completion of the centralisation of the onboarding process for SME and Commercial Customers
• 78% of SME Customers and 67% of Corporate Customers
opened through a fully digital onboarding process (in Q4
2025)
• increase in the self-service index for SME and Corporate
Customers to 58% (in Q4 2025)
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
44
Food & Agro Area
Area description
BNP Paribas Bank Polska S.A. (the Bank) has a comprehensive product offering for the agro-food sector, including: current
accounts, term deposits, loans and insurance for farmers (voluntary and mandatory).
Micro Customers and Small and Medium-sized Enterprise Banking
In lending, the Bank’s offering includes:
• revolving loans, including the Agro Express secured overdraft and loans with a BGK guarantee and interest rate subsidies,
• investment loans for farmers and Agro companies, including Agro Progres, Unia+ (to co-finance EU projects),
• subsidised loans with interest rate subsidy or partial capital repayment (under an agreement with the Agency for
Restructuring and Modernisation of Agriculture).
In addition to its own offerings, the Bank, in cooperation with external companies, prepares dedicated offers for farmers
concerning additional services, such as Generali Agro insurance, and runs sales campaigns.
Corporate Banking Customers
The Bank’s activities for Corporate Banking Customers focus on:
• business development by leveraging unique knowledge and a precise understanding of the entire sector value chain
(farmer, processor, distributor, consumer) and sector ecosystem (macro environment, policy, technology, international
trade, suppliers, customers), including the development of cross-segment financing (value chain financing),
• preparation of sector analyses, including changes in industry trends,
• initiating cooperation with the BNP Paribas Group in the field of agro-food sector Customers,
• sector recommendations for significant credit transactions (company positioning in the industry and peer group),
• operation and development of the Agronomist platform providing reliable knowledge and useful tools for the digital
and sustainable transition of the agro-food sector.
Implementation of key strategic initiatives in 2025
INITIATIVE
Agronomist - an innovative way to build relationships and share knowledge
INITATIVE
DESCRIPTION
Creation of a portal for farmers and entrepreneurs from the Food & Agro (F&A) sector wishing to develop
in line with market trends. Providing knowledge and tools to support the transition towards sustainable
agriculture and digital transition. The portal’s content covers the entire F&A value chain with special
attention to local communities
ACHIEVEMENTS
• Agroemisja – a greenhouse gas emissions calculator at the farm level for dairy, livestock, and crop
production, including water footprint assessment
• Regagri Explorer – a professional tool for estimating the level of CO₂ absorption in soil
• Nitrogen use calculator and an agricultural weather service with SMS alerts
• Kredytomat – a simple and user-friendly search tool for bank products, helping farmers find the
solutions best suited to the needs of their agricultural operations
• ESG materials – preparation and publication of materials related to environmental and social impact
reporting for the food production value chain
• PULS AGRO – video materials prepared together with experts about the current situation on the fields in
various regions of Poland
KEY FIGURES
• 209,700 unique visitors to the portal (source: Google Analytics 4)
• 14.3 million hits in Google (source: Google Search Console)
INITIATIVE
Knowing the Customer as the basis for building profitable relationships and increasing their satisfaction
INITATIVE
DESCRIPTION
Further industry knowledge-based expansion in the area of the food production value chain. Adapted
service model for current and future key F&A sector Customers. Improvements in the credit process
ACHIEVEMENTS
• analyses of markets and selected subsectors of the agro-food industry, analyses and publications
related to the market implications of the war in Ukraine, used both internally and externally by the
Bank
• organising sessions on specific food market areas for existing and prospective Customers and
• active substantive participation in economy-wide and sector-specific events, cooperation with
a number of organisations from the agro-food sector
KEY FIGURES
• increase in the average annual deposit balance of farmers by 8.4% year on year (with a stable number
of farmers)
• increase in loan balances in the Corporate Banking segment by 4.6% year on year (with a stable number
of active food processing companies)
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45
Other initiatives of the business line
Investment loans with Agromax guarantee (FGR Plus) - in August 2024, the Bank’s offer was extended to include a loan
with an interest subsidy secured by an Agromax guarantee from the Fund for Agricultural Guarantees Plus (FGR Plus). This
financing is available under an agreement with Bank Gospodarstwa Krajowego, which allows us to act as an intermediary
for the public support provided for in the Strategic Plan for the Common Agricultural Policy 2023-2027.
In 2025, the following changes were introduced to this product:
• March – we launched financing for investments carried out by pig producers, secured with the Agromax guarantee and
preferential subsidy conditions for interest repayment. Eligible Customers may receive a subsidy for four consecutive
years from the loan disbursement date, amounting to:
100% for the first two years, up to 8 percentage points,
50% for the following two years, up to 4 percentage points.
The same subsidy levels also apply to working capital financing linked to the investment.
• June – we expanded the eligibility of this loan to include producers connected to agricultural products (e.g., bakeries,
confectionery manufacturers, pasta producers, ready-meal producers), as well as companies providing services to
agriculture or forestry.
Sales of FGR Plus Guarantees in 2025 placed the Bank first among all banks offering this product, with a 37% market share.
Working capital loans with FGR guarantee
In September 2025, the Ministry of Agriculture asked banks for proposals to support farmers in response to falling grain
prices. In October, the Bank launched a new version of the existing working capital loan with an FGR guarantee and an
interest rate subsidy (extending the subsidy period from 12 to 24 months, increasing the subsidy for Customers from 5% to
7%). From October to December 2025, we granted over 2,100 loans under the FGR initiative, totalling over PLN 640 million
(market share: 21%).
Insurance – cross-sell
Through cooperation with Generali Polska TU S.A., the Bank offers a wide range of insurance products, including: crop
insurance with state subsidised premiums, agricultural machinery insurance, life and health insurance, and Generali
Agricultural Farm insurance. Crop insurance accounts for the largest share of sales: across the spring and autumn
campaigns, 4,400 policies were concluded, with total premiums of PLN 27.8 million. Insurance sales represent a significant
part of Agro’s non-interest income.
Cooperation with the Polish Federation of Cattle Breeders and Dairy Farmers (PFHBiPM)
PFHBiPM is a nationwide industry organisation with over 11,000 members, including individual farmers, state farms,
state-owned companies, private enterprises, cooperatives, and leased farms.
The Bank has cooperated with the Federation for many years, and the cooperation agreement signed in 2025 enabled us to
reach a broader group of breeders. Under the agreement, we conducted promotional and advertising activities, participated
in meetings, conferences, and promotional events, including the Federation’s 30th anniversary and 10 regional conferences
for milk producers – Mleczne Laury (a special promotional offer was prepared for selected farmers: 0% front-up fee on
selected loans related to agricultural operations).
Sales support and Customer relationship activities
• Value Chain Financing – in the second half of 2025, the first transactions were signed with agro-food processors as part
of developing financing across the food production value chain (farmer – food processor – distributor – consumer).
• “Time for Financial Harvest” – until 31 December 2025, a deposit promotion targeted at new Customers (Farmers) in the
Micro and SME segments who opened an Agrobiznes or AgroBOX account with attractive interest rates on deposited
funds.
• Sustainable agriculture – implementation of tools and operational activities supporting the transition of farmers toward
regenerative agriculture, including internal training, meetings with farmers, press publications, and cooperation with
external partners (e.g., signing a cooperation agreement with the Polish Academy of Sciences).
• Agro Academy – second edition – a six-month series of sectoral training sessions (in-person and online) on crop and
livestock production and sustainable agriculture, delivered to 73 advisors (Micro business segment), totalling 42
workshop hours.
• O N A: WOMAN IN AGRO – a new format of meetings organised by the Bank in cooperation with Leaders of Innovation,
dedicated to women in the agricultural sector: farm owners, community leaders, specialists, and innovators. The concept
is built on four elements:
EARTH: knowledge and foundations (EU funds and artificial intelligence)
WATER: exchange of experience (panel discussion – innovations in agriculture from women’s perspectives)
AIR: banking solutions (new products and services for farmers)
FIRE: development and relationships (workshops on communication across genders and generations).
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
46
Corporate and Institutional Banking area
Area description
Corporate and Institutional Banking (CIB Area) provides a broad product offering aimed at both the largest Polish
enterprises and medium-sized companies. The Custody Services Department also addresses its offer to insurance
companies as well as pension and investment funds.
The CIB Area provides Customers with comprehensive BNP Paribas Group solutions in financing and risk management,
including:
• capital market transaction advice and arrangement,
• acquisition and investment project finance,
• working capital financing,
• cash flow, liquidity, and working capital optimisation management,
• currency and money market transaction arrangement,
• sales of financial market products, hedging currency, interest rate, and commodity price risks,
• M&A and restructuring advisory.
In addition, this area includes market risk management in the trading book, quotation of prices of foreign exchange market
instruments and interest rate market instruments (including derivative market transactions), as well as determining the
Bank’s foreign exchange rates table and structuring and management of risks associated with the Bank’s offering of
structured products.
Implementation of key strategic initiatives in 2025
INITIATIVE
New approach to the Customer leveraging the strength and potential of the Group
INITATIVE
DESCRIPTION
Leader in the international Customer sector and in developing cooperation with the largest Polish
corporations. A unique approach based on the strong position of the BNP Paribas Group, especially in
global relationships and product platforms.
ACHIEVEMENTS
• increase in cross-sell with international Customers through sales activities aimed at decentralising
market risk management competences
• leveraging the BNP Paribas Group’s position and developing global relationships resulting in closer
cooperation with international Customers
INITIATIVE
New approach to the Customer leveraging the strength and potential of the Group
KEY FIGURES
• increase in the volume of transactions made via electronic channels by international Customers (+6%
year on year)
• increase in NBI on transactions made via electronic channels by international Customers (+18% year on
year)
INITIATIVE
New Customer service model
INITATIVE
DESCRIPTION
Transformation of the sales area by providing Customers with the widest range of self-service solutions
and ensuring centralised and dedicated post-sales service.
ACHIEVEMENTS
changes in the sales network, adapting its structure to the evolving model of corporate Customer
service, and to the specificity of the conducted business
KEY FIGURES
increase in the number of active Customers in the FX Pl@net application (+4% year on year)
increase in the number of transactions in the FX Pl@net application (+12% year on year)
Other banking activity
The remaining banking activity of BNP Paribas Bank Polska S.A. (the Bank) is operationally carried out mainly within the
Asset and Liability Management Division (ALM Treasury Division). The task of the ALM Treasury Division is to ensure the
proper and stable level of financing that allows the Bank to operate safely while complying with the legal norms and
limiting the Bank’s net interest income sensitivity to the volatility of market interest rates.
The ALM Treasury Division combines the function of a business line and a competence centre responsible for managing:
• interest rate risk,
• current and structural liquidity of the Bank,
• structural currency risk,
• internal transfer prices for all deposit and credit products offered by the Bank (including their determination).
Tasks carried out within the ALM Treasury Division include both a prudential aspect (compliance with external regulations
and internal directives) and an optimisation aspect (managing financing costs and generating results from managing
positions in the Bank’s balance sheet).
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47
One of the key risk management mechanisms in the Bank is the systemic transfer of structural risks from all business lines
to the ALM Treasury Division. Structural risks are: currency risk, liquidity risk and interest rate risk in the banking book. The
ALM Treasury Division centrally manages these risks. Risk transfer is primarily carried out within the transfer pricing
system, which reflects the strategy of financing the Bank’s activities and developing the Bank’s balance sheet.
The main duties of the ALM Treasury Division include ensuring: a balanced liquidity position while optimising the cost of
financing the Bank’s operations, and an appropriate structure of assets and liabilities, including sensitivity to changes in
interest rates. Other functions of the ALM Treasury Division include:
• management of the internal transfer pricing system,
• balance sheet analysis,
• modelling and monitoring of liquidity risk and interest rate risk in the banking book,
• issuance of the Bank’s debt securities,
• organising long-term credit lines,
• raising financing sources,
• cooperation with business lines supporting sustainable development,
• coordination of the securitisation transactions of the non-bank Customers’ loan portfolio,
• organisation of the Asset and Liability Management Committee (ALCO) operations.
The Bank adjusts internal product behavioural models affecting the Bank’s interest rate and liquidity risk profiles on an
ongoing basis. The ALM Treasury Division cooperates with business lines by organising regular meetings and consultations
to optimise the Bank’s product structure and maintain the Bank’s profitability at the highest possible level in current
macroeconomic conditions.
Cooperation with financial institutions
As at 31 December 2025, the Bank maintained correspondent relationships with approximately 1,000 banks, including 52
NOSTRO accounts in other banks for 20 major currencies.
The Bank operates 46 LORO accounts exclusively in PLN for foreign banks in the BNP Paribas Group. LORO accounts
operated in the Bank’s books represent an external source of obtaining free operating funds for the Bank’s operational
needs. Above all, these accounts are used to make Customer transfers and bank-to-bank transfers.
In 2025, the Bank continued its cooperation with other domestic and foreign financial institutions, brokers and banks, which
allowed for a wide range of treasury and deposit transactions. Several agreements with new and existing counterparties
from these segments were signed, and steps were taken to introduce new agreements, in line with ISDA and ZBP
recommendations.
Agreements with the National Bank of Poland signed in 2025:
• Agreement for opening and maintaining a “SORBNET3” bank account
• Term deposit agreement in PLN in the “SORBNET3” system
• Lombard credit agreement
• Technical credit agreement
Distribution channels
Sales network
As at 31 December 2025, the Bank had 355 Customer Centres (including 8 partner branches). The network of Customer
Centres was complemented by 16 Wealth Management Centres.
In efforts to optimise the network in 2025, 8 Customer Centres were closed, including 3 partner branches.
In 179 Customer Centres (including 1 partner branch), cash service was provided exclusively by self-service devices.
All of the Bank’s Customer Centres have the OK SENIOR® Certificate, confirming that senior Customers (60+) are serviced in
branches in a safe, understandable and accessible manner; and 144 Customer Centres hold the “Barrier-Free Facility”
Certificate, issued by the Integration Foundation for good practices in servicing disabled people.
The Customer Centres are responsible for providing full service to retail Customers including Mass, Premium and Micro
Customers.
The sales network is managed within the Retail and Business Banking Customer Division, which is also responsible for the
product offering and services offered to retail Customer segments in Customer Centres, including the service model.
For Wealth Management segment Customers, both the Wealth Management Centres and the range of products and
services offered to this segment are managed by the Wealth Management Division.
The current branch network and management structure enables effective sales management, increasing the quality of
Customer service in a manner tailored to Customers’ expectations and quickly addressing the needs of Customers in given
segments.
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48
In 2025, the in Corporate and SME Banking sales network comprised:
• Strategic Customers Division, organised within the head office, responsible for relations with international Customers,
Poland’s largest corporations (with net sales revenue in excess of PLN 600 million), as well as financial institutions and
selected public sector entities;
• SME and Corporate Customers division, which manages the regional sales network, divided into segments by revenue:
Commercial Customers: entities with revenues of PLN 80–600 million. Service for this group of Customers is provided
through 9 Corporate Customer Centres located in key cities,
SME Customers: the sales network consists of a total of 15 specialised SME Customer Centres located in cities with the
highest economic potential.
The sales network is complemented by specialised competence units. The SME and Corporate Customers Division includes
the Sector Customers Department (servicing Customers from the agricultural sector and public sector entities) operating
since January 2024 and the Digital Customers Office (dedicated to developing cooperation with Customers who prefer
remote service through online and mobile banking channels).
This organisation of the sales network enables greater specialisation in servicing different Customer groups, which in turn
improves the quality of products and services offered and ensures better alignment with the specific needs of Customers,
particularly companies in the agricultural and public sectors.
The Bank’s business model for servicing SME and Corporate Customers is based on relationship banking. Its core principle
is individual service and support provided by a Relationship Manager, who is responsible for the overall management of the
Customer relationship and cooperation with the Bank. In addition, to fully meet Customer needs, dedicated specialist teams
provide a high standard of sales and product advisory services, drawing on expertise in cash management, treasury,
leasing, factoring, and trade finance services and financing.
An important element of access to the products and services offered is the state-of-the-art online and mobile banking
systems offered as part of the GO Biznes ecosystem dedicated to SME and Corporate Customers.
The distribution channels of the sales network are complemented by after-sales Customer service, which is provided
through dedicated Customer Service Offices.
Cooperation with brokers
As at 31 December 2025, in the Retail and Business Banking Division, the Bank collaborated in the acquisition of banking
products based on:
• outsourcing contracts - with 13 external outsourcing intermediaries, 1 outsourcing broker acting exclusively for the Bank
and 7 franchise partners,
• marketing contracts - with 94 counterparties.
In the B2C Sales Development Division, with regard to the acquisition of banking products, the Bank cooperated with 17
external brokers on the basis of outsourcing agreements.
Automated teller machine (ATM) and cash deposit machine (CDM) network
As at 31 December 2025, the Bank’s Customer Centres were operating 590 machines including:
• 589 dual-function devices handling contactless deposits and withdrawals with the Bank’s cards and using BLIK, as well as
cash withdrawals using Google Pay and Apple Pay; and
• 1 ATM handling only standard withdrawals and transactions provided by the VISA and Mastercard systems.
In addition, 12 machines including 10 dual-function machines and 2 ATMs were operating outside the Bank’s Customer
Centres.
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49
Operations and business support area
Implementation of key strategic initiatives in 2025
INITIATIVE
Process excellence
INITATIVE
DESCRIPTION
Optimisation, automation and digitalisation of all key processes, thus enhancing Customer service quality
and cost efficiency. Developing process mining to assist process owners in process management.
Promoting Lean culture and continuous process improvement by creating a dedicated training
programme and Lean community
ACHIEVEMENTS
• focusing on the measurable value delivered to the Customer by organising work in product/process
circles and consolidating the operational area of Customer Financial Security Management
• improving operational efficiency through the implementation of a New Operating Model supporting the
Bank’s strategy, based on tools such as Kaizen, Problem Solving, Efficiency Boost (workload balancing),
Competence Matrices, and performance dashboards that enhance process efficiency
• implementation of a new tool for managing workflow, monitoring efficiency, and developing
competences
• development of AI-based solutions that streamline operational process handling and mitigate
transaction risks (including credit, claims, insurance, AML) – classification and data extraction models
for documents provided by Customers, increasing cost and resource efficiency
• increased automation through the deployment of process robotics across the Bank, improving efficiency
in retail, corporate, trade finance, compliance, and AML processes
• implementation of a culture of continuous improvement, supported by the development of lean
competences aimed at eliminating process redundancy
• optimisation of the Bank’s product portfolio – reduction in the number of retail and corporate products
• implementation of a tool supporting the procurement and accounting platform
KEY FIGURES
• increase in operational efficiency by 15%
• increase in multiskilling of employees (acquisition of new skills and functions and expansion of those
already acquired by developing the scope and level of competence) - 55% of multiskilling employees
• 250 active robots, 35 new implementations in 2025
• optimisation of the product portfolio by 15%
Entities of BNP Paribas Bank Polska S.A. Group
BNP Paribas Towarzystwo Funduszy Inwestycyjnych S.A.
BNP Paribas Towarzystwo Funduszy Inwestycyjnych S.A. (BNPP TFI, the Company) has been operating in the financial
services sector since 1992, previously functioning on the Polish capital market as a Brokerage Office.
BNPP TFI is authorised by the Polish Financial Supervision Authority to create and manage investment funds and as an
intermediary in selling and redeeming shares of funds and foreign funds.
BNPP TFI cooperates with the Bank in the distribution of shares of funds offered by the Company, based on an agreement
between the Bank’s Brokerage Office and the Company.
In 2025, the following significant events took place in the Company’s operations:
• increase of 26% year on year in net assets under management in investment funds managed by the Company;
• most popular sub-funds in the Company’s offering were:
BNPP Papierów Dłużnych Krótkoterminowych Skarbowych (net inflows of PLN 416 million), part of BNPP FIO ,
BNP Paribas Krajowych Funduszy Dłużnych Uniwersalny (net inflows of PLN 342 million), part of BNP Paribas Parasol
SFIO ,
BNP Paribas Globalny Obligacji Zamiennych (net inflows of PLN 324 million), part of BNP Paribas Parasol SFIO,
applying an ESG-based investment policy (in line with Article 8 of the SFDR),
BNPP Globalny Strategii Dłużnych Uniwersalny (net inflows of PLN 317 million), part of BNPP FIO, also applying an
ESG-based investment policy (in line with Article 8 of the SFDR);
• net inflows in 2025 totalled PLN 1,524 million;
• as of the end of 2025, 30.6% of net assets under management in investment funds managed by the Company were
allocated to sub-funds applying ESG-based investment policies (in accordance with the SFDR);
• on 5 May 2025, investment policy changes were introduced for the BNP Paribas Globalny Obligacji Uniwersalny sub-fund
and the BNP Paribas Globalny Obligacji Zamiennych sub-fund in the Articles of Association of BNP Paribas Parasol SFIO
managed by the Company;
• on 19 November 2025, net assets under management in the investment funds managed by the Company exceeded PLN
10,000 million.
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Corporate Governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
50
As at 31 December 2025, the Company managed the following funds with a total value of PLN 10,318 million:
• BNP Paribas FIO – created in March 2016. This fund comprises 7 sub-funds (including two sub-funds applying an ESG-
based investment policy) with diversified investment policies that enable Customers to invest in various asset classes
both locally and globally. The BNP Paribas FIO also includes an Individual Retirement Account: BNP Paribas - IKE and an
Individual Retirement Security Account: BNP Paribas - IKZE. The value of the fund’s assets at the end of 2025 was
PLN 1,609 million.
• BNP Paribas Parasol SFIO – there are 9 sub-funds within the fund, including 6 sub-funds applying an ESG-based
investment policy. The value of the fund’s assets at the end of 2025 amounted to PLN 3,079 million.
• BNPP FIO – established in 2005. This fund comprises 3 sub-funds (including one sub-fund applying an ESG-based
investment policy). The value of the fund’s assets at the end of 2025 amounted to PLN 5,052 million.
• BNP Paribas PPK SFIO – created to offer Customers employee capital plans, with 9 sub-funds (defined date funds).
The value of the fund’s assets at the end of 2025 amounted to PLN 578 million.
• BNP Paribas Premium SFIO in liquidation – created in July 2014, with 4 sub-funds. The management of the fund was
taken over as a result of the merger with Riviera TFI.
• FWR Selektywny FIZ in liquidation - created in May 2014, the management of the fund was taken over as a result of the
merger with Riviera TFI.
Table 6. Key financial data of BNP Paribas Towarzystwo Funduszy Inwestycyjnych S.A.
PLN’000
31.12.2025
31.12.2024
change y/y
PLN’000
%
Total assets
57,389
48,992
8,397
17.1%
Long-term investments
540
509
31
6.1%
Equity, including:
44,985
38,886
6,099
15.7%
net profit
14,479
8,465
6,014
71.0%
BNPP TFI has share capital of PLN 16,692.9 thousand divided into 695,538 shares with a nominal value of PLN 24 each.
Its equity as of 31 December 2025 amounted to PLN 45.0 million and is sufficient to safely conduct day-to-day operations.
The Company achieved a net profit of PLN 14.5 million in 2025 (PLN 8.5 million in 2024).
BNP Paribas Leasing Services Spółka z o.o.
BNP Paribas Leasing Services Sp. z o.o. (the Company), in cooperation with the Bank, offers a full range of leasing products
for micro-enterprises, Personal Finance, SME and corporate Customers. Since 2018, based on the decision of the Bank’s
Management Board, the Company has taken on the role of the only entity in the BNP Paribas Bank Polska Group that
provides leasing services for Customers in the above-mentioned segments.
Table 7. Key financial data of BNP Paribas Leasing Services Spółka z o.o.
PLN’000
31.12.2025
31.12.2024
change y/y
PLN’000
%
Total assets
7,162,288
7,207,866
(45,578)
(0.6%)
Long-term investments*
6,755,382
6,939,722
(184,340)
(2.7%)
Equity, including:
142,441
109,900
32,541
29.6%
net profit
32,534
25,741
6,793
26.4%
* receivables from granted financing
The year 2025 brought a continuation of the sales challenges experienced in the previous year. The micro-enterprise
segment delivered particularly strong results, achieving significantly higher sales compared with 2024. In Personal Finance,
after a strong start to the year, the following months showed a noticeable slowdown in sales dynamics, although signs of
recovery appeared toward year-end. In the Corporate and SME segments, sales volumes declined compared with 2024,
while at the end of 2025 there were early signs of renewed activity in the Strategic Customers segment.
The portfolio of financed assets reached PLN 6.8 billion as at 31 December 2025 (a 3% year on year decrease), driven by
lower sales volumes. In 2025, the Company concluded 19,800 new contracts with a total value of PLN 3,253 million (a 19%
year on year decline in volume) and recorded a net profit of PLN 32,534 thousand, consistently increasing its equity base.
During the same period, the Company’s administrative expenses increased by 3% compared with 2024, which is below the
inflation rate affecting personnel costs and external supplier expenses. Effective cost management continues to be
supported by the Company’s strategy of improving operational efficiency. Credit risk in the portfolio remained stable,
generating a financial impact below forecasts. Throughout 2025, the quality of the credit portfolio remained very strong.
Initially, the Company’s operations were financed by BNP Paribas S.A., Paris. In December 2021, an additional loan
agreement was signed with BNP Paribas Bank Polska S.A. for PLN 1 billion. In November 2023, an annex increased the limit
to PLN 2.5 billion, followed by further increases to PLN 3.5 billion in July 2024 and to PLN 4.5 billion in August 2025. In July
2025, an agreement was signed with the European Investment Bank for a non-renewable credit line of EUR 200 million,
planned for use in 2026.
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
51
Table 8. Financing structure of BNP Paribas Leasing Services Spółka z o.o. as at 31 December 2025
million
amount in
PLN
PLN
EUR
BNP Paribas S.A.
3,623
1,390
528
BNP Paribas Bank Polska S.A.
2,635
2,511
29
BNP Paribas S.A. Oddział w Polsce
167
167
-
European Investment Bank
422
397
6
BNP Paribas Group Service Center S.A.
The business areas of BNP Paribas Group Service Centre S.A. consist of:
• providing IT services in the development of banking and financial applications and systems and IT support for entities
from the BNP Paribas Group,
• providing electronic equipment rental services for retail Customers,
• comprehensive management of loyalty programmes for entities related to the Bank and for the Bank’s Customers,
• providing marketing services on behalf of the Bank for employees of the Bank’s partners, Customers or the Bank’s
employees and other entities of the BNP Paribas Group,
• developing scoring models as well as their verification and monitoring on behalf of the BNP Paribas Group entities,
• providing financial intermediation services through the mamgo.pl platform, which makes available financial products
from BNP Paribas Group companies focused on car financing for individual and corporate Customers,
• providing auxiliary services to insurance mediation activities, consisting of administering and executing group insurance
contracts concluded by the Bank,
• providing agency services in the field of insurance services.
Table 9. Key financial data of BNP Paribas Group Service Center S.A.
PLN’000
31.12.2025*
31.12.2024
change y/y
PLN’000
%
Total assets
76,152
71,504
4,648
6.5%
Long-term investments
47,500
45,500
2,000
4.4%
Equity, including:
61,444
56,854
4,590
8.1%
net profit
4,590
4,123
467
11.3%
* unaudited
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
52
Pillar POSITIVE
Pillar description
The Bank wants to be a leader in sustainable finance by developing a portfolio of products and services for all business
lines. The Bank’s aim was their dynamic sales, leading to an increase in sustainable finance. The target of 10% set in the
GObeyond Strategy for 2025 was achieved in 2023 and at the end of 2025 the share was 14.6%. The Bank is implementing
the highest ESG risk management standards and constantly improving the ESG risk profile of its loan portfolio. Additionally,
the Bank consistently measures and limits its carbon footprint by supporting Customers in their transition. The Bank also
seeks to reduce resource use and implement responsible purchasing practices. By 2025, the Bank reduced CO
2
emissions
from its operations by 61% (vs. 2019) and paper use by 60% (vs. 2019).
In relationships with Customers, the key factors included responsibility, availability, transparency and ethics. The
overriding aim is to make Customers buy consciously what they need and not to be surprised by hidden clauses in
contracts. Our Customer Centres continued to be modernised in 2025 to cater to the special needs of seniors and people
with disabilities. The Bank does not plan to introduce solutions that would force Customers to give up their visits to the
outlets. Instead, it will actively support Customers in their digital transition.
The Bank continued its commitment to local communities in 2025 through the development of employee volunteering and
further support of the initiatives of the BNP Paribas Foundation. The Bank initiated public debate, provided educational
activities, and established sectoral and cross-sector partnerships, thus building a brand that is closely associated with
caring for the environment and issues important to society.
Strategic commitments and their implementation
Indicator
Strategic objectives 2025
Implementation 2025
Share of sustainable financing [vs. 2021: 4.5%]
10%
14.6%
Share of sustainable assets under management
[vs. 2021: 5%]
30%
32.1%
Social commitment of employees
(annual average per employee)
4h
2h 40 min
Customer Centres with the "Barrier-Free Facility"
certificate (excluding partner establishments)
[vs. 2021: 18%]
50%
41,5%
Reduction in CO
2
emissions from operations [vs. 2019]
55%
61%
Reduction in paper consumption (based on paper
purchase rate, in tonnes) [vs. 2019: 439.3t]
-80%
-60% (176.9 t)
Sustainable financing
The Bank was committed to offering responsible and sustainable products that have a positive impact on the environment.
The Bank wanted to contribute to the energy transition and the dissemination of solutions that foster environmental
protection and climate change mitigation. More information on the Bank’s actions is presented in the Sustainability Report,
section Climate change (ESRS E1). With its offerings, the Bank wanted to support entrepreneurship development and social
innovation. In 2025, the Bank focused on further developing sustainable products, conducting training for Customer
Advisors and information activities for Customers to promote sustainable financing.
The total value of sustainable financing (total sustainable loans and advances, in line with the assumptions described
above as per the Bank’s internal classification) as at 31 December 2025 was 13.6 billion, representing 14.6% of the total
gross credit portfolio measured at amortised cost (the total gross credit portfolio measured at amortised cost was
presented in Note 21 of the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the year
ended 31 December 2025).
Table 10. Value of sustainable financing provided by the Bank
PLN million
2025
2024
change (%)
with a positive environmental impact
9,083
6,353
43.0%
with a positive social impact
297
471
(36.9%)
ESG Rating-Linked Loans
538
468
15.0%
Sustainability-Linked Loans
3,660
2,866
27.7%
Total
13,578
10,158
33.7%
Table 11. Value of financing with positive environmental impact
PLN million
2025
2024
change (%)
renewable energy
2,107
1,500
40.5%
green building
4,755
2,727
74.4%
thermo-modernisation of buildings
1,214
1,220
(0.5%)
improving the energy efficiency of production processes
169
151
11.9%
low-carbon transport
416
108
285.2%
circular economy
353
212
66.5%
wastewater and water treatment
42
237
(82.3%)
natural resources and biodiversity
27
198
(86.4%)
Total
9,083
6,353
43.0%
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53
Financing with a positive environmental impact includes the following projects:
• renewable energy, including above all onshore and offshore wind farms as well as PV farms,
• energy-efficient construction, whose demand for primary energy is 10% lower than the threshold defined for nearly
zero-energy buildings,
• thermal modernisation of buildings, which reduces primary energy demand by 30% and is linked to the installation of
energy-efficiency enhancing equipment or renewable energy technologies,
• improving energy efficiency of production processes – e.g., replacing machinery and technological lines with equipment
that consumes at least 30% less energy,
• low-carbon transport – electric vehicles and charging stations, energy-efficient public transport, rail transport, and the
production of components, parts, and equipment for low-carbon mobility,
• circular economy – use of circular materials, product design aimed at reducing material consumption or increasing
durability, modularity enabling repair and recycling, and activities supporting selective waste collection and recycling,
• efficient wastewater and water treatment – including initiatives supporting resource-efficient water supply and sewage
treatment,
• protection of natural resources and biodiversity, including mainly sustainable agriculture practices confirmed by
recognised certificates such as EU Organic.
Table 12. Value of financing with positive social impact
PLN million
2025
2024
change (%)
preventing social exclusion
9
4
112.5%
health protection
115
349
(67.0%)
education
172
75
129.3%
basic infrastructure (e.g. water supply, sewerage)
2
43
(96.5%)
Total
297
471
(36.9%)
The area of financing with a positive social impact includes projects that, among others:
• prevent social exclusion, i.e., support the creation of jobs for vulnerable groups, prevent unemployment, and promote
entrepreneurship
• relate to healthcare, in particular activities of the public healthcare system and the production of equipment supporting
the mobility of persons with disabilities
• support the operations of public educational institutions
Since 2020, the Bank has been offering more attractive pricing for sustainable products, which significantly strengthens the
competitiveness of the offering. To this end, the Bank has introduced a formal catalogue of products and types of
investments with a positive environmental impact for individual Customer segments.
The classification of a loan as compliant with the Bank’s internal sustainable-finance methodology is verified by the ESG
competence unit and subsequently approved by credit decision-makers.
Financing linked to Sustainable Development
Sustainability-Linked Loan (SLL)
A Sustainability-Linked Loan (SLL) is a general or investment purpose financing in which the loan margin is partly linked to
the achievement of the company’s defined ESG objectives. Sustainability-Linked financing is provided according to the LMA
Sustainability-Linked Loan Principles. According to the guidelines, the indicators developed should address relevant areas
of the company’s impact on the environment, be verifiable and comparable. These may include the reduction of emissions
of greenhouse gases or other pollutants, the certification of raw materials, the reduction of social inequalities in the
workplace such as equal access to managerial positions for both genders or the gender pay gap indicator.
Examples in 2025:
• Syndicated loan for the Woodeco Group (a producer of wood-based boards) with a total value of EUR 155 million.
Woodeco Group and the Bank, acting as Sustainability Coordinator, jointly agreed on a set of indicators, including:
reduction of direct greenhouse gas emission intensity, increased use of recycled wood raw material in chipboard
production, ESG-based supplier assessments, and improvement of the company’s EcoVadis ESG rating.
• Financing for the Iglotex Capital Group in a bank consortium with a total value of PLN 84.9 million (BNP Paribas share:
50%). The funds may be used to finance investments in automation at the Skórcz plant, improve efficiency and reduce
emissions at the Tarnów facility, and partially support ownership decisions related to the Group’s development. The Bank,
acting as Sustainability Coordinator, supported the Customer in defining ambitious ESG targets: reduction of CO₂
emissions in Scopes 1 and 2 in production activities, reduction of CO₂ emission intensity in Scopes 1, 2 and key categories
of Scope 3 in distribution activities, and improvement of the EcoVadis ESG rating.
ESG Rating-Linked Loan
An ESG Rating-Linked Loan is a general purpose or investment loan in which the margin is partially linked to the
improvement of the borrower’s ESG rating. This solution is designed for Customers who want to develop and improve the
quality of sustainability management and reporting of ESG indicators in the company. In order to promote the concept and
functionality of ESG ratings to Customers, the Bank has partnered with EcoVadis, a global ESG rating agency.
Examples in 2025:
• investment loan for Młyny Kapka Sp. z o.o. (a family-owned company producing flour for corporate clients and the retail
market) amounting to several dozen millions of PLN for the construction of a grain mill together with equipment,
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54
• loan for Job Impulse Polska (one of the leading temporary employment agencies, specialising in recruiting and hiring
workers, including foreign nationals, for the industrial, logistics and services sectors) in the amount of PLN 15 million.
ESG-Linked Factoring
ESG-Linked Factoring is sustainable factoring in which commercial terms are partly linked to improvements in a company’s
ESG indicators or ESG rating.
BNP Paribas Faktoring Sp. z o.o., in cooperation with the Bank, signed an agreement with Raben Logistics Polska Sp. z o.o.
for the amount of PLN 140 million. The indicators applied in the transaction relate to the highest standards of carriers’
truck fleets, the calculation of carbon footprints by carriers, and the provision of information by carriers regarding their
sustainability policies and practices. This transaction was awarded in the PolSIF Award competition in the category of Best
Sustainability-Linked Financing.
Green Loan
Green Loans are loans used for investments that have a positive or significantly reduced negative environmental impact.
A Green Loan can combine several environmental objectives, such as an energy efficiency project, RES installations or the
construction of nearly zero-energy buildings. Financed investments can additionally be described in a Green Loan
Framework based on the LMA Green Loan Principles and validated by a Second Party Opinion.
The Bank is an active player in the commercial property financing market, supporting projects in various segments. When
selecting projects, we pay great attention to all environmental and social aspects, seeking to focus on those transactions
that have a significant positive impact on the environment.
Examples in 2025 :
• Financing of EUR 31 million granted to the Polish Logistics (UK) LLP structure managed by REINO IO Logistics, whose
investors include Grosvenor DPI, REINO Capital and IO AM. The investment will feature high energy efficiency, meeting the
technical criteria of the EU Taxonomy and achieving a BREEAM certification at the “Excellent” level.
• Financing of EUR 33.5 million for Accolade, a company developing the modern logistics park Park Szczecin Trzebusz. The
investment will feature high energy efficiency, meeting the technical criteria of the EU Taxonomy and achieving a BREEAM
“Excellent” certification. The financing was granted on the basis of Accolade’s Green Finance Framework, whose
alignment with the Green Loan Principles and the EU Taxonomy was confirmed by Sustainalytics.
Investment in renewable energy sources
We finance projects that involve renewable energy sources (RES). These include wind power plants, agricultural biogas
plants, small hydroelectric plants and photovoltaic installations. The Bak finances micro RES installations as well as mid-
and large-scale RES projects.
Cooperation with banks
ELENA (European Local Energy Assistance)
Until the end of July 2025, the Bank continued its cooperation with the European Investment Bank (EIB) under the ELENA
Programme, which supports energy efficiency improvements for SMEs (small and medium-sized enterprises) and MidCAP
companies (entities with more than 250 and fewer than 3,000 employees) – ELENA EEFFCB. Nearly 600 SME/MidCAP
companies were covered by the support programme, carrying out energy efficiency investment projects with a total value
exceeding PLN 350 million.
Beneficiaries of the programme received a subsidy of 90% of the cost of preparing technical documentation, which may
include: a preliminary simplified technical assessment report (a document that the Bank offers as the only bank on the
Polish market) and/or an energy audit in basic or extended version.
InvestEU guarantees from the European Bank for Reconstruction and Development (EBRD)
On 12 May 2025, the Bank concluded a portfolio guarantee agreement (a risk-sharing instrument) with the European Bank
for Reconstruction and Development (EBRD) under the InvestEU Green Portfolio Guarantees programme.
The beneficiaries are individuals – the Bank’s retail Customers – and the guarantee covers loans for the purchase and
installation of photovoltaic micro-installations, energy storage systems, heat pumps, and electric bicycles. The Bank also
received technical assistance from experts in implementing this instrument.
Thanks to this agreement, the Bank will grant loans totalling up to EUR 100 million within three years from the date of
signing the agreement.
InvestEU guarantees from the European Investment Fund (EIF)
After signing in 2024 a portfolio-guarantee agreement with the European Investment Fund (EIF) under the InvestEU Fund
for up to EUR 105 million, in 2025 the Bank made InvestEU-supported products available to Customers. The agreement is
intended to increase the availability of financing for sustainable investment projects for startups and scaleups, micro, small
and medium-sized enterprises, small mid-cap companies, and housing associations in Poland. Based on the guarantee, the
Bank plans to provide up to EUR 160 million (approximately PLN 688 million) in new debt financing over a period of three
years. The EIF covers between 50% and 80% of potential losses in the created portfolio.
Preferential loan under the European Funds for Silesia 2021–2027 programme
In October 2025, the Bank signed an Operational Agreement with the European Investment Bank (EIB) concerning the
Financial Instrument under the European Funds for Silesia 2021–2027 programme.
Under the agreement, the Bank acts as a financial intermediary providing access to funds designated for preferential loans.
The offer will be directed to Customers carrying out investments in the Silesian Voivodeship aimed at improving the energy
efficiency of public use buildings, residential buildings, and enterprises. The loans will feature favourable interest rates for
Customers and the possibility of up to 30% principal forgiveness. Launch of the offer is planned for 2026.
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55
Loans granted in cooperation with Bank Gospodarstwa Krajowego (BGK)
Loans for the implementation of ecological investments leading to a reduction of primary energy consumption by at least
30%:
• Green Loan - within the framework of the FENG Operational Programme (European Funds for a Modern Economy 2021-
2027, Priority 3 Greening of Enterprises, Measure 3.01 Green Credit). The product is aimed at SME, Small Mid-Cap and
Mid-Cap companies. The correct implementation of the project gives the entrepreneur the opportunity to obtain an
environmental bonus from BGK for partial repayment of the loan up to 80% of the eligible costs.
In 2025, there were two editions of the Green Loan call for applications.
• Ekomax loan - the product is aimed at companies in the SME sector. The loans are covered by a free guarantee from BGK
and entitle the borrower to a subsidy of 20% of the loan used, once the investment has been implemented.
Sustainable financing offer for retail Customers
Offer
Implementation in 2025
Instalment loan
to finance green energy
sources
• more than 1,700 projects financed (mainly related to photovoltaics and heat pumps), with a total
loan volume of over PLN 60 million
• continued cooperation with market-leading RES companies with the offer of instalment loans
dedicated to the energy transition
Credit for Green Change
• over 6,000 loans in a total amount of nearly PLN 300 million (+35% year on year)
• enabling the financing of zero-emission cars, electric scooters and e-bikes, as well as home
charging stations for electric vehicles
Green Mortgage
• over 1,500 mortgage loans in a total amount of over PLN 760 million
• attractive loans for green homes - the entitlement document is the energy performance certificate
for the property, where the non-renewable primary energy demand indicator does not exceed 58
kWh/(m2*year)
Financing of low-emission
vehicles
• redefinition of the designation of car loans as green: from 2024, this includes only loans financing
PHEV, electric and hydrogen drives; from 2026, only zero-emission vehicles (electric or
hydrogen-powered) will be covered by the definition of “green”
• financing, in cooperation with dealers and second-hand car dealers, of 680 low-emission vehicles
for an amount of ~PLN 61 million
• promoting the NaszEauto programme through the product offering as well as informational and
educational materials
Supporting Customers in sustainable transition
The Bank’s key commitment to environmental responsibility is to support Customers in their energy transition. The Bank is
continually developing its range of products and services to help Customers make the transition to a low-carbon economy
and develop their sustainable and green investments.
Technical Expertise Team on Energy Transition
The Bank has a team of engineers who provide expertise to the Bank’s existing and prospective Customers in the field of
energy transition investments, including those relating to the change to a sustainable business model. The experts’ tasks
include the development of analytical methods and tools to support decision-making processes regarding the financing of
energy transition investments, the preparation of a substantive opinion on planned investments. The experts also identify
potential for sustainable financing such as the Green Loan, Ekomax Loan, SLL, ESG RLL or the Decarbonisation Loan. Their
role is also to present the offer while highlighting the benefits that such financing provides.
Sustainable Finance Team
The Bank also has a team of ESG and sustainable finance experts to support the business lines in structuring the ESG
component for Sustainability-Linked Loan and ESG Rating-Linked Loan transactions. Experts in the promotion of such loans
and coordinated loan transactions are in strategic dialogue with corporate Customers on sustainable business transition,
regulatory requirements and ESG challenges in supply chains. In 2025, the Bank continued its collaboration with EcoVadis,
an agency specialising in ESG rating.
Business meetings
In 2025, the Bank conducted a series of “Business Dinners” and “Business Lunches” with entrepreneurs, inviting both
existing and prospective Customers. The events were held in seven locations across the country. Bank experts discussed a
range of important topics related to corporate decarbonisation, sustainable financing, EU funds, and ways to improve
energy efficiency.
The Bank was also the main partner of the 25th anniversary of the Responsible Business Forum. The Workshop Day titled
“ESG in the value chain – a shared path for Customers, Suppliers and the Bank” took place at the Bank’s headquarters. The
meeting was co-hosted by experts from the Technical Expertise Team for Energy Transition.
Cooperation with Envirly
In 2025, the Bank continued its cooperation with Envirly, the provider of a platform for measuring and managing carbon
footprint and ESG reporting. For business Customers in the Micro and SME segments, the platform is made available free of
charge for measuring environmental impact in Scopes 1 and 2. The tool enables Bank Customers to calculate their carbon
footprint in line with international standards (GHG Protocol, ISO 14064-1), generate data for non-financial reporting, and
support the implementation of decarbonisation strategies.
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56
An important element of the cooperation involves activities aimed at building awareness and expanding knowledge among
the Bank’s Customers in the areas of climate transition, carbon footprint measurement, and the use of ESG data. These
activities include participation in industry events and the organisation of expert meetings where the Envirly tool and
market best practices are presented. Such initiatives help Customers better understand regulatory requirements, identify
emission reduction opportunities, and make informed business decisions.
These initiatives strengthen the Bank’s position as a leader in the provision of non-financial services, particularly in the
areas of ESG and climate transition, fully aligned with the Bank’s strategy.
Educational activities in support of Business Advisers
In order to guarantee the best service in the area of sustainable financial products, in 2025 the Bank:
• delivered training and consultation sessions to Advisors serving Business Customers,
• conducted the second edition of the ESG Development Academy in Business Banking, completed by 50 advisors,
• conducted the second edition of the Agro Academy in Business Banking, completed by 70 advisors; part of the programme
was dedicated to topics related to regenerative agriculture and carbon footprint,
• together with the Warsaw Banking Institute, an organisation specialising in financial education, continued the Level II
certification "Professional Business Advisor to Companies - Level II”.
As part of this training, more than 550 Business Banking Advisors expanded their knowledge on topics such as sustainable
financing and available European programmes to support business development.
Support for regenerative agriculture
The Bank, in cooperation with Klim GmbH – a European leader in decarbonising supply chains in the food sector – supports
agro-food companies and their suppliers in transitioning to regenerative agriculture and preparing for new ESG reporting
requirements. As part of the partnership, the Bank developed an ESG guide for companies in the food sector, while Klim
GmbH provides comprehensive support in reducing Scope 3 emissions through cooperation with raw material suppliers and
the implementation of regenerative practices at farm level.
The Bank plans to further develop its cooperation with Klim GmbH by offering Customers SLL solutions based on
decarbonisation indicators and supporting farmers in accessing more favourable financing conditions, facilitating their
transition to regenerative agricultural practices. More information about Klim GmbH’s offering and the environmental
impact of regenerative farming practices is presented in the Sustainability Statement, section Actions and resources in
relation to climate change policies (E1-3).
Activities to support Customers in the Food & Agro sector
The BNP Paribas Group has extensive international experience in servicing the Food & Agro sector, including as the
European leader in agricultural machinery lease financing. Also in Poland, we are a leader in financing this sector. We work
to popularise a responsible approach to food production and help implement the right tools for this.
AgroEmisja – greenhouse gas calculator
AgroEmisja allows a precise assessment of the emissivity of agricultural production. The first and only solution of its kind
available in Polish, it will be successively extended with new calculation models from 2021. Users can make calculations
for crop production, dairy production, as well as chicken and turkey broilers, pigs and beef cattle, and the water footprint
for crops. This enables farmers to better understand their environmental impact, but also sets new standards for the
industry as a whole.
The Agronomist.pl platform
The Agronomist.pl platform is an innovative way of building relationships and sharing knowledge. It is aimed at agricultural
producers, processors and food manufacturers who understand the need to change their business model and want to grow
in line with market trends, including, above all, sustainable production standards. The content of the Agronomist platform
covers the entire Food & Agro value chain with a particular focus on local communities.
In 2025, the platform’s content section has been enriched with new publications of material related to environmental and
social impact reporting in accordance with the CSRD for the food production value chain, as well as the Puls Agro series,
videos of experts on the current situation in the fields in different regions of Poland, and Food&Agro Sonar videos with news
from bank analysis on the food & agro industry.
In 2025, more than 209,000 users visited the platform.
Food & Agro sector partnerships
The Bank participated in the development of legislation at the national level on sustainable development and energy
transition through the Renewable Energy Council of the Lewiatan Confederation, working groups set up by the Ministry of
Climate and Environment as part of the Implementation of Industry Agreements, and groups set up by the Ministry of
Agriculture and Rural Development. At the same time, the Bank continued its cooperation with the Polish Sustainable
Agriculture and Food Association (ASAF) and its member companies. Educational initiatives were launched for women in the
Agro sector in collaboration with the Innovation Leaders Association.
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Solutions for selected groups of Customers in the Retail and Business Banking segment
Samodzielniak Account
Since 2020, the Bank has an offer aimed at parents, the Samodzielniak Account, and is running a series of educational
campaigns as part of its Mission Education project, which supports teachers and parents in building financial awareness
among the youngest.
At the end of 2025, the Bank was operating more than 86,000 Samodzielniak Accounts for under-18s using the offer under
the care of their parents or guardians.
Offer for Ukrainian citizens
For Ukrainian citizens living in Poland, the Bank offers options that facilitate the use of banking products. At the Bank,
Ukrainian citizens can easily open an Otwarte na Ciebie Account or a Konto na Teraz Account for refugees. The account
offers are designed for Customers who appreciate transparent and simple banking solutions.
For this group of Customers, the Bank also has a website and prepares advertising materials in Ukrainian. Customers can
also select the Ukrainian language when they call the Bank’s helpline.
In 2025, more than 35,000 personal accounts were opened with the Bank for Ukrainian citizens, bringing the total to
204,000.
Otwarte na Biznes Non-Profit Account
The Bank offers an account for non-profit activities, i.e. social or professional organisations whose basic services are free of
charge. The following can take advantage of this offer: housing communities, cooperatives, foundations, associations, local
government units, and other social and professional organisations.
Under a single agreement with the Bank, an organisation can get:
• current account in PLN,
• investment account,
• term deposit accounts,
• debit card,
• access to mobile and online banking systems,
• comprehensive support by a Banking Advisor,
• preferential terms for additional services,
The number of Non-Profit Otwarte na Biznes Accounts (Non-Profit Package) in 2025 was 46,800.
Measures to promote a circular economy and extend the life of products
• The Bank, through its retail partners, makes it possible to take advantage of electronics rental in a new sales channel - in
selected online shops, including iSpot.
• The Bank works with the fintech Plenti, which specialises in equipment rental offers. Previously, this company offered a
rental period of between one month and one year to users of its platform. Thanks to the involvement of the Bank and BNP
Paribas Group Service Centre, users of the Plenti platform can now use their electronics for two years, without having to
purchase them. Renting for two years reduces the cost of the service compared to an offer for a shorter period, and the
longer use of the equipment means less electronic waste and environmental burden.
mamGO Mobility Platform
mamGO is a marketplace built for collaboration between the Group and car dealers. The platform features offers from
dealers and vendors from all over Poland, and the Bank provides financing for the purchase with a loan, lease or rental.
The platform is a result of cooperation between the Bank and BNP Paribas Group companies operating in Poland: leasing
company BNP Paribas Leasing Solutions, BNP Paribas Group Service Center, which is responsible for the creation and
technological development of the platform, and Arval, which specialises in car rental.
In addition to the car offers, the website includes an information and education section, where the user can broaden their
knowledge of electric cars.
As part of mamGO, the Bank:
• promotes zero-emission vehicles by giving Customers the opportunity to select them easily and encouraging them to
consider purchasing an electric vehicle,
• educates Customers on the advantages of electric cars through articles on electromobility,
• provides information on available grant and subsidy programmes, e.g. under the My Electric Vehicle programme.
The Polish Alternative Fuels Association is a content partner of the mamGO blog.
Investing based on ESG criteria
The Brokerage Office provides Customers with sub-funds of investment funds managed by BNP Paribas TFI S.A. At the end
of 2025, there were 9 sub-funds on offer that included ESG factors according to the SFDR classification (Article 8 or Article
9).
The Brokerage Office also offers the sale of shares of funds run by various TFIs. Among these are 527 funds designated as
balanced funds (Article 8 and Article 9 of the SFDR).
According to legal requirements, Customers receiving investment advice on exchange-traded financial instruments and
investment funds are offered portfolios containing a minimum of 20% of instruments rated as balanced. This applies to
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local and foreign currency portfolios with different risk profiles. The Brokerage Office’s procedures use an assessment of
instruments (shares, bonds, ETFs) based on the BNP Paribas Group methodology.
For listed instruments, namely shares, bonds and ETFs, issuers and instruments that do not meet the BNP Group’s
requirements are excluded from the investment universe, thus limiting exposure to ESG sensitive sectors. These include
manufacturers of controversial unconventional weapons, companies in the pornography industry, tobacco industry, entities
producing asbestos fibres, selected chemicals, or trading in endangered animal and plant species.
Investment products in support of social and environmental objectives
Selected structured certificates in the Brokerage Office’s offering are issued under the Green Bonds Principles standard,
which means that the net proceeds of the issue are reallocated in whole or in part to Qualifying Green Assets. These assets
can include various forms of financing in selected categories such as renewable energy, energy efficiency or water
management, among others.
ESG sub-funds
BNP Paribas TFI S.A., as a financial market participant, with the launch of the ESG sub-funds, in compliance with EU
regulations, has implemented a number of measures to disclose information to end investors on the integration of
sustainability risks into the business. In particular, this includes the consideration of adverse sustainability impacts as well
as the topic of sustainable investment objectives (Article 8 SFDR) in the investment decision-making process. As of 30
December 2022, the disclosures have been expanded with new guidance in line with the regulatory technical standards so
that end investors can make informed decisions based on reliable data.
Available ESG sub-funds offered by BNP Paribas TFI S.A.:
• BNP Paribas Europejskich Obligacji Zamiennych,
• BNP Paribas Globalny Obligacji Uniwersalny,
• BNP Paribas Akcji Wzrostowych USA,
• BNP Paribas Akcji Azjatyckie Tygrysy,
• BNP Paribas Akcji Światowych,
• BNP Paribas Akcji AQUA,
• BNP Paribas Globalny Akcji,
• BNP Paribas Globalny Stabilnego Wzrostu,
• BNPP Globalny Strategii Dłużnych Uniwersalny.
A detailed description of all ESG products can be found on the website of BNP Paribas TFI S.A. (ESG - BNP Paribas TFI S.A.).
Key data on ESG investments and risks are included in the funds’ prospectuses, where all investment aspects are described
in detail, including ESG specifics.
Positive banking
Customer relations
The foundation of the Bank’s business is to build lasting relationships with its Customers based on transparency, integrity,
simplicity and sensitivity. The Bank wants to know what Customers’ current needs are, so it listens to the voice of the
Customer and, based on this, takes various measures to be a trusted business partner for Customers. For more information
on Customer relations, see Consumers and end-users (ESRS S4).
Accessibility
The Bank creates an ecosystem of solutions that provide every Customer with equal access to banking and utmost comfort
and simplicity of use.
The Bank adapts its Customer Centres architecturally to the needs of persons with reduced mobility. The Bank’s efforts are
confirmed by the Integration Foundation, which awards the "Barrier-Free Facility" certificate to buildings that have
implemented facilities for people in wheelchairs, with mobility impairments, who are blind, partially sighted or deaf, and
are adapted to the needs of seniors and people with young children.
Key achievements in 2025:
• 144 Customer Centres and the Bank’s Head Office building in Warsaw with the “Barrier-Free Facility” certificate,
• 195 Customer Centres with induction loops,
• 529 sign language interpreter calls - call time 25 hours.
Our accessibility initiatives are described in more detail in the section Consumers and end-users (ESRS S4).
Plain language
The Bank simplifies communication with Customers and formal documents in line with the Polish Accessibility Act. The
Bank employs 70 plain-language consultants: trained staff who simplify formal documents, product and service
information, messages, SMS communications, marketing texts and other materials addressed to Customers.
The Bank also offers employees training on the basic principles of plain language through an e-learning platform, with
more than 340 participants in 2025, as well as traditional in-person training sessions. In 2025, the Bank organised the
“Plain Language Day” conference for employees for the third time.
Representatives of the Bank participate in the working group on plain banking communication at the Polish Bank
Association. The Bank is a signatory of the “Agreement on the Standard of Language Clarity in Retail Banking Services”.
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Addressing social and environmental themes in communication
Pupil (My Pet) Card
Pupil (My Pet) Card is the first debit card in Poland designed for animal lovers, introduced by the Bank.
For many people, a dog or a cat is more than a four-legged companion – it is a member of the family. According to
research, as many as 52% of Poles take care of a dog or a cat, and spending on pet care is becoming a significant part of
household budgets. With pet owners and their everyday needs in mind, the Bank became the first in Poland to launch the
Pupil (My Pet) Card – a Mastercard debit card offering numerous benefits that combine the convenience of everyday
payments with real advantages for dog and cat owners. In mid-September, the media campaign “It must be love” was
launched, promoting the new product along with attractive promotions and discounts, including veterinary packages,
pet-care purchases and other services useful for animal guardians.
In addition, together with Customers and the BNP Foundation, the Bank donated approximately PLN 270,000 to the
Ratujemy.pl Foundation. Our Customers contributed PLN 133,000 through charity transfers, and the Bank doubled this
amount.
Mission Education and other educational initiatives
The Bank continues its interdisciplinary banking project Mission Education, which spreads knowledge in the community on
the topics of finance, cyber-security, ecology, entrepreneurship and psychology, with Bank employees having the
opportunity to conduct classes in educational institutions or for senior citizens. This social campaign includes two thematic
modules: Pocket Mission and Saving Mission, which fill a gap in the education system by providing children, parents and
teachers with valuable and engaging financial education content in the form of practical expert advice, podcasts,
developmental games, lesson plans. In September 2025, workshops were added to the project, combined with volunteering
for primary school d VII and VIII. The project is dedicated to educators of children in primary school grades I-VIII and
parents.
During the 2021-2025 campaign, 27,400 pupils from local kindergartens, primary and secondary schools participated in
financial education lessons delivered by the Bank’s staff and 3,400 teachers were involved.
Throughout the year, educational activities addressed to our Customers were carried out. As part of these initiatives, we
delivered educational communication focused on personal finance topics. We covered issues such as building healthy
financial habits, financial security, effective household budget management and preparing for periods of increased spending
– holidays, Back to School, Black Friday and December holiday expenses. The aim of these activities was to increase
Customers’ financial awareness and support them in making responsible and well-informed financial decisions.
In parallel, we conducted social impact communication encouraging Customers to participate in charitable initiatives. The
Bank informed them about campaigns such as pet food collections, support for the education of refugee children, the
Szlachetna Paczka initiative and the “Share Help” campaign. These activities aimed to promote pro-social attitudes and
build Customer engagement in helping those in need.
Housing communities – thermal modernisation
In 2025, the Bank actively participated in a series of 31 nationwide conferences dedicated to property managers and
housing communities, organised by the Polish Institute for Market Development. These events gathered nearly 2,500
participants, becoming one of the most important knowledge exchange platforms in the sector. In addition, the Bank
organised and took part in numerous meetings for local associations and organisations, supporting investment
development and expanding the knowledge of community managers and interested stakeholders in the area of improving
energy efficiency.
Key educational role
Presentations delivered by the Bank’s representatives were primarily educational and advisory. Bank experts acted as
guides through the complex process of energy transition in multi-family buildings. The main objective was to equip
managers with practical, substantive knowledge enabling them to carry out investments safely and effectively in 2026.
Comprehensive support for housing communities
During the presentation “Thermal modernisation and renewable energy investments – financing for housing communities”,
the Bank presented comprehensive building modernisation strategies, with particular emphasis on:
• BGK loans with thermal modernisation and renovation bonuses: a detailed explanation of the rules for obtaining subsidies
that significantly reduce the amount of capital to be repaid, which is crucial for protecting residents’ renovation funds
• RES grant loans: an overview of the benefits of installing photovoltaic systems and other renewable-energy solutions,
supported by grants covering a significant share of investment costs
• diversification of financing sources: education on combining different financial instruments, including funds from the
National Recovery Plan, to achieve the lowest possible cost of modernisation
By participating in these conferences, the Bank provided meaningful support to nearly 2,500 professionals across Poland,
equipping them with tools necessary to address rising energy costs and improve living standards for residents.
Education and support for the development of SMEs and Corporate Customers
In 2025, the Bank consistently supported the education of business Customers from both the SME and Corporate segments
in key areas of development. It organised webinars and educational activities dedicated to market, regulatory and
technological changes, EU funding, energy efficiency and cybersecurity, supporting responsible, safe and sustainable
business growth.
The Bank carried out activities including:
• a cybersecurity webinar for companies, supporting awareness building in the area of data protection and digital risks,
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• webinars and informational as well as promotional activities under the GO4founds programme, covering available EU
funds, effective application processes, call-for-proposal rules and preparation of investment projects,
• a webinar on regulatory changes related to the National e-Invoicing System (KSeF), helping companies prepare for new
reporting obligations and the digitalisation of financial processes,
• continuation of the article series in the ESG Forum of “Rzeczpospolita”, addressing topics related to financing the
transition, regenerative agriculture and decarbonisation,
• expert articles and media commentary, as well as participation in Customer meetings covering business development
topics and product solutions supporting companies’ daily operations,
• participation in a debate on sustainable business transition.
These activities aimed to educate Customers and support the responsible, long-term development of enterprises.
#WPŁYWOWI
In 2025, the initiative launched the previous year continued, encouraging residents of Poland to create a grassroots system
for collecting information on water cleanliness. By the end of 2025, we had distributed more than 10,000 floats. The 7th
edition of the rewards campaign is already underway. Measurements using the floats are now being taken worldwide – the
map with nearly 7,000 current measurements is available in the Aguard app. The topic of water cleanliness and the Bank’s
role was presented during this year’s Green Film Festival in Kraków.
Agroabsolwent Competition
The Bank continues its competition for the best thesis on modern agriculture, sustainable food production and the
agro-food industry. In 2025, we concluded the 7th edition of the competition. Its aim is to promote topics related to
progress, innovation and the development of agro-business. The awarded works present ideas for modern, environmentally
friendly activities in rural areas and agro-related enterprises, focusing on ecological practices, sustainable agriculture and
ESG.
Between 2019 and 2025, the competition attracted 293 students, more than 20 universities and 16 Partners.
Community involvement
The Bank has remained committed to local communities for years. In line with the POSITIVE pillar of the GObeyond strategy
2022-2025, the Bank aimed to have a positive impact on the social and natural environment, among other things. The Bank
wants to be an agent of positive change and a good neighbour open to local needs. The Bank focuses on tackling social
exclusion, supporting diversity and financial education. The Bank’s impact on society is reinforced by the BNP Paribas
Foundation.
BNP Paribas Foundation
Since 2006, the BNP Paribas Foundation has been running proprietary and partnership scholarship programmes, is active in
the area of environmental philanthropy, coordinates the Bank’s employee volunteering and cooperates with social
organisations, supporting them in a substantive and financial way. The BNP Paribas Foundation Council is chaired by the
President of the Bank’s Management Board and its members are representatives of the areas of the Bank and Group
companies most important for the Foundation’s activities.
The Foundation’s mission is "to boldly change the world to one where there is less inequality and where we can be at
peace with the future of our planet”.
BNP Paribas Foundation activities:
• promoting social commitment - employee volunteering and individual philanthropy by Bank employees,
• development of tools to support community involvement, e.g. salary deduction scheme, volunteering platform,
• strengthening cooperation with NGOs and experts working in the field of social exclusion, climate change and promoting
diversity,
• education programmes - equal educational opportunities and inspiring children and young people through scholarships
and development activities,
• environmental philanthropy programmes - protecting ecosystems and implementing our own activities with care for the
environment.
Activities of the BNP Paribas Foundation
Initiatives involving
employees
• Employee volunteering programme
• Individual philanthropy programme I support you all year round
• Competition for Volunteering Projects
• The Szlachetna Paczka campaign
• Action Good kilometres
• Action Two Hours for Earth
• Bank’s Local Ambassador Programme
• Local Grant Programme
Initiatives targeting
external stakeholders
• Scholarship and development programme Class
• MOGĘ programme
• Dream Up education programme
• Programme of Encounters with Music with the National Philharmonic Orchestra
• Rest Home for Young People Project with the OFFschool Foundation
• My Future Scholarship Programme with Our Home Society
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Actions for refugees
• Knowledge to Power tutor and scholarship programme with the Ocalenie Foundation
• Charitable donation to the Ocalenie Foundation
• Grassroots volunteering initiatives
Environmental
philanthropy
• Re:Generation programme with UNEP/GRID - Warsaw
• Evergreen Forests and Microreserves with the Natural Heritage Foundation
• Community Organisations for Climate initiative with the Donors Forum
Programmes and partnerships
Employee volunteering
With the support of the BNP Paribas Foundation, employees can tailor the form of involvement to their needs and
capabilities. The Bank and the Foundation support the implementation of their own initiatives, team volunteering and
participation in social actions coordinated by the Foundation in cooperation with NGOs. The Foundation runs a special
volunteering platform that enables the organisation of new and joining existing volunteer actions. Each person employed at
the Bank had 24 fully paid hours available for volunteering per year. At the same time, employees’ social activities are part
of the BNP Paribas Group’s international #1MillionHours2Help initiative, coordinated in Poland by the BNP Paribas
Foundation.
Individual philanthropy programme I support you all year round
Operating since 2017, the “I support you all year round” programme is a simple tool for voluntary salary deductions.
Regular contributions help NGOs plan their long-term activities. In 2025, just like in 2024, people working at the Bank
chose to support the Słonie na Balkonie Foundation and the Projekt Starsi Foundation. 422 people participated in the
programme. The financial support totalled over PLN 380,000 (including PLN 190,000 from programme participants and PLN
190,000 from the BNP Paribas Foundation).
Competition for Volunteer Projects
The Volunteer Projects Competition has been a key element of the Bank’s employee volunteering programme for 12 years.
All people working in the Group can submit initiatives that address the most pressing needs of local communities. Winners
receive up to PLN 5,000 to implement their ideas in cooperation with local community organisations. In addition, they can
count on substantive support from the BNP Paribas Foundation.
Competition for Volunteer Projects in 2025:
• 60 completed projects,
• 307 employees involved,
• 5,460 beneficiaries,
• 2,456 hours worked,
• over PLN 280,000 earmarked by the BNP Paribas Foundation for projects.
Szlachetna Paczka
Since 2018, the Bank has been a strategic partner of Szlachetna Paczka. During this time, the Bank has supported the
programme with PLN 11 million. The BNP Paribas Foundation runs the largest organised employee volunteering campaign
among companies for the beneficiaries of the Szlachetna Paczka. In 2025, as in previous years, we also made it possible for
Customers to support the Szlachetna Paczka. On the Bank’s website, we have included the possibility of making a quick
donation directly to the organiser’s account, i.e. the Wiosna Association. Thanks to the support of the Bank, the Foundation
and Customers, in 2025 the Szlachetna Paczka received support of nearly PLN 2 million.
Szlachetna Paczka in 2025:
• 115 people working in the Bank and Group companies were leaders of the Szlachetna Paczka,
• 136 families in need received parcels prepared by our volunteers,
• 2,185 volunteers from the Bank and Group companies,
• PLN 1,500 subsidy for each parcel from the BNP Paribas Foundation.
Dobre kilometry
Every year, the BNP Paribas Foundation organises the "Dobre kilometry" campaign, which allows employees to combine
physical activity with social commitment. For a month, kilometres covered on a bike, in a run or during other distance
sports are counted. The Foundation converts them into financial support, which goes to a social organisation selected by
employees in a vote.
Dobre kilometry in 2025:
• 214,508 kilometres covered,
• PLN 70 thousand donated to the Słonie na Balkonie Foundation,
• 1,200 people involved.
Two hours for the Earth
In April 2022, the Bank joined the celebrations of International Earth Day. On the grassroots initiative of employees with the
support of the BNP Paribas Foundation, the Two Hours for Earth campaign is organised annually. Our volunteers, together
with their relatives and colleagues, dedicate this time to cleaning green areas together. In 2025, 131 employees from all
over Poland participated in the action.
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The Foundation’s activities in the field of education
Scholarship and development programme Class
The Class is one of the longest-running scholarship programmes in Poland - it was initiated in 2003 by the Bank and has
been run by the BNP Paribas Foundation since 2006. Its participants are development-oriented primary school graduates
from smaller towns and from families with low income. The scholarship enables students to attend good general secondary
schools in six academic cities in Poland. Participants receive full financial support during their secondary school education
and a financial scholarship in their first year of university. They can also count on the support of the BNP Paribas
Foundation in their volunteering activities and benefit from holiday and integration trips. Over the course of more than 20
years, more than PLN 30 million has been allocated to the Class programme.
In 2023, the programme underwent a major strategic review. Based on the results, a pilot of a new MOGĘ programme
focused on strengthening social-emotional competences of young people was launched in 2024.
Scholarship and development programme Class in numbers:
• support for 897 graduates from 540 towns and villages (since 2003),
• 52 scholarships in the school year 2025/2026.
MOGĘ programme
MOGĘ is a programme that develops key competences essential for development (self-confidence, communication,
collaboration, taking on challenges, learning from mistakes, etc.) and provides young people with the support of wise adults
and peers, enabling them to discover and realise their potential. The programme is operated by the Civic Education Centre
Foundation. In 2024, its first pilot edition took place, involving 80 children.
MOGĘ in 2025 :
• 120 children in individual tutoring,
• 12 adventure groups,
• 2 summer camps.
Knowledge to Power tutoring and scholarship programme
Since 2016, together with the Ocalenie Foundation, the BNP Paribas Foundation has been helping children and young
people with refugee and migration experience from Syria, Iraq, Ukraine and Chechnya, among others. In 2018, the
foundations launched the joint scholarship and tutoring programme Knowledge to Power, which helps children from
refugee families find their way in the Polish education system and supports their social inclusion. Since 2019, the
programme has been implemented as part of the BNP Paribas Group’s European initiative for the integration of young
refugees. From 2021 onwards, BNP Paribas Foundation has been a strategic partner of the Ocalenie Foundation.
In 2025, in addition to the standard activities within the programme – such as regular meetings with tutors, tutoring
sessions, and educational or developmental events and outings – additional initiatives were undertaken to raise public
awareness about refugees and migration. The exhibition of works created by programme participants, titled “Dreams
Without Borders”, was presented in the autumn and remained on display for a month at the Warsaw City Library. The
exhibition of works created in 2024, titled “My Place on Earth”, was showcased again in the publicly accessible space of the
BNP Paribas Bank headquarters. It not only helped raise awareness among employees and visitors but also supported
fundraising efforts, including a charity transfer campaign involving Bank employees and Customers, which resulted in a
total of PLN 130,000 in additional support for the programme’s objectives.
Knowledge to Power in 2025:
• 100 young people participating in the programme (from 2018 - 220 people, many have been in the programme for several
years),
• 29 scholarships awarded - 19 academic and 8 aid,
• 71 committed volunteers.
Dream Up
Dream Up is an international programme of the BNP Paribas Group, operating in 29 countries and initiated and funded by
the BNP Paribas Foundation in Paris. Under the programme, the BNP Paribas Foundation in Poland, together with its
partner, organise professional music classes for disadvantaged children and young people. Their aim is not only artistic
education, but above all the shaping of social and emotional competences, building confidence in oneself and one’s
abilities, and discovering passions.
2,185
Group volunteers involved in the
Szlachetna Paczka campaign
422
employees participating in the
individual philanthropy programme
“I support you all year round”
26,602
hours dedicated to social
engagement
3,600
hours worked for local
communities by the Bank’s Local
Ambassadors
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In 2025, the BNP Paribas Foundation cooperated with the “For the Earth” Association as part of the fourth edition of the
programme (ongoing since September 2024). The Dream Up programme supported activities for girls from refugee
background families who form the Girls’ Drumming Group.
Dream Up in 2025:
• 12 programme participants,
• 114 hours of music workshops,
• 6 concerts on local stages during major events and celebrations, such as the Grand Finale of the Great Orchestra of
Christmas Charity, World Refugee Day, International Day of the Girl, as well as at festivals including the Two Riversides
Film and Art Festival, the Folkowisko Festival, and on local radio
Rest Home for Young People
In September 2023, the BNP Paribas Foundation became a strategic partner of the Rest Home for Young People programme
initiated by the OFF School Foundation. This is a programme in which secondary school students act as agents of change
and lead activities with their peers, based on scenarios prepared by experts and organisations.
The programme developed scenarios in seven thematic areas proposed by young people, including mental health, social
and civic engagement, finding one’s way in the labour market and artificial intelligence. We prepared a section dedicated to
financial education, which expanded the offer with six lesson plans focused on this topic. The project website has been
visited by nearly 90,000 people and the lesson plans have been downloaded more than 47 thousand times.
In 2024, the nationwide Rest Home for Young People - Home on Tour was launched to explore the real needs of young
people through dialogue involving them personally. The campaign was conducted in 10 towns in 2025. A “School of
Dreams” study was carried out, and its results were compiled into a report and submitted to the Ministry of National
Education. In 2025, another research project was launched, “School in Dialogue”, aimed at gathering insights into the
quality of intergenerational communication between students and teachers.
Encounters with Music
Since 2003, the BNP Paribas Foundation has cooperated with the National Philharmonic, and since 2011, it has been a
partner of the Encounters with Music concert series. These are “music classes”: mini-concerts accompanied by a narrative
which discusses various issues related to music in a professional manner that engages the audience to actively participate.
These concerts are held outside the Philharmonic’s home, in schools, kindergartens and community centres in smaller
towns and cities in several regions of Poland in order to increase access to high culture where it is difficult.
Encounters with Music in 2025:
• 1,498 educational concerts,
• over 260,000 people attending concerts,
• around 90 towns and villages visited.
My Future
My Future is a scholarship programme organised by Our Home Society and aimed at children and young people residing in
family-based and institutional forms of foster care, as well as independent alumni. Participants can receive financial
support to be used for their needs and passions in the amount of up to PLN 4,000 per child.
The BNP Paribas Foundation has supported the implementation of the programme since 2019 through its participation in
the scholarship committee and the substantive assessment of applications. The committee selected 80 scholarship
winners. In 2025, the Society received a PLN 100,000 grant from the Bank and PLN 20,000 from the BNP Paribas
Foundation. The Bank has been involved in providing assistance since 2008.
The Foundation’s environmental philanthropy activities
The BNP Paribas Foundation is committed to delivering programmes and initiatives in a sustainable and environmentally
responsible manner. It works for the climate through the protection and restoration of key ecosystems and education. In
2025, the BNP Paribas Foundation was a partner in three initiatives:
• Re:Generation (in partnership with the UNEP/GRID-Warsaw Centre) – protection of peatland ecosystems in the Biebrza
National Park, in the Bagno Ławki area. The active conservation measures will improve hydrological conditions across
an estimated area of around 6 hectares, which will also generate a climate benefit – increasing peatland moisture will
reduce carbon dioxide emissions resulting from peat mineralisation, and if optimal moisture levels are achieved, it may
even enable CO₂ uptake from the atmosphere. An additional effect expected over the next few years is the improvement of
habitat conditions for rare animal species, which will positively influence the level of biodiversity in the area.
• Eternal Forests and Microreserves (in partnership with the Natural Heritage Foundation) - as part of the “Eternal
Forests” project, we have protected 2 ha of forest in the Biebrza National Park buffer zone, which, by creating a carbon
storage through living and dead trees, will retain and permanently store carbon taken out of the atmosphere, at a rate of
approximately 150 tonnes of pure carbon per hectare of forest. In the "Microreserves" project, five protection zones have
been proposed for the lesser spotted eagle – a rare animal species found in an ecologically valuable region in southern
Poland.
• Social Organisations for the Climate (in partnership with the Donors Forum in Poland) – as part of an initiative bringing
together NGOs from across the country, more than 10 educational events were held to increase climate awareness:
expert workshops, networking meetings with experience sharing sessions, and webinars. In addition, member
organisations could benefit from individual consultations. A guidance document, “Climate Compliance”, co-created by
member organisations, was also published, offering a range of recommendations for climate-friendly organisational
management. The online knowledge base was continuously expanded, and progress in implementing the Social
Organisations for the Climate Declaration was monitored. In 2025, 13 new organisations joined the initiative, bringing the
total number of signatories to 63.
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Actions for refugees
In 2025, the BNP Paribas Foundation continued its support for refugees, including individuals affected by the armed conflict
in Ukraine.
Organisations working for refugees, people on the move, and minority groups, including cultural minorities, faced a
significant funding crisis in 2025, linked, among other factors, to the decision of the United States to suspend financing for
the United States Agency for International Development (USAID) and the resulting consequences in Poland. In response to
this situation, the BNP Paribas Foundation provided financial support totalling PLN 400,000 to five organisations, which
independently decided how to allocate the funds according to their current priorities. This flexible support model responds
to the real needs of the NGO sector and represents an important alternative to grant programmes with a limited scope of
activities.
The following organisations received support:
• Polish Migration Forum Foundation – supporting foreigners in Poland through psychological, legal, professional and
educational assistance,
• “Ukrainian House” Foundation – helping people with migration experience from Ukraine by offering legal, psychological
and integration support,
• “For the Earth” Association – supporting refugees in centres for foreigners and conducting global and environmental
education,
• Towards Dialogue Foundation – supporting Roma communities in Poland and combating discrimination,
• Lepszy Świat Association – implementing activities in the areas of human rights, global education and social assistance.
The BNP Paribas Foundation also actively participates in the international Tent Partnership for Refugees initiative, which
aims to support people with refugee backgrounds in entering the labour market. In 2025, the BNP Paribas Foundation
became a partner of a mentoring programme dedicated to women from Ukraine who are rebuilding their lives in Poland. As
part of the programme, 22 employees from the Bank and the BNP Paribas Foundation – mainly from management and HR
teams – served as mentors, offering participants individual support in developing professional competences, building
networks, navigating a new work environment and preparing to take up employment aligned with their skills.
Actions for local communities
Local Ambassador Programme
The Bank’s Local Ambassadors are a community of more than 150 people. The Bank’s employees have been active in their
local communities since 2018 and support foundations, associations and schools with grassroots initiatives. In 2025, they
worked a total of 3,600 hours (over 43,000 hours since 2018).
Local Grants Programme
The Local Grants Programme, one of the Bank’s most important social initiatives, allows us to support local communities
and NGOs. We particularly support activities that:
• minimise the social exclusion of children and young people from difficult backgrounds, seniors, and people with
disabilities,
• are directed towards the support and integration of refugees,
• serve to protect the environment and animals.
During the 15 editions of the Local Grants Programme to date, the Bank has awarded more than 1,100 grants worth more
than PLN 4 million.
Local Grants Programme in 2025:
• 100 grants for local community organisations,
• PLN 500,000 earmarked for grants.
Donations and sponsorship
Donations
Donations made by the Bank support civic development and activity, enhance the quality of life of local communities,
strengthen the social commitment of employees, and promote responsibility in the field of health and environmental
protection. When deciding to make a donation to an NGO or institution, we want to increase the effectiveness of the
implementation of its socially useful activities.
Table 13. Financial donations to NGOs made by the Bank in 2025
Category
Amount (PLN’000)
BNP Paribas Foundation
5,045
Beneficiaries of the Local Grants Programme
500
Organisations promoting social inclusion and diversity
520
Organisations supporting education and culture
2,090
Social partners
62
Strategic partnership with the Szlachetna Paczka
632
Organisations promoting environmental protection
276
Total
9,125
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Sponsorship
Our sponsorship policy is designed to build the brand and strengthen brand awareness. Through the sponsorship policy, we
create a positive image of the Bank. The direction of sponsorship activities is determined by the BNP Paribas Group’s global
sponsorship strategy. As part of this strategy, we promote culture, especially cinema and tennis. We sponsor tennis events
in Poland, film festivals, cultural, economic and technological events.
Table 14. Expenditure on sponsorship in 2025
Category
Amount (PLN’000)
Film events
7,746
Tennis events
0.5
Other sponsorship activities
1,452
Total
9,199
Film events
Cinematography is one of the most important pillars of BNP Paribas Group’s sponsorship strategy. The Bank is
implementing this strategy under the slogan #WeLoveCinema.
In 2025, the Bank took part in many film events, including:
• Mastercard OFF Camera International Festival of Independent Cinema – the largest independent film festival in Central
Europe. The Bank was a partner of the event for the seventh time.
• BNP Paribas New Horizons – a festival distinguished by its programme, dozens of international meetings and an
exceptional audience that gathers in Wrocław every summer.
• BNP Paribas Sopot–Zakopane Summer Cinema – the longest free summer film festival in Poland.
• BNP Paribas Green Film Festival – an international festival of environmental films. The Bank was the title sponsor of the
8th edition.
• BNP Paribas Two Riversides Film and Art Festival – a festival for connoisseurs of cinema and other arts. For the fifth
consecutive year, the Bank served as the title partner.
• BNP Paribas Warsaw SerialCon – the first series festival in Poland. The Bank was the title partner for the second time.
• UKRAINA! 10th Film Festival – the Bank, as a partner of the event, was promoted in Warsaw during the main programme
and in 14 cities across Poland.
Additionally, in 2025 the Bank:
• continued the “We Love Cinema” project – screenings of films from festivals sponsored by the Bank, organised for
employees at the Bank’s headquarters;
• partnered with the original project by graphic artist Andrzej Pągowski – “Has Anew”, presenting posters for all 25 films by
Wojciech Jerzy Has; the collection premiered at the BNP Paribas Two Riversides Festival;
• continued its cooperation with the Cinema City network, where it is, among others, a partner of IMAX cinemas and Ladies
Night screenings.
Tennis events
The Bank is part of the BNP Paribas Group, the largest sponsor of tennis in the world. Tennis, alongside cinema, is the
second most important pillar of the BNP Paribas Group’s sponsorship strategy. The Bank implements this strategy under
the slogan #WeAreTennis.
In 2025, the Bank participated in a number of tennis events, including:
• We Are Tennis Cup – Group employee qualifiers for the 8th international tournament for BNP Paribas Group employees.
The finals of the tournament took place at the Roland Garros courts in Paris,
• BNP Paribas Business Cup - a series of tournaments for amateur tennis players - business people, held in Częstochowa,
Gdynia, Katowice, Kraków, Poznań, Warsaw and Wrocław,
• XIX Beskid Cup - Polish Artists’ Tennis Tournament,
• over 20 local tennis tournaments for children and amateurs.
Other activities
BNP Paribas Young Talent
In 2025, the Bank continued its scholarship and development programme for young tennis players in Poland. In the third
edition of the programme, the Bank had 14 scholarship recipients under its care.
The Bank provides the scholarship recipients not only with a monthly financial stipend to support the development of a
player’s career, but also with various training courses, e.g. in public speaking, career planning, social media management,
cooperation with sponsors. Young tennis players also have the opportunity to participate in BNP Paribas Group
tournaments, e.g. on a wild card basis, as a sparring partner or as a participant in group training sessions. They have also
had the opportunity to go to the Roland Garros tournament. The Mariusz Fyrstenberg Tennis Foundation is the
programme’s content partner.
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Economy and technology events
In 2024, the Bank became a partner of several international events in Poland. During the congresses, the Bank’s
representatives shared knowledge and good practices in the areas of governance, finance, agro-business, energy transition
and sustainable development. They participated, among others, in:
European Economic Congress in Katowice – the Bank served as a main partner and as a partner of several discussion
panels: Europe’s Competitive Economy, Banks and ESG, VC and PE Funds, Polish Business in the World, Business on the
Green Path, Finance of the Future, the Green Food Industry and the Family Foundation.
European Financial Congress in Sopot – an event showcasing the extent to which the financial sector can support the
competitiveness and development of the EU and Polish economies, as well as the transition and security agenda, in
particular energy, digital, cyber and defence security, while also supporting Customers across the sector.
Environmental responsibility
Environmental responsibility is one of the Bank’s commitments under the GObeyond strategy in the POSITIVE pillar. For
years, the Bank has been committed to minimising the impacts of and addressing climate change. In the time horizon of
the GObeyond strategy, the Bank for Green Change Programme aggregated all the organisation’s environmental activities.
The programme consisted of:
• monitoring Customers and investments from an ESG perspective and implementing CSR policies, with a particular focus
on decarbonisation processes,
• developing our range of products and services to help our Customers make the transition to a low-carbon economy and
green investments (described extensively in Implementation of the strategy, Filar POSITIVE., section the Sustainable
financing),
• real changes in the functioning of the organisation, leading to the minimisation of the negative impact of operations on
the environment,
• educational activities aimed at employees in all areas of the Bank and external stakeholders, and establishing
partnerships and supporting pro-environmental initiatives.
As part of minimising the environmental impact of our operational activities, our priorities were to reduce CO
2
emissions,
implement new efficiencies in the workplace, use energy from renewable sources, and increase the proportion of hybrid
and electric cars in the banking fleet.
Reducing the carbon footprint
The financial sector plays a key role as a catalyst for economic growth, providing the capital necessary for the transition
and modernisation of enterprises. Owing to their position, financial institutions have a unique ability to shape sustainable
development pathways by supporting the transition to a low-carbon economy. Aware of the direct impact that financing
has on the economy’s emissions and on the natural environment, the Bank has introduced a number of ESG sector policies
and regulations covering, among others, the mining sector, coal-based energy, the fuel sector (in the area of
unconventional oil and gas resources) and the agro-food sector. Their aim is to reduce the emissions intensity of the Bank’s
portfolio and the climate impact of financed investments (for example, by not financing coal extraction or the combustion
of thermal coal). More information on this topic can be found in the Risks and Opportunities chapter, in the ESG Risk
section.
The Bank is intensifying its operational efforts to reduce greenhouse- emissions. One of the key objectives of the Bank’s
GObeyond business strategy – an objective that has been achieved and even exceeded – was the reduction of CO₂
emissions from operational activities. To achieve this, the Bank uses 100% renewable energy and undertakes initiatives to
reduce the carbon footprint of its buildings. It also considers the reduction of emissions associated with digital channels,
marketing activities, communication and IT processes. The Bank is also taking steps to promote sustainable mobility, and
nearly 100% of its fleet now consists of electric and hybrid vehicles. A detailed description of the Bank’s and the Group’s
activities in this area, including objectives and their implementation status, as well as information on energy consumption
and greenhouse gas emissions from Scope 1, Scope 2 and Scope 3 (category 6), can be found in the Sustainability
Statement, section Climate Change (ESRS E1).
Water
The water used at the Bank is sourced from mains water supply systems and, after consumption, is discharged into sewage
systems. The Bank uses water for domestic purposes - food and hygiene - and the scale of its consumption does not
generate a material negative environmental impact. Nevertheless, the Bank has consistently implemented solutions to
reduce water consumption over the years. Among others, aerators have been installed in taps, motion sensors have been
used, as well as electronic washing programmes which allow a significant reduction in the Bank’s water consumption. As a
natural consequence, the increasingly popular remote and hybrid work modes are also reducing water consumption.
Table 15. Water consumption in the Group
2025
2024
Water consumption (m
3
)
35,871
37,294
Table 16. Water consumption at the Bank
2025
2024
Water consumption (m
3
)
33,860
36,987
Method of presenting indicators: data for locations where there was no meter data (lump sum, water covered by rent) was estimated based on average consumption/full-time equivalent in locations where
we know the exact consumption from meters - average 0.5m
3
/ full-time equivalent.
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Materials and waste
Minimising plastic consumption
Selected initiatives of the Bank to reduce plastic consumption:
• since 2019, the Bank has not ordered single-use plastic accessories or water in plastic bottles,
• employees can use water dispensers, glass carafes and glasses,
• in the canteen at the Bank’s Headquarters, reusable cutlery is used, as well as biodegradable or compostable cutlery and
packaging for takeaway meals,
• outdated promotional prints are destroyed safely by a company authorised to perform such services.
Minimising paper consumption
Selected initiatives of the Bank to reduce paper consumption:
• printing bulk mailings to Customers and marketing flyers on certified recycled paper (in cooperation with suppliers),
• the use of recycled lightweight paper at the Bank’s head offices,
• reducing the printing of correspondence and encouraging Customers to use digital versions (e-correspondence),
• digitalisation of an increasing number of processes,
• use of a special Autenti platform for electronic contract signing and digital document workflow.
Table 17. Group and Bank paper purchases in 2025
Group
Bank
Purchase of paper (tonnes), of which:
181.8
176.9
share of certified and recycled paper
99.7%
99.7%
Table 18. Paper purchase at the Bank
tonnes
2025
2024
Paper used for internal operations
88.4
94.3
Paper used for marketing purposes
34.1
38.0
Bulk mail
51.6
50.2
Other
2.7
1.6
Total
176.9
184.1
Waste segregation
In 2025, waste was segregated in all 4 of the Bank’s head office buildings and 304 Customer Centres and 7 Business
Centres, representing approximately 85% of all locations.
Waste segregation and disposal initiatives:
• coffee grounds recycling - from August 2022 until August 2025, we collaborated with EcoBean, a startup that recycles
coffee grounds into reusable products: straws, cups or pots. In 2025, 700 kg of grounds were collected, and more than
8,200 kg throughout the collaboration,
• automatic segregation at the Bank’s headquarters building in Warsaw - the Bin-e is an intelligent waste container that
automatically recognises and segregates waste,
• segregation of electro-waste - containers in the Bank’s head offices for batteries, light bulbs, caps, small electrical
appliances,
• the donation of 1,300 pieces and the resale for a "symbolic zloty" of 646 pieces of office furniture as part of cooperation
with public benefit institutions, another 324 pieces sold to Bank employees.
Community-based employee initiatives
We support the environmental engagement of the Bank’s employees. In 2025, the following initiatives were implemented by
employees through collaboration with the Administration Office:
• 150 birdhouses prepared in cooperation with the SPES Association for People with Disabilities,
• 1,000 trees planted in cooperation with the Katowice Forestry Commission,
• Green Exchange Bank - dedicated space in the Bank’s headquarters in Warsaw, Katowice and Kraków for the exchange of
books and potted plants,
• fourth edition of the "Commute to work by bike" competition – in 2025, the Bank’s employees cycled a total of more than
18,000 km,
• Safe Journey picnic - road safety education and eco-workshops for employees and their families,
• participation in the Two Hours for the Earth campaign in Katowice, Kraków and Warsaw.
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Pillar STRONGER
Pillar description
Dynamic and, above all, effective growth will not be achieved without improving internal processes and a large-scale
transformation of the IT area, using modern information technologies, such as cloud computing or open banking. The Bank
invested a total of approx. PLN 1.5 billion by the end of 2025 according to the strategy in technological improvements,
aimed at supporting business development and doubling the pace of implementing new solutions. A thorough change of the
technology used in the Bank enabled business scaling, as fast and cost-effective scalability is the basis of a modern digital
bank and allows to go beyond the framework of traditional banking services.
The Bank is implementing an operational model focused on quality and is striving to optimise all key end-to-end processes.
For this purpose, process mining tools, robotic process automation (RPA) and artificial intelligence are used.
The Bank also increases the use of the potential of the data. With the aid of advanced analytical tools that utilise modern
technologies such as cloud computing, big data, and artificial intelligence in decision-making processes, the Bank aims to
support its business development, enhance service quality, and bolster operational efficiency.
The fundamental assumption of the strategy is to maintain a safe and optimal capital and liquidity position and to meet
the minimum regulatory requirements.
The Bank’s intention, defined in the GObeyond Strategy, to distribute a dividend at the level of 50% of net profit in 2025,
was fulfilled. In accordance with Resolution No. 7 of the Annual General Meeting of 15 April 2025, the Bank allocated
approximately 50% of its net profit for 2024 to dividend distribution (DPS: PLN 7.86).
Strategic commitments and their implementation
Indicator
Strategic Objective 2025
Implementation 2025
Total investments in technology by 2025
PLN 1.5 billion
PLN 1.5 billion
Optimisation of all key end-to-end processes*
156 processes
114 processes
Increase in efficiency of operations [vs 2021]
>10% per annum
+19% per annum
Number of use cases using artificial intelligence or
advanced data analytics
>200
99
Dividend payout ratio
50%
50%
* Target for process count increased from 38 to 156 according to the new Process Architecture organisation
Digitalisation and innovation – IT strategy
Implementation of the IT strategy
In 2022, the Bank began the implementation of the GObeyond strategy, aiming to become the digital bank of the future; it
initiated wide-ranging actions in the technological field, defining them within the framework of strategic actions named
IT@Scale. In 2025, the four-year implementation of this strategy was completed, resulting in a comprehensive
transformation of the Bank’s technological ecosystem.
Over the past four years, we have significantly increased the maturity of our IT processes and services: the annual number
of IT incidents decreased by 92%, and the average downtime of critical services fell by 74%, demonstrating a substantial
improvement in the stability and quality of our systems and services. As part of the IT ecosystem modernisation, we
systematically reduced technological debt. The most important initiative in this area was the transformation of the Bank’s
core system, where we developed two new product factories – the Payment Factory and Customer360. These will
ultimately replace a large group of outdated applications. We also guided the Bank through major regulatory changes and
developed the foundations for a long-term core banking strategy.
We ensured the Bank’s digital resilience by continuously developing and improving cybersecurity tools and processes, as
well as expanding a modern multi-cloud environment. As a result, we maintained top-tier market cybersecurity indicators
and one of the most advanced private-cloud-based environments in Poland.
We created a secure internal environment for working with generative artificial intelligence (genAI), along with a
governance model supporting the adoption and development of new AI-based solutions. In 2025, more than 3,500 Bank
employees used the internal personal chat assistant, generating over 34.5 million queries, confirming the growing use of
these tools and the increasing efficiency of business processes. Our efforts in this area were recognised on the market,
earning us a distinction in the international Banking Tech Awards.
We focused on building a strong internal IT team by developing competences in cloud technologies, IT architecture
management, and the design and implementation of AI-based solutions. Employee turnover in the IT area decreased, while
the engagement score rose by 9 percentage points, confirming growing commitment and trust in the organisation.
Competence development is supported through a wide range of internal training programmes and development initiatives.
In 2025, the New Technologies and Cybersecurity area received several prestigious awards in the financial sector. The
Bank’s Vice-President and CIO of the area was named Innovator of the Year in the Leaders of the Financial World
competition. Our achievements in cybersecurity were particularly recognised – we received the Golden Cybersecurity Shield
Award in the 2025 Golden Banker competition and the Forrester Security & Risk Enterprise Leadership Award.
The assumptions of the IT@Scale strategy were successfully implemented over the past four years, and the direction we set
– along with our achievements – had already been recognised the previous year with the prestigious Forrester Technology
Strategy Impact Award. Over the last four years, we have built strong and modern foundations for the Bank’s further
dynamic growth, acquisition of new customers and increasing operational efficiency. Thanks to the elimination of key risks
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and the comprehensive modernisation of the technological ecosystem, we are well prepared to meet the ambitious
challenges defined by the new business strategy Accelerate 2030.
Implementation of the IT@Scale Strategy in 2025
INITIATIVE
Deep transformation of the core banking ecosystem (GOcore)
INITATIVE
DESCRIPTION
The transformation of the core banking ecosystem entails a comprehensive overhaul of the Bank’s
application architecture concerning the central system and systems directly associated with it. The
purpose of this transformation is to shorten the time-to-market, enhance the efficiency of IT solutions
and decrease the operational risk by doing the following:
• implementing IT platforms - scalable and reusable across various business domains (in the areas of
payments, products and Customer data)
• reducing the business logic and dependencies between the central system and other IT systems
ACHIEVEMENTS
• implementation of two regulatory changes – SORBNET3 and SWIFT – in the payments area
• advanced work aimed at migrating BLIK mass payments to the new Payment Factory platform
(following the earlier launch of a new BLIK payment product – BLIK Cheques)
• achieving readiness for the technical certification of the new SEPA Instant product (instant EUR
transfers)
• providing new customer data sources for determining the “golden record” on the Customer360
platform, migrating all planned customer-related business attributes to the new platform, and carrying
out advanced work on integration with the Bank’s internal systems
• developing the foundations for a long-term strategy and scenarios for the future modernisation or
potential replacement of the core banking system
INITIATIVE
Hyperautomation/ DevOps Platform & Agile Way
INITATIVE
DESCRIPTION
Improving the maturity of IT management processes and services through optimisation, standardisation
and automation
ACHIEVEMENTS
• introduction of automation and standardised tools supporting the efficiency of the software
development process, ensuring full transparency and increasing the effectiveness of infrastructure cost
management for individual systems, while reducing manual work
• execution of an advanced PoC for providing AI services on a container platform, enabling faster and
more cost-efficient implementation of AI Agents within the Bank
• enhancement of the security of banking applications through the creation, automation and
standardisation of the process for using third-party software
• implementation of the first scope of a new functionality allowing the Bank to track the carbon footprint
of individual systems
INITIATIVE
Building a data platform (GOdata)
INITATIVE
DESCRIPTION
Improving and implementing data solutions to create a scalable and secure platform ready to work in the
cloud, providing consistent and integrated data and offering analysis capabilities available to the entire
Bank
ACHIEVEMENTS
• establishment of structures and introduction of a governance model enabling the effective adoption of
generative AI solutions implemented in 2024, including:
a coding-assistant tool supporting software development work
a text2SQL tool enabling data processing using natural language
a personal-assistant tool
• continued development of AI competences and strengthening operational efficiency across the
organisation: training on managing and using genAI-based tools, as well as internal programmes
focused on identifying new genAI applications in internal processes
• enhancement of access control mechanisms for customer data in the Bank’s key system (the replica of
the core banking system)
INITIATIVE
Building digital competences (Engineering Culture)
INITATIVE
DESCRIPTION
Building the Bank’s digital competences through innovative reskilling and upskilling programs and
promoting knowledge about new trends and technologies
ACHIEVEMENTS
• GOtech Week and GOtech Week on Tour – subsequent editions of the Bank’s largest technology events
dedicated to employees. The initiative aims to promote knowledge of trends and new technologies
within the organisation, build business relationships and facilitate knowledge exchange
• GOtech Excellence Awards – the first edition of an internal competition for employees of the NT&CS
area. The goal is to highlight teams implementing innovative solutions with a strategic impact on the
organisation’s development
• UniversITy – the 7th edition of the internal upskilling programme offering training in new technologies
for Bank employees. Since the programme’s launch in 2022, more than 6,000 employees have taken
part in the training
• launch of a mentoring and development programme for female students of technical and finance
programmes at the University of Warsaw, supporting the idea of building diverse IT teams
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INITIATIVE
Elimination of technological debt (GOmodulo)
INITATIVE
DESCRIPTION
Ensuring that business units are supported by providing modern, scalable, and cost-effective system
architecture
ACHIEVEMENTS
• enhancement of processes and tools for managing the architecture of the Bank’s IT ecosystem,
including the identification and management of technological debt within the implemented Architecture
as a Product concept
• modernisation of the Bank’s IT ecosystem through the decommissioning of 11 additional outdated
production applications and two applications classified as critical technological debt
INITIATIVE
Cloud transformation (GOcloud)
INITATIVE
DESCRIPTION
Building and consistently implementing a hybrid-multi-cloud environment based on the benefits of
private and public clouds, in order to ensure IT service scalability and access to the latest tools and
technologies
ACHIEVEMENTS
• reduction of the average time needed to deliver infrastructure services to just a few minutes, and the
launch of 12 additional services on the One Click platform – introduced in 2024 and based on a
private-cloud environment – resulting in a significant decrease in manual work and an acceleration of
processes related to managing the Bank’s infrastructure resources
Online and mobile banking
In 2025, the Bank continued intensive development of remote channels, implementing a series of functionalities aimed at
strengthening its competitive position, lowering the cost of service delivery, raising the level of Customer service quality
and ensuring the highest security standards.
The Bank’s activities in the field of online and mobile banking focused on providing maximum support to Customers in
remote access to banking services and products.
The Bank consistently introduces additional self-service processes to its electronic banking offer, enabling Customers to
meet their most important needs daily without the need to visit a branch - from applying for additional products to after-
sales service - from any device and at a time convenient for them.
Key changes in the systems and offerings for retail Customers in 2025
Payments
• option to save mobile top-up templates
• for SORBNET transfers, the option to execute a transfer after 15:00 in D+1 mode
• development of SEPA, SWIFT and TARGET2 international transfers, along with returned information on sender/recipient code
fields in the transaction history
Loans and cards
• option to sign a credit card agreement with the Customer using a mobile signature in the GOmobile app
• enabling the display of post-transaction balances in the transaction history for credit cards
• extension of the credit term
• making the process for selling consolidation loans available through electronic channels
• changes to mortgage loan applications:
application for partial loan repayment
application for full loan repayment
Investment and savings
• new FATCA questionnaire
• addition of documents containing key information for investment portfolios
• new ESG questionnaire for Micro Customers
Customer Data / Customer
• questionnaire enabling Customers to confirm their data, helping us maintain the appropriate quality of our databases
• addition of an option to book an appointment at a Customer Centre in the Services tab for Individual Customers
• adaptation of digital channels to medium-level digital accessibility requirements
Accounts and cards
• implementation of the Dreams module and the new savings account
Security
• activation of the GOmobile app using an additional Voicebot security step and the introduction of the Panic Button which
immediately blocks online banking access
• improved management of the number of applications and the activation of mobile authorisation
• enhancement of the remote account opening process with new functionalities in Customer data verification modules
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The development plans in the field of online and mobile banking is based on the voice of the Customer. Regular feedback,
for example, through a Customer satisfaction survey, allows us to more efficiently identify the advantages and
disadvantages of the services offered and better understand Customer needs.
The security of Customers is a fundamental element of the Bank’s electronic banking development strategy, which is why
the GOonline system has been equipped with additional mechanisms to prevent the potential effects of unauthorised
access. The Bank conducts campaigns promoting modern methods of authorisation and responsible use of remote channels.
Table 19. Data concerning Retail Customers
Detailed list
System name
31.12.2025
31.12.2024
change %
Number of Customers / users using online banking
GOonline
645,191
668,039
(3.4%)
Average monthly number of transactions in the
online channel
GOonline
2,540,606
2,794,421
(9.1%)
Number of Customers / users using the mobile
application (GOmobile)
GOmobile
1,341,144
1,260,673
6.4%
Number of Customers / users using mobile banking
(mobile devices)
GOmobile+
GOonline
1,423,898
1,355,489
5.0%
Number of Customers / users using only the mobile
application (GOmobile)
GOmobile
944,368
875,571
7.9%
Number of Customers / users using only mobile
banking (mobile devices)
GOmobile+
GOonline
1,083,047
1,006,328
7.6%
Key changes in the systems and offerings for business Customers in 2025
GOonline Biznes
• implementation of the new Cards module and launch of the Debit Card Application
• addition of a tab in the account details view presenting the account balance interest rate history
• migration of the Import Letters of Credit module in the Trade Finance panel to the new system version, new functionalities:
a summary of all open letters of credit (broken down by currency)
flexible search and additional filters (e.g., by users)
inclusion of SWIFT field numbers in the names of individual fields in applications
key information and actions available directly from the lists of letters of credit, orders and payments
the option to add new fields in orders, including country of origin of goods and comments for the bank
Key changes in the systems and offerings for business Customers in 2025
• implementation of a new mechanism for generating statements (daily and monthly), preventing the creation of statements for
accounts where the Bank detects discrepancies in balances or transaction counts. Statements generated with errors are
suspended until corrected, after which the corrected statements are automatically restored and available for download
• addition of new sections in the international transfer form for identifying the beneficiary in a non-EU country (Organisation
Identifier and Private Identifier)
• extension of the list of beneficiary identifiers in the SEPA transfer form
• implementation of a mechanism verifying the validity date of identity documents (no possibility to authorise or send transfers in
online or mobile banking if the document is expired)
• availability of export templates compliant with ISO20022 for the formats “Bank Statement XML V2 (camt.053.001.08)” and
“Transaction History XML V2 (camt.052.001.08)”
• introduction of the CAMT (xml) preview function, enabling graphical display of the contents of files generated in xml format
(camt.052.001.08, camt.053.001.08)
GOmobile Biznes
• addition of the Cards module
• addition of new sections in the international transfer form for identifying the beneficiary in a non-EU country (Organisation
Identifier and Private Identifier)
• extension of the list of beneficiary identifiers in the SEPA transfer form
Table 20. Data concerning Corporate and SME Customers
Detailed list
System name
31.12.2025
31.12.2024
change %
Number of Customers actively logging in
GOonline Biznes
114,613
117,260
(2.3%)
Average monthly number of transactions
GOonline Biznes
7,381,154
6,835,064
8.0%
Number of Customers/users of the mobile
application
GOmobile Biznes
40,863
34,881
17.1%
Bank cards
BNP Paribas Bank Polska S.A. collaborates with Mastercard and Visa in issuing and servicing payment cards. The card
portfolio includes debit cards, credit cards, and cards with a delayed payment date.
The number of issued cards as at 31 December 2025 amounted to 1,899,000 and was 308,000 lower than in 2024. The
recorded decline in the credit and debit card portfolio results from the termination of inactive agreements and the
implementation of KNF recommendations (AML and KYC processes) regarding the update of identity documents.
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The Bank is pursuing acquisition activities to increase the number of cards and accounts. Current promotions require
Customers to participate with transactions in order to meet bonus sales. Active card use is promoted in the Priceless
Moments programme, through which Customers earn points for each card payment and can then redeem them for
rewards.
Under the current debit card account offer, Customers may:
• open a Moje Premium Account with a dedicated Moja Premium Card or Multi-Currency Card,
• open an Otwarte na Ciebie Account with the possibility of issuing four cards (Otwarta na Dzisiaj, Otwarta na eŚwiat,
Otwarta na Świat, and Multicurrency Card),
• take advantage of the Family Banking offer with the do Dorosłości Card issued to 13-18 year olds and the Samodzielniak
Card issued to children aged 7-13,
• benefit from the dedicated offers of two new cards, the Visa Film Card, the Visa Tennis Card, and the new Pupil (My Pet)
Card.
• In the Moje Premium and the Konto Otwarte na Ciebie Account offering, Customers can receive not only a physical card
but also a mobile card. For each business segment, the Bank offers a full range of credit cards. The following initiatives
deserve particular recognition in 2025:
• combining credit card distribution with a term deposit,
• acquisition campaigns offering gift card benefits (Allegro, Biedronka) and money-back mechanisms,
• promotion of the “Dobra karta” Mastercard credit card (promotional instalment plans, no-fee card, reduced interest rate),
which accounted for nearly 50% of new acquisition,
• portfolio campaigns aimed at activating and increasing transaction volumes generated with credit cards.
Table 21. Number of bank cards issued by the Bank
‘000
31.12.2025
31.12.2024
change y/y
‘000
%
Retail Customers’ debit cards
1,430
1,415
15
1.1%
Retail Customers’ credit cards
256
584
(328)
(56.2%)
Business debit cards
201
195
6
3.0%
Business cards with deferred payment
8
8
0
1.2%
Business credit cards
3
4
(1)
(15.0%)
Total
1,899
2,207
(308)
(13.9%)
* excluding cards for technical accounts
Support for innovation
The Open Innovation Office in 2025 continued activities in supporting product development and improving technological
and operational efficiency at the Bank
The main tasks of the team are:
• supporting the Bank’s units in obtaining and testing innovative solutions from start-ups and scale-ups,
• evaluating the potential and possibilities of implementing innovations,
• identifying new business models,
• educating and inspiring the Bank’s units in terms of innovative solutions,
• investing in innovative companies,
• implementing and conducting banking for innovative companies.
The Open Innovation Office collaborates with all units of the Bank, particularly with:
• the New Technologies and Cybersecurity Area - jointly developing new products and promoting the spirit of innovation,
• SME and Corpo Sales Area - in the Banking for Innovative Companies project
Actions taken in 2025
Testing innovative solutions (Industry Tests) within the Polish Agency for Enterprise Development
programme
In 2025, for the first time, the Office Team initiated participation in the Polish Agency for Enterprise Development’s Startup
Booster programme and joined as one of the industry partners of the programme operator (the accelerator), Huge Thing.
The Startup Booster programme aims to connect corporations (technology recipients) with innovative young companies
(startups; solution/technology providers). In practice, this involved mapping the Bank’s current internal challenges and
selecting several of the most important ones from the organisation’s perspective. Huge Thing then searched for startups
capable of addressing these challenges and, during a six-month acceleration programme, carrying out a Proof of Concept
under the guidance of experts from both the Bank and Huge Thing. The selected startup receives a non-repayable grant of
up to PLN 350,000 from the programme operator to be used during the six-month testing period.
The Office Team conducted a call for topics among Departments and Product Owners interested in testing their ideas
within the programme. Out of 15 submissions from diverse teams, 5 challenges were selected for further work.
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To address the first two challenges, two startups were selected in the second half of 2025, and agreements for Industry
Tests were signed with them (the results of these tests will be known by the end of March 2026). The selection of startups
for the remaining three Industry Tests will take place in 2026.
Education and exploration of emerging technology trends
In 2025, the Team continued its efforts to promote and educate employees on the latest innovation trends that can support
the strategy and objectives of individual Tribes and Product Owners.
AI Agents Academy Warsaw 2.0 – a training programme for practitioners planning to implement generative AI using the
Zowie platform, one of the leading startups in agentic AI. Participants included individuals responsible for designing and
deploying AI agents, automating customer service or operational processes, integrations and AI solution security. Sixty
participants, divided into twelve teams, worked on their daily challenges and ways to solve them using agents. More
information: AI Agents Academy 2.0 – Warsaw.
“UX Guild” – regular meetings covering a wide range of topics related to UX design, user research and emerging trends in
customer and digital product experience design. Guest speakers, often industry leaders, share their expertise and insights,
helping guild members develop their skills and understand the latest challenges in UX.
“Startup Coffee” – a series of events enabling employees from the sales network and risk area to meet some of the most
innovative and technologically advanced companies in Poland and their founders – our “Customers of tomorrow,” who are
transforming the world and can also support our own transformation. Six additional meetings were held with founders of
companies such as Riffsec and Pethelp.
“Startup Lovers Community” – an initiative launched in 2025 for employees interested in startups and the innovation
ecosystem. The community receives dedicated monthly newsletters featuring key market updates, articles and industry
reports, as well as special opportunities such as access to conferences and sector events.
Promoting an innovation ecosystem
We support innovative companies with financial products and a dedicated team of experts
The Open Innovation Office team continues to acquire and provide banking services to innovative companies at different
stages of development in collaboration with the SME and Corporate Customers Division. In addition to financing offers, we
offer young, dynamically growing companies a full range of banking products - so far available only as part of Corporate
Banking. We focus primarily on building long-term relationships with innovative companies and their investors, and looking
for new development opportunities for them and a holistic support for development, which is why private and investment
banking experts also joined the team. We already cooperate with over 200 innovative companies and their founders. Our
goal is to make the Bank the financial institution of first choice for fast-growing innovative companies.
In the second half of 2025, the Office Team launched a dedicated credit facility for innovative companies (working capital or
investment loan) – the InvestEU Loan – secured by a guarantee from the European Investment Fund (EIF). The purpose of
the EIF support is to provide financing to enterprises whose risk profile is not always acceptable to private financial
institutions, thereby contributing to strengthening the competitiveness of the EU economy. The EIF guarantee line of EUR
25 million will enable the creation of a credit portfolio worth EUR 35 million. The InvestEU Loan is intended for companies
in the SME and Commercial segments that meet innovation criteria (e.g., VC fund in the ownership structure, high R&D
expenditure, new technologies, modern products, etc.). The maximum loan amount per client is up to EUR 7.5 million, and
the guarantee covers up to 80% of the financing amount for companies outside Warsaw and 70% for companies based in
Warsaw. The EIF limit will be available until April 2028. More information: Kredyt z gwarancją InvestEU – nawet do 7,5 mln
EUR na rozwój firmy - BNP Paribas Bank Polska S.A.
Continuation of cooperation with the Polish Development Fund (PFR)
We continue to develop digitalisation pathways for small and medium-sized enterprises (SMEs) together with the Polish
Development Fund. We joined the “Cyfrowa Wyprawka” initiative, which supports SMEs in their digital transition. The
programme consists of six steps designed to help companies digitalise their operations. Thanks to PFR’s support,
participants gain access to free advisory services, digital tools and educational materials that help them streamline
processes and increase their digital maturity. One of the key tools is the “Digital Maturity Test,” which enables
organisations to identify weaknesses and better understand the factors influencing their digital transition. As part of the
programme, our Axepta payment gateway was included on the PFR Digital Solutions Map among tools that genuinely help
entrepreneurs enter the digital world. Another element of the cooperation is a series of free webinars for entrepreneurs
titled “Cyfrowy Start.”
Partnerships
In 2025, the Open Innovation Office established new partnerships and continued existing collaborations, thanks to which
the Bank remains one of the most recognisable financial institutions within the startup ecosystem.
Partnership
Description
Startup Wrocław
An initiative of the Wrocław Agglomeration Development Agency, responsible among other things
for networking the ecosystem of startups, large companies and investors, as well as promoting
the successes of Wrocław-based startups. More information: Strona główna - Startup Wrocław |
Startup Wrocław
Endeavor Poland
Endeavor is a non-profit organisation bringing together technology entrepreneurs from around
the world. It provides founders with strategic support in scaling their companies, as well as a
platform through which they can share their knowledge and help other Polish businesses grow.
Endeavor also invests in entrepreneurs through its co-investment fund, Endeavor Catalyst. The
Bank’s Chief Innovation Officer is a member of the Founding Board of Endeavor Poland. More
information: Endeavor Poland - Dream bigger. Scale faster. Pay it forward
Startup Poland
Startup Poland Foundation was established in 2015 by a group of entrepreneurs from
fast-growing small and medium-sized technology companies, lawyers, academics and investors.
Today, Startup Poland operates as a strong organisation that integrates and represents the
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Partnership
Description
interests of young, dynamic businesses in Poland. More information: Strona główna - Startup
Poland
Emerging Founders
A collaboration network for founders of innovative companies scaling their businesses globally,
typically in the revenue range from USD 250,000 to USD 1 million and above. More information:
You will never grow alone - Emerging Founders
Entrepreneurs’
Organisation (EO)
EO is the world’s largest organisation for entrepreneurs, open to all founders of companies with
annual revenues exceeding USD 1 million. Its mission is to grow together by sharing knowledge
and providing mutual support, both in business and in private life. More information: Strona
główna - EO Poland
Carpathian Startup
Fest
In 2025, the Bank collaborated for the first time with the Rzeszów Regional Development Agency,
the organiser of Poland’s largest startup-focused conference, Carpathian Startup Fest, which in
2025 attracted more than 1,000 participants. The Bank served as an Event Partner and hosted
workshops dedicated to innovation financing.
“Positive Impact
Startups” report
The Bank has been co-creating the “Positive Impact Ecosystem” project with the Koźmiński
Business Hub for many years. In June 2025, Koźmiński Business Hub published another edition of
the “Positive Impact Startups” report. The aim of the report is, among other things, to highlight
companies implementing the most interesting initiatives. The reports include expert commentary
on the Polish positive impact ecosystem, as well as descriptions of the most noteworthy startups
of the year. They also showcase innovative solutions proposed by positive impact startups across
selected sectors – from construction, education and sustainable fashion to health and responsible
tourism.
Cybersecurity
In 2025, the Bank continued to strengthen its cybersecurity capabilities, focusing on education and awareness building
among both employees and Customers. As part of these efforts, a number of webinars, online courses and internal training
sessions were delivered to enhance teams’ competences in protecting against cyber threats. At the same time, information
campaigns targeted at Customers were carried out through the Bank’s website, social media, online meetings in the “Stay
One Step Ahead of the Hacker” series, nationwide educational events for seniors organised in cooperation with the Senior
Economy Congress, as well as messages in the electronic banking system regarding current fraud scenarios and principles
of safe banking.
The security dedicated section of the Bank’s official website (https://www.bnpparibas.pl/bezpieczenstwo), thoroughly
redesigned in 2024, continues to be developed as the primary source of BNP Paribas’ cybersecurity recommendations,
including responses to risks arising from international conflicts and global instability. The Bank consistently maintained
heightened oversight of its IT infrastructure, implementing modern technologies to ensure the highest level of data and
system protection.
Implementation of the strategy in 2025
INITIATIVE
Secure Tomorrow
INITATIVE
DESCRIPTION
Strengthening cybersecurity
ACHIEVEMENTS
• continued development of state-of-the-art anti-fraud systems using advanced technologies, including
artificial intelligence and machine learning mechanisms. These efforts focused primarily on increasing
Customer security in online channels through more effective detection of suspicious activity, fraud
attempts and false positives
• strengthening IT infrastructure security through the development of the Threat Intelligence tool and
reinforcement of network protection, including the use of cloud technologies; deepened cooperation
with the BNP Paribas Group in the area of knowledge exchange and unified cybersecurity standards
• expansion of anti-fraud systems preventing the theft of personal data and financial assets belonging to
the Bank’s Customers
• successful execution of a series of tests covering resource relocation, notification systems, crisis
scenario simulations and the recovery of key systems, including verification of their interoperability
with other electronic-banking channels
• further development of the PenTest Competence Centre to conduct internal penetration tests for critical
banking applications
• maintaining high security ratings from Moody’s “BitSight” and Mastercard RiskRecon
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Pillar TOGETHER
Pillar description
The Bank believes that an engaged and satisfied employee guarantees a high level of Customer satisfaction. Hence, it is
crucial to provide an environment that supports the development of employees, their activity and creativity, but also
accepts mistakes resulting from testing bold, non-standard solutions. To this end, the Bank promotes among its employees
such values (empowerment, cooperation, courage, simplicity and transparency) which in everyday work allow us to
dynamically respond to changing market conditions and contribute to the effective implementation of our strategic
ambitions.
In order to ensure greater operational flexibility and better alignment of products and services with Customer expectations,
the Bank operates in an agile working model, Agile@Scale with a high level of independence and decision-making power for
employees.
Strategic commitments and their implementation
Indicator
Strategic Objective 2025
Implementation 2025
Share of women on the Bank’s Management Board
[vs 2021: 22%]
30%
37.5%
Closing the gender pay gap [vs 2021: 7.3%]
<4.0%
3.7%
eNPS - employees Net Promoter Score [vs 2021: -9]
20
20
People working in Agile@Scale (in Tribes)
>1,300
~1,600
Good workplace
Our key objective is to continually build an organisation that is an exceptional place to work attracting the best candidates
from the labour market and nurturing motivation and performance among existing employees. Only committed and
effective employees, managed by exceptional leaders, acting in the spirit of agile and in line with the values of the
organisational culture will allow us to make a market success.
We want to achieve this through the continuous development of leadership as well as future competences among our
employees, enabling them to find their way and continuously develop in the current digital and changing times. A high
standard of leadership and qualified employees equipped with key competences and the values of the organisation are the
basis for us to create an exceptional workplace. All of this, supported by efficient and digitised HR processes, an attractive
employee offering and development opportunities, provides a complete picture of the organisation we are building. At the
same time, through our activities we support the transformation of the organisation into a more agile one, based on the five
values that are the pillars of our organisational culture.
Our values: empowerment, collaboration, courage, simplicity and transparency
Building an inclusive, values-based organisational culture is a key element of the Bank’s sustainability strategy and social
responsibility. Accordingly, the Bank is taking a number of measures to strengthen collaboration and support opportunities
for employees to realise their full potential while respecting diversity and equal opportunities. These actions have a
significant impact on the success of the organisation - its innovation and reputation in the eyes of stakeholders.
Implementing culture requires several key elements:
• Defining values and mission, including the introduction of policies that exclude any discrimination. At the Bank, we refer
to the BNP Paribas Group Code of Conduct, which is a guideline for adhering to ethical and responsible business
standards. We have defined our values: empowerment, cooperation, courage, simplicity and transparency, underpinned by
"MOGĘ". All this determines the attitudes and behaviours of every employee. Since 2022, these values have been included
in the evaluation process (EVP- Employee Value Proposition). They are embedded in the GObeyond strategy, and the
pillar #TOGETHER refers directly to the organisational culture as the foundation for a diverse and inclusive working
environment based on trust, courage and creativity.
• Involving leaders in the process of building and promoting values. Organisational culture is created by all people working
at the Bank through the manifestation of behaviours and attitudes driven by values. Additionally, we ensure that
managers at all levels are role models in this regard. In 2021-2022, we focused on building awareness and understanding
of the organisational culture - we conducted a series of workshops, podcasts, testimonials, webinars and inspirational
debates, and implemented a communication and visual campaign to internalise the five values and the foundation of
“MOGĘ” among all employees.
• Education and training – we deliver a range of educational activities - both development programmes and activities to
raise awareness of the importance of human rights in the broadest sense. In the implementation of values, between 2022
and 2024, we conducted a series of workshops - Value Meetings - for almost 4,000 employees, resulting in, among other
things, action plans related to improving the quality of the application of values in daily work.
• Monitoring and measuring progress – we regularly review the working atmosphere and the manifestations of behaviour
embedded in our values - we examine the realisation of each value in our daily work at the Bank (Pulse Check), as well as
using a regular feedback tool (Friday6), in which we observe, among other things, the behaviours that define the values.
Agile@Scale - a new operating model
The Agile@Scale transformation covers the part of the organisation responsible for developing and implementing products
(business, IT, support roles). The Bank is currently organised around products responsible for comprehensive processes and
IT systems.
The Agile@Scale operational model was implemented in January 2022 and covers 17 Tribes, 5 IT areas, 61 Products, 77
Chapters and 169 Squads. Since January 2025, the Beyond Agile working model (a model that goes beyond Agile) has been
extended to the retail distribution network and the Personal Finance area. Additionally, in the Operations and Business
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Support Area, a new work model was implemented, based on Lean methodology and Beyond Agile practices (circle-based
work). At the end of 2025, these working models (Agile@Scale, Beyond Agile, circle-based work in the Operations and
Business Support Area) included around 5,300 employees (approximately 74% of the total workforce).
By implementing the Agile approach, the Bank aims to achieve the following goals:
• FASTER - by reacting more quickly to changing Customer needs and market conditions, measured by a change in the Time
to Market, which shows how fast we can implement new solutions. In 2025, Time to Market improved by 16% year on
year.
• BETTER- by delivering innovative, high-quality products and services based on Customer needs, measured by an increase
in the NPS, which shows how Customers recommend the Bank. Thanks to the increased maturity of IT service
management and delivery processes, critical errors were reduced significantly (by 92% in 2025 compared with 2022), and
the downtime of critical systems was minimised (by 74% in 2025 compared with 2022).
• HAPPIER - through employee engagement, raising their competences, and attracting and retaining talent. The Pulse Check
employee opinion survey shows that, at the Bank level, nearly all metrics remained strong, supported by the Agile@Scale
and Beyond Agile ways of working. The eNPS score improved by 29 points, rising from –9 in 2021 to 20 in 2025, while the
employee engagement score increased from 63% in 2021 to 77% in 2025. Employee turnover in the retail branch network
(within the first 12 months of employment) decreased by 20 percentage points year on year.
As in previous periods, we5continued in 2024 to focus on optimising and facilitating processes and making ways of working
more consistent between Tribes and other units in the Bank.
Employee satisfaction survey
One very important goal of the Bank is to continuously build a friendly and engaging work environment. The main factor in
taking care of such an environment is regularly listening to the voice of employees and responding to the feedback
provided. The tool for collecting opinions is the Pulse Check survey. The survey was conducted in October 2025, and its
results are currently being analysed by managers, HR Business Partners, the Organisational Culture Team and the
Management Board.
The 2025 Pulse Check was the final survey conducted during the implementation of the Bank’s GObeyond strategy. We can
confirm that the targeted indicators were achieved – an engagement score of 77% (the strategic target for 2025 was 70%)
and an eNPS of 20 points (the 2025 target was 20)
Pulse Check eNPS
eNPS
2025
2024
Question:
How likely are we to recommend BNP Paribas Bank as an employer to our friends and
family?
20
27
Employment
Table 22. Employment structure in the Bank and the Group
Employment
Number of active employees
Number of active FTEs
31.12.2025
31.12.2024
31.12.2025
31.12.2024
Group – total
7,255
7,512
7,232
7,478
Bank, including:
7,112
7,378
7,092
7,353
Headquarters
4,420
4,620
4,402
4,598
Customer Centres
2,579
2,642
2,577
2,638
Mobile advisers
73
74
73
74
Brokerage Office
35
37
35
37
Trade unions
5
5
5
5
BNP Paribas Towarzystwo Funduszy
Inwestycyjnych S.A.
46
41
46
40
BNP Paribas Leasing Services Sp. z o.o.
10
13
6
7
BNP Paribas Group Service Center S.A.
87
80
88
79
Data expressed in terms of positions have been rounded to the full unit
Headquarters employees include all employees in the support areas.
Employees of the Customer Centres include all employees of the sales network, consisting of, among others, the Market Development Department, the Wealth Management Regions, the Corporate and SME
Banking Sales Network Division, and the Consumer Finance Sales Division.
Excluding technical posts. Technical FTEs refer to persons employed within the Group who are contracted for a specific FTE of 0.05, 0.0625 or 0.063 due to their tasks within the Group.
At the end of December 2025, the Group’s headcount expressed in full-time equivalents amounted to 7,575 (compared with
7,883 at the end of December 2024), and the Bank’s headcount was 7,426 (compared with 7,746 at the end of December
2024).
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For more information on the workforce structure, see the Sustainability Statement, section Own workforce.
In December 2023, as a result of negotiations with the trade unions, an agreement was signed on the rules for carrying out
group layoffs and on the Voluntary Redundancy Programme. The agreement was concluded for the period 2024-2026. The
group redundancies will involve the termination of employment contracts with up to 800 employees. This number includes
employees who will be offered new terms and conditions of employment though change notices. In 2025, 197 employment
contracts were terminated under the programme (in 2024, 164 employment contracts were terminated).
Remuneration
The Bank follows a rational, balanced and controlled remuneration policy, which is in line with our strategy, accepted level
of risk, standards and key values. The policy is based on clear principles and addresses good market practices in terms of
remuneration. Formally, the rules related to remuneration are set out in the "Collective Bargaining Agreement" and the
"Remuneration Policy for Employees of BNP Paribas Bank Polska S.A.". In addition, the Bank also has a remuneration policy
for persons who have a significant impact on the Bank’s risk profile.
Incentive schemes
Incentive systems (bonus systems) are designed to support the Bank’s strategy by rewarding employees for achieving their
targets. They are based on Management by Objectives (MbO), which means that an employee’s individual bonus is linked to
the level of achievement of his or her objectives - both quantitative and qualitative. In addition, the combination of
individual and team objectives indicates to the employee what level of performance is expected of him or her, taking into
account the Bank’s risk profile and attention to activities in line with the interests of the Customer.
The Bank has in place:
• a bonus system defining the rules for the award and payment of variable remuneration, including bonuses, to employees
working in positions with a significant impact on the Bank’s risk profile (persons with MRT status),
• sales and quality bonus systems, which have been adapted to the specific tasks performed in the individual business
lines, taking into account regulatory guidelines,
• operational and quality bonus schemes for specific groups of employees outside direct sales.
The Remuneration Committee and the Nominations Committee support the Supervisory Board in fulfilling supervisory
duties in management of workplace. They monitor and supervise the most important processes - succession plans,
employee career development, remuneration policy. The Committees prepare opinions and recommendations for the
Supervisory Board which concern, among others, the assessment of candidates for members of the Management Board and
candidates for members of the Supervisory Board, the terms of employment of members of the Management Board,
including the amount of fixed and granted variable remuneration. The Bank carries out an annual Compensation Review
Process; one of the significant criteria taken into account in this process is reducing the pay gap, for which dedicated funds
are allocated.
At the end of 2025, the pay gap, as expressed in the adjusted Gender Pay Gap, was 3.87This means that men’s wages were
3.7% higher than women’s wages in comparable positions. The indicator is a weighted average of the size of the various
employee groups. Compared to 2024, the ratio decreased by 0.1 p.p. The Bank’s strategic objective under the GObeyond
Strategy for 2022-2025 was to reduce the pay gap to below 4%.
Table 23. Adjusted Gender Pay Gap
2025
2024
Adjusted Gender Pay Gap (2025 target - <4%)
3.7%
3.8%
We calculate the adjusted gender pay gap for homogeneous employee groups to ensure transparency and consistency of
data. We have divided employees into groups by area of employment and grade level - this allows us to compare the
salaries of women and men who perform similar work. In calculating the indicator, we included all active employees with
more than one year of service with the Bank and who remained employed at the end of December 2025. We included total
salaries for comparable positions in the analysis.
7,255
active employees of the Group
7,112
active employees of the Bank
45%
women in the Group’s senior
management (B1+B2)
55%
women in the Group’s lower
management
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Diverse and inclusive workplace
In the Group, we create a diverse community for many talents. The inclusive organisational culture, which has been
consistently built for years, increases creativity, drives innovation, opens up new ideas, markets, Customers, builds a
business advantage, and thus contributes to the development of employees and the success of the entire organisation. We
base daily cooperation on trust and respect - we want everyone in our Bank to be able to express themselves, realise their
career aspirations, passions, feel appreciated and have a sense of influence.
Diversity management policy
The Bank’s "Diversity Management Policy" in force since 2016 promotes a work environment focused on respecting and
optimally utilising the potential inherent in the differences between employees. According to the Policy, diversity is
respected in every aspect of workplace management in the Bank. We strictly adhere to these principles during the
recruitment process, career development, and during training.
The Policy sets out rules of conduct for managing the risk of discrimination and for respecting diversity. We have
established the position of Diversity and Inclusion Manager, whose responsibilities include overseeing and coordinating
respect for diversity. There are two Diversity Officers at the Bank.
Employees who have experienced a lack of respect for themselves or others should primarily contact their supervisor or HR
Business Partner in this matter. If for various reasons this is not possible, they can also use other channels (described in
the Policy on dealing with violations of respect for others at BNP Paribas Bank Polska S.A.):
• mailbox: sprawypracownicze@bnpparibas.pl,
• anonymous reports (whistleblowing).
All reports are considered by the Employee Relations Team, while cases involving behaviours that may indicate the
occurrence of mobbing or discrimination, including harassment or sexual harassment, are directed for consideration by the
Employee Behaviour Standards Committee.
In 2025, 17 reports were investigated at the Bank, of which the Employee Standards of Conduct Committee was appointed
once due to the severity of the allegations made.
The complaints examined mainly concerned inappropriate relations with a superior or between colleagues. No behaviours
amounting to mobbing or discrimination were confirmed.
All reports were analysed with due seriousness, thoroughly, fairly, and while maintaining full confidentiality.
The perpetrators of all misconduct reported at the Bank suffered consequences appropriate to the misconduct, and those
affected received the necessary support.
Diversity and inclusion (D&I) management is part of the GObeyond business strategy for 2022-2025. In the TOGETHER
pillar, we focus on a culture of courage, agency, and diversity, as a basis for supporting efficiency and creativity.
Our commitments to a diverse and inclusive workplace (D&I):
• under the GObeyond Strategy, the targets included:
reducing the pay gap to below 4% in 2025, and
at least 30% women representation in management positions by 2025,
• increasing the employment of people with disabilities,
• monitoring of indicators relevant to D&I management, including, female vs. male participation in specific initiatives,
parental leave take-up, retention rates by gender,
• BNP Paribas Group’s cyclical survey on the Code of Conduct and diversity and inclusion,
• supporting grassroots employee initiatives for groups at risk of exclusion.
Supporting diversity is one of the commitments in the global BNP Paribas Group Strategy. The Group’s Management Board
is also involved, with measurable goals set in this area, cascaded down to individual countries. With the help of Group
leaders and Diversity Officers, countries implement their local challenges respecting local conditions and supporting the
potential of grassroots employee initiatives.
83 years
age of most senior employee
42 years
average age of employees
20 years
age of most junior employee
42 years
longest period in service
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Financial results
80 Financial results of the Group
99 Results of the business segments
103 Financial results of the Bank
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Financial results of the Group
Consolidated statement of profit or loss
The Group’s net banking income was PLN 8,184,962 thousand in 2025, up by PLN 432,246 thousand (5.6%) year on year.
Significant factors influencing net banking income in 2025 and in 2024 included macroeconomic conditions and the interest
rate policy of central banks, impacting among others Customers’ economic activity and the situation on the financial
markets. The key factors driving the Group’s results included:
• NBP interest rates. From October 2023 until early May 2025, the NBP interest rates remained unchanged (5.75% for the
reference rate). In 2025, the Monetary Policy Council (RPP) introduced six rate cuts, bringing the reference rate down to
4.00%. These reductions contributed to lower profitability of PLN loans with variable interest rates in 2025 compared with
2024. A potential continuation of rate cuts in 2026 would negatively affect PLN margins generated by banks,
• the monetary policy easing cycle launched by the European Central Bank in June 2024. By the end of July 2025, nine rate
cuts had been implemented, reducing the deposit facility rate by 200 bps (to 2.0%). These changes lowered the
profitability of variable rate loans granted in EUR,
• a strong liquidity position of Customers, leading to an increase in deposit volumes, enabling further growth in the scale of
operations,
• the absence of a negative impact on the 2025 net interest income from the amendment to the statutory mortgage
payment holiday scheme, which took effect in mid-May 2024,
• volatility in financial markets, including fluctuations in the PLN exchange rate against major currencies in the first half of
2025, driven among other factors by geopolitical conditions (including U.S. trade policy) and political uncertainty
(including the presidential election in Poland). This volatility increased Customer demand for hedging instruments,
positively impacting banks’ financial results,
• favourable market conditions and rising stock prices on the Warsaw Stock Exchange, combined with declining deposit
interest rates, which supported Customer interest in asset management and brokerage services and contributed to higher
fee and commission income for banks.
Net interest income, which is the biggest item of net banking income, stood at PLN 5,892,084 thousand in 2025, up by PLN
151,078 thousand (2.6%) year on year. Despite falling profitability of loans, this was possible thanks to gains on liquidity
invested in securities and financial instruments, improvement in interest income on hedge accounting, and optimised cost
of deposits.
The net banking income item to improve the most was net trading income, which stood at PLN 1,076,777 thousand in 2025
(up by PLN 211,725 thousand or 24.5% year on year). The improvement was driven among others by higher gains on
financial instrument transactions in asset and liability management, higher gains on margins on currency exchange and
derivatives transactions with Customers (including several large transactions with Customers in H1 2025), and improved
gains on equity investments.
The negative impact of the legal risk of court cases concerning foreign currency mortgage loans remains a significant factor
affecting the Group’s net profit. In 2025, thanks to gradual reduction of the portfolio and an observed decrease in the
number of new court cases, the charge to the Group’s results was PLN 498,751 thousand, down by PLN 296,977 thousand
year on year.
The quality of the loan portfolio remained strong in 2025, as confirmed by lower migration to Stage 3 and recovery on non-
performing loans combined with no additional provisions for expected future materialisation of the cost of risk in the
institutional portfolio (Post Model Adjustment), which had been set up in 2024. As a result, the negative impact on
provisions for expected credit losses on financial assets and provisions for contingent liabilities stood at PLN 174,499
thousand in 2025, compared to a negative impact of PLN 246,192 thousand in 2024 (improvement by PLN 71,693
thousand).
General administrative expenses, depreciation and amortisation stood at PLN 3,368,667 thousand in 2025, up by only PLN
16,858 thousand (0.05%) year on year, despite an increase in the total cost of the Bank Guarantee Fund by PLN 52,343
thousand (net of the BFG cost, total costs would have decreased by PLN 35,485 thousand, i.e. 1.1%). General administrative
expenses in 2025 were positively impacted by a review of the cost base, in particular the costs of advisory services,
including services provided by the Group, and the costs of legal advisory on the CHF mortgage loan portfolio.
A change of the corporate income tax rate under the Act amending the Corporate Income Tax Act and the Act on Tax on
Certain Financial Institutions adopted in Q4 2025 resulted in reevaluation of the deferred tax asset and liability using the
future tax rates. The positive impact of the reevaluation on the Group’s result as at 31 December 2025 was PLN 174,116
thousand, recognised by the Group in Q4 2025.
A positive financial impact of deferred tax, based on provisions against future payments relating to the cancellation of CHF
loans, was recognised at PLN 135,535 thousand in 2024.
The BNP Paribas Bank Polska Group generated a net profit of PLN 3,057,754 thousand in 2025, up by PLN 699,486
thousand (29.7%) year on year.
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Table 24. Statement of profit or loss
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Net interest income
5,892,084
5,741,006
151,078
2.6%
Net fee and commission income
1,261,469
1,249,458
12,011
1.0%
Dividend income
9,772
13,147
(3,375)
(25.7%)
Net trading income
1,076,777
865,052
211,725
24.5%
Result on investing activities
(2,340)
14,374
(16,714)
-
Result on hedge accounting
(11,161)
1,946
(13,107)
-
Result on derecognition of financial assets measured at
amortized cost
(19,698)
(35,739)
16,041
(44.9%)
Other operating income and expenses
(21,941)
(96,528)
74,587
(77.3%)
Net banking income
8,184,962
7,752,716
432,246
5.6%
Net allowances on expected credit losses on financial
assets and provisions for contingent liabilities
(174,499)
(246,192)
71,693
(29.1%)
Result on legal risk related to foreign currency loans
(498,751)
(795,728)
296,977
(37.3%)
General administrative expenses
(2,839,585)
(2,837,359)
(2,226)
0.1%
Depreciation and amortisation
(529,082)
(514,450)
(14,632)
2.8%
Operating profit
4,143,045
3,358,987
784,058
23.3%
Tax on financial institutions
(393,352)
(404,971)
11,619
(2.9%)
Profit before tax
3,749,693
2,954,016
795,677
26.9%
Income tax expense
(691,939)
(595,748)
(96,191)
16.1%
Net profit
3,057,754
2,358,268
699,486
29.7%
Net profit, net of credit holidays impact
3,057,754
2,414,542
643,212
26.6%
Note: Due to rounding, individual values presented in the tables and charts of these Financial Statements may not sum up.
Chart 14. Structure of net banking income (PLN million)
* ‘Other’ includes result on investment activities, result on hedge accounting, dividend income and other operating income and expense
Chart 15. Net banking income by segment
The structure of net banking income by segment in 2025 did not change significantly compared to 2024. The increase in the
share of Other operations was driven by an increase of gains in asset and liability management from invested liquidity and
financial transactions. The decrease in the share of Corporate Banking was driven by interest rate cuts and realised interest
income.
5,892.1
5,741.0
1,261.5
1,249.5
1,076.8
865.1
( 45.4)
( 102.8)
8,185.0
7,752.7
12M 202512M 2024
Other*
Net trading income
Net fee and commission income
Net interest income
CIB; 5%
Other
banking
activity; 4%
Corporate;
30%
SME; 11%
Retail Business;
50%
12M 2024
CIB; 6%
Other banking
activity; 8%
Corporate; 27%
SME; 10%
Retail Business;
49%
12M 2025
5.6%
+2,6%
+1,0%
-55,9%
+24,5%
PLN 7,753
million
PLN 8,185
million
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Net interest income
Net interest income, which is the Group’s main source of revenue, amounted PLN 5,892,084 thousand in 2025 and was
higher year on year by PLN 151,078 thousand, i.e. by 2.6%. Net of the impact of credit holidays, net interest income in 2025
would be PLN 81,604 thousand. i.e. 1.4% higher compared to 2024. Interest income was lower by PLN 372,169 thousand, i.e.
by 3.6% in 2025, while interest expenses decreased by PLN 523,247 thousand, i.e. by 11.6%.
An important external factor influencing net interest income is the interest rate policy of central banks. In 2024, NBP
interest rates remained unchanged (5.75% for the reference rate). In 2025, the Monetary Policy Council (RPP) introduced six
rate cuts, bringing the reference rate down to 4.00%. In June 2024 the European Central Bank launched a monetary policy
easing cycle. By July 2025, nine rate cuts had been implemented, reducing the deposit facility rate by 200 bps (to 2.0% at
the end of July 2025).
As a result of the lower average interest rates, the average profitability of PLN and EUR denominated loan products in 2025
was lower than in the previous year. The sensitivity analysis of the Group’s net interest income to interest rate changes is
presented in the Risk and Opportunities chapter.
Table 25. Net interest income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Amounts due from banks
516,727
428,039
88,688
20.7%
Loans and advances to Customers measured at amortised
cost
6,285,061
6,739,682
(454,621)
(6.7%)
Loans and advances to Customers measured at fair value
through profit or loss
29,954
50,227
(20,273)
(40.4%)
Debt instruments measured at amortised cost
1,335,267
972,653
362,614
37.3%
Debt instruments measured at fair value through profit or
loss
5,216
7,466
(2,250)
(30.1%)
Debt instruments measured at fair value through other
comprehensive income
922,091
850,362
71,729
8.4%
Derivative instruments as part of fair value hedge
accounting
737,283
854,393
(117,110)
(13.7%)
Derivative instruments as part of cash flow hedge
accounting
39,312
11,628
27,684
238.1%
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Repo transactions
2,003
330,633
(328,630)
(99.4%)
Total interest income
9,872,914
10,245,083
(372,169)
(3.6%)
Amounts due to banks
(577,473)
(725,863)
148,390
(20.4%)
Liabilities under issued debt securities
(42,071)
-
(42,071)
-
Amounts due to Customers
(2,275,767)
(2,437,170)
161,403
(6.6%)
Lease liabilities
(20,762)
(23,282)
2,520
(10.8%)
Derivative instruments as part of fair value hedge
accounting
(980,603)
(1,275,490)
294,887
(23.1%)
Derivative instruments as part of cash flow hedge
accounting
(63,816)
(36,561)
(27,255)
74.5%
Repo transactions
(20,338)
(5,711)
(14,627)
256.1%
Others related to financial assets
-
-
-
-
Total interest expense
(3,980,830)
(4,504,077)
523,247
(11.6%)
Net interest income
5,892,084
5,741,006
151,078
2.6%
Another factor affecting the comparability of interest income on loans and advances in 2025 and 2024 was the absence of
the negative impact of statutory credit holidays in 2025. In 2024, following the entry into force of the Act of 12 April 2024
amending the Act on Support to Housing Loan Borrowers in Financial Distress and the Act of Crowdfunding for Economic
Ventures and Borrower Assistance (the “Act”), the negative impact on the Group was PLN 69,474 thousand.
Total interest income on loans and advances to Customers measured at amortised cost and measured at fair value through
profit or loss was PLN 6,315,015 thousand in 2025, down by PLN 474,894 thousand i.e. 7.0% year on year (net of the credit
holidays impact, it was down by PLN 544,368 thousand i.e. 7.9%).
The factors that positively influenced the level of interest income in 2025 compared with 2024 included the continued very
good liquidity position and the increase in the scale of the Group’s operations reflected among others in the increase in the
average value of the securities portfolio.
Depending on market conditions and opportunities, the Group adjusts the mix of liquid assets and interbank transactions.
As a result, the Group reported an increase in interest income on debt instruments measured at amortised cost and
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measured at fair value by PLN 432,093 thousand i.e. 23.6% and an increase in interest income on amounts due from banks
by PLN 88,688 thousand combined with a decrease in the cost of amounts due to banks by PLN 148,390 thousand.
The sharp decrease in the cost of interest on amounts due to banks was driven among others by a change in the Group’s
approach to subordinated and long-term funding, as reflected in the replacement of loans and advances with bonds. As a
result, interest costs in 2025 included the cost of liabilities under issued debt securities at PLN 42,071 thousand.
Net interest income was negatively impacted in 2025 by a decrease of interest income on reverse repo transactions by PLN
328,630 thousand (interest cost on reverse repos increased by PLN 14,627 thousand year on year). The decrease was due to
a change of approach to investing the liquidity surplus.
The excess liquidity of the banking sector and the differences in the level of market interest rates between 2025 and 2024
contributed to a decrease in the cost of deposits. The Group’s comfortable liquidity position (the net loans/deposits ratio at
the end of 2025 was 64.7% compared to 65.8% at the end of 2024) helped the optimisation of deposit margins. As a result,
interest expenses on amounts due to Customers amounted PLN 2,275,767 thousand in 2025 and were lower by PLN
161,403 thousand, or by 6.6% in comparison with the costs incurred in 2024, despite an increase of the deposit portfolio.
The level of net interest income is affected by the Group’s use of fair value hedge accounting and (to a much lesser extent)
cash flow hedge accounting. The change in the fair value measurement of hedging transactions is recognised in the result
on hedge accounting. Interest on IRS transactions and hedged items is recognised in net interest income. Net interest
income on hedging relationships (the sum of interest income and interest expense on derivatives under fair value and cash
flow hedge accounting) in 2025 was negative at PLN 267,824 thousand, compared to a negative result of PLN 446,030
thousand in 2024 (a decrease in the negative impact of PLN 178,206 thousand i.e. 40.0% year on year).
Net fee and commission income
The Group’s net fee and commission income in 2025 amounted to PLN 1,261,496 thousand and was PLN 12,011 thousand
(i.e. 1.0%) higher than in 2024. This was mainly the result of an improvement in commission income in the areas of
payment cards and credit cards, asset management and brokerage operations. Fees and commissions on bank accounts
and loans were down.
Fee and commission income amounted to PLN 1,519,765 thousand in 2025 and was down by PLN 8,789 thousand (i.e. by
0.6%) compared with 2024, while fee and commission expenses amounted to PLN 258,296 thousand and decreased by PLN
20,800 thousand (i.e. by 7.5%).
The increase in fee and commission income was mainly related to:
• asset management and brokerage operations by PLN 27,032 thousand, i.e. by 19.8% (primarily due to higher revenues
from the sale and management of investment funds and brokerage services),
• payment card and credit card services by PLN 9,304 thousand, i.e. by 2.2 % (primarily due to higher revenues from
cooperation with Mastercard and Euronet, higher income from card transactions in the form of transfers as well as higher
income from interchange fees).
The decrease in fee and commission income was mainly related to:
• loans, advances and leases by PLN 14,610 thousand or 5.1% (among others due to lower fee income from Retail and
Business Banking loans, including loans to farmers as well as lower fees on used and unused commitments),
• sale of insurance products by PLN 10,375 thousand i.e. 6.1% (among others due to lower income on settlements with
Cardif and sales of insurance for mortgage and farmer loans),
• account services by PLN 9,756 thousand i.e. 4.2% (among others due to lower fees for accounts of retail and micro
Customers and court seizures in the micro segment),
• electronic banking transfers and services by PLN 6,149 thousand i.e. 5.7% (due to lower income from commissions on
international payments and domestic outgoing payments).
The decrease in fee and commission expenses was mainly due to:
• lower costs of payment card and credit card services by PLN 12,761 thousand i.e. 10.6% (among others, lower settlement
cost of card transactions),
• lower other commissions by PLN 5,063 thousand i.e. 9.1% (mainly lower provisions for unpaid commissions and cost of
writing down unpaid commissions),
• lower cost of guarantees and documentary transactions by PLN 4,783 thousand i.e. 52.4%.
Table 26. Net fee and commission income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Fee and commission income
loans, advances and leases
274,640
289,250
(14,610)
(5.1%)
account maintenance
221,177
230,933
(9,756)
(4.2%)
cash service
30,353
31,462
(1,109)
(3.5%)
cash transfers and e-banking
101,898
108,047
(6,149)
(5.7%)
guarantees and documentary operations
76,384
77,320
(936)
(1.2%)
asset management and brokerage operations
163,610
136,578
27,032
19.8%
payment and credit cards
423,611
414,307
9,304
2.2%
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PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
insurance mediation activity
159,066
169,441
(10,375)
(6.1%)
product sale mediation and Customer acquisition
13,408
12,667
741
5.8%
other commissions
55,618
58,549
(2,931)
(5.0%)
Total fee and commission income
1,519,765
1,528,554
(8,789)
(0.6%)
Fee and commission expense
loans, advances and leases
(319)
(1,294)
975
(75.3%)
account maintenance
(9,398)
(9,774)
376
(3.8%)
cash service
(30,466)
(28,566)
(1,900)
6.7%
cash transfers and e-banking
(3,369)
(2,765)
(604)
21.8%
guarantees and documentary operations
(4,337)
(9,120)
4,783
(52.4%)
asset management and brokerage operations
(8,365)
(6,647)
(1,718)
25.8%
payment and credit cards
(107,855)
(120,616)
12,761
(10.6%)
insurance mediation activity
(19,692)
(21,487)
1,795
(8.4%)
product sale mediation and Customer acquisition
(23,742)
(23,011)
(731)
3.2%
other commissions
(50,753)
(55,816)
5,063
(9.1%)
Total fee and commission expenses
(258,296)
(279,096)
20,800
(7.5%)
Net fee and commission income
1,261,469
1,249,458
12,011
1.0%
Dividend income
Dividend income of the Group in 2025 totalled PLN 9,772 thousand and was paid from the profits of companies for 2024 in
which the Bank held a minority interest, i.e.: among others, Biuro Informacji Kredytowej S.A. (PLN 4,251 thousand), Krajowa
Izba Rozliczeniowa S.A. (PLN 2,473 thousand), VISA (PLN 328 thousand) and Mastercard (PLN 125 thousand).
Dividend income in 2024 totalled PLN 13,147 thousand and was paid the profits of companies for 2023 in which the Bank
held a minority interest, i.e.: among others, Biuro Informacji Kredytowej S.A. (PLN 4,131 thousand), Krajowa Izba
Rozliczeniowa S.A. (PLN 2,125 thousand), VISA (PLN 1,614 thousand) and Mastercard (PLN 235 thousand).
Net trading income and result on investment activities
Net trading income in 2025 amounted to PLN 1,076,777 thousand and was higher by PLN 211,725 thousand, i.e. by 24.5%
year on year. The level and volatility of this result are mainly shaped by the result on foreign exchange and derivative
transactions with Customers, the result on transactions concluded by CIB and the Asset and Liability Management Division,
and the result on equity instruments measured at fair value through profit or loss.
The increase in net trading income in 2025 compared to 2024 was mainly due to higher gains on derivatives and foreign
exchange transactions which stood at PLN 1,013,634 thousand in 2025 (up by PLN 173,579 thousand, i.e. 20.7% year on
year. The improvement was driven mainly by higher gains on financial instrument transactions in asset and liability
management (mainly FX swaps) and higher gains on margins on foreign exchange and derivatives transactions with
Customers (including several large transactions with Customers in the Corporate and Institutional Banking (CIB) segment in
H1 2025). The margin on foreign exchange and derivatives transactions with Customers increased by PLN 55,834 thousand
i.e. 7.7% year on year.
The increase in net trading income was also supported by a significant improvement in gains on equity instruments
measured at fair value through profit or loss, which stood at PLN 66,861 thousand in 2025, up by PLN 44,594 thousand i.e.
200.3% year on year. The increase occurred in the Group’s equity investments.
The result on investment activities in 2025 was negative at PLN 2,340 thousand compared to a positive result of PLN
14,374 thousand in 2024.
The decrease in the result on investment activities was mainly due to a PLN 11,286 thousand year-on-year decrease in
gains on debt instruments measured at fair value through other comprehensive income and a PLN 5,428 thousand decrease
in the valuation of the portfolio of loans and advances to Customers measured at fair value through profit or loss.
Other operating income
Other operating income in 2025 amounted to PLN 311,261 thousand, up by PLN 82,662 thousand or 36.2% year on year.
The change in other operating income was mainly due to:
• income from the release of provisions for litigation and other liabilities up by PLN 63,687 thousand (i.e. by 326.2%)
(among others, release of provisions for a penalty imposed by the General Inspector of Financial Information for failure to
perform obligations under the Anti-Money Laundering and Counter-Terrorist Financing Act, reduction of provisions for the
legal risk of relationships with the Bank’s Partners and provisions for potential costs of litigation concerning cancellation
of loan agreements),
• income from the sale or liquidation of property, plant and equipment and intangible assets up by PLN 13,323 thousand
(i.e. 69.2%) following the sale of the Bank’s real estate in Gdańsk and Łódź,
• income from the sale of goods and services up by PLN 8,517 thousand (i.e. 40.5%).
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Table 27. Other operating income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Sale or liquidation of property, plant and equipment and
intangible assets
32,586
19,263
13,323
69.2%
Impairment allowances on other receivables
5,051
8,104
(3,053)
(37.7%)
Sale of goods and services
29,549
21,032
8,517
40.5%
Release of provisions for litigation and claims and other
liabilities
83,212
19,525
63,687
326.2%
Recovery of debt enforcement costs
21,002
22,098
(1,096)
(5.0%)
Recovered compensation
-
-
-
-
Leasing operations
54,749
56,398
(1,649)
(2.9%)
Other operating income
85,112
82,179
2,933
3.6%
Total other operating income
311,261
228,599
82,662
36.2%
Other operating expenses
Other operating expenses in 2025 amounted to PLN 333,202 thousand and were up by PLN 8,075 thousand (i.e. 2.5%) year
on year.
Other operating expenses were mainly influenced by:
• other operating expenses up by PLN 33,107 thousand (i.e. 21.9%) (among others due to the cost of settlements and
enforcement of court judgments paid to the Bank’s Partners and additional provisions set up in 2025 for the cost of
unauthorised transactions of Customers at PLN 48.9 million),
• costs of provisions for litigation and claims and other liabilities down by PLN 11,006 thousand (i.e. 18.5%),
• costs of leasing operations down by PLN 4,536 thousand (i.e. 10.5%),
• costs of impairment of other receivables down by PLN 3,761 thousand (i.e. 34.5%),
• cost of sale or liquidation of property, plant and equipment and intangible assets down by PLN 3,700 thousand (i.e.
26.1%).
Table 28. Other operating expenses
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Loss on sale or liquidation of property, plant and
equipment and intangible assets
(10,500)
(14,200)
3,700
(26.1%)
Impairment allowances on other receivables
(7,143)
(10,904)
3,761
(34.5%)
Creation of provisions for litigation and claims and other
liabilities
(48,401)
(59,407)
11,006
(18.5%)
Debt enforcement
(35,042)
(38,591)
3,549
(9.2%)
Donations made
(9,414)
(7,894)
(1,520)
19.3%
Costs of leasing operations
(38,646)
(43,182)
4,536
(10.5%)
Costs of compensations, penalties and fines
-
-
-
-
Other operating expenses
(184,056)
(150,949)
(33,107)
21.9%
Total other operating expenses
(333,202)
(325,127)
(8,075)
2.5%
Net allowances on expected credit losses of financial assets and provisions for contingent liabilities
Net allowances on expected credit losses of financial assets and provisions for contingent liabilities in 2025 stood at a
negative PLN 174,499 thousand compared to a negative PLN 246,192 thousand in 2024 (improvement by PLN 71,693
thousand i.e. 29.1% year on year).
Considering the main operating segments:
• Retail and Business Banking segment: negative result (-PLN 6,447 thousand), deterioration of result by PLN 5,078
thousand,
• SME Banking segment: positive result (+PLN 56,619 thousand), improvement of result by PLN 56,064 thousand,
• Corporate Banking segment: (including CIB) negative result (-PLN 207,949 thousand), improvement of result by PLN
37,857 thousand,
• other banking operations: negative result (-PLN 16,723 thousand), deterioration of result by PLN 17,152 thousand.
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The difference in the cost of risk in 2025 vs. 2024 was significantly influenced by one-offs including mainly additional
provisions for expected future materialisation of the cost of risk in the institutional portfolio (Post Model Adjustment) set up
in 2024.
The quality of the loan portfolio remained strong in 2025, as confirmed by lower migration to Stage 3 and recovery on non-
performing loans. The following one-off events impacted the cost of risk in 2025:
• release of additional provisions (Post Model Adjustment) for risks identified in the portfolio as a result of analyses and
portfolio observation at PLN 44,979 thousand including:
PLN 19,168 thousand released for sensitive customers using credit holidays,
PLN 11,000 thousand released for sensitive customers in the commercial real estate segment,
PLN 8,663 thousand released for customers in sectors exposed to the results of a crisis in the German economy
(automotive, furniture, large home equipment),
• positive impact from the sale of loans at PLN 28,172 thousand,
• adjusting the level of write-downs to expectations of the future macroeconomic situation, resulting in additional PLN
5,679 provisions as a result of updating the forecasts of macroeconomic factors included in the IFRS 9 model,
• the total impact of changes to models and update of parameters was minor at PLN 1,851 thousand, where the biggest
individual impact was that of the adjustment of the IFRS 9 model including change of granularity of EAD depreciation in
the ECL calculation formula resulting in PLN 46,226 thousand released.
In 2025, the Bank entered into agreements to sell retail, SME and corporate portfolios. The gross carrying amount of the
sold portfolio measured at amortised cost was PLN 273,916 thousand, the amount of impairment allowances created was
PLN 219,696 thousand. The contractual price for the sale of these portfolios was set at PLN 82,392 thousand. The net
impact on the Bank’s result due to the sale of portfolios amounted to PLN 28,172 thousand and is presented under Net
allowances on expected credit losses of financial assets and provisions for contingent liabilities.
In 2024, the Group entered into agreements to sell retail, SME and corporate portfolios. The gross carrying amount of the
sold portfolio measured at amortised cost was PLN 430,520 thousand, the amount of impairment allowances created was
PLN 291,643 thousand. The contractual price for the sale of these portfolios was set at PLN 198,143 thousand. The net
impact on the Bank’s result due to the sale of portfolios amounted to PLN 59,266 thousand and is presented under Net
allowances on expected credit losses of financial assets and provisions for contingent liabilities.
The cost of credit risk, measured as the result on allowances to the average gross loans and advances to Customers
measured at amortised cost (calculated on the basis of balances at the end of each quarter), was -0.19% in 2025 compared
with -0.28% in 2024. Net of the impact of the sale of loans, the estimated cost of risk would be -0.23% in 2025 and -0.35%
in 2024.
General administrative expenses, depreciation and amortisation
The Group’s general administrative expenses (combined with depreciation and amortisation) in 2025 amounted to PLN
3,368,667 thousand, an increase of PLN 16,858 thousand, or 0.5%, compared to 2024.
Table 29. General administrative expenses, depreciation and amortisation
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Personnel expenses
(1,614,769)
(1,554,054)
(60,715)
3.9%
Marketing
(122,683)
(104,517)
(18,166)
17.4%
IT and telecom expenses
(339,005)
(312,287)
(26,718)
8.6%
Short-term lease and operation
(89,422)
(83,229)
(6,193)
7.4%
Other non-personnel expenses
(150,985)
(148,734)
(2,251)
1.5%
External services under other contracts and consulting
(176,017)
(351,505)
175,488
(49.9%)
Business travel
(12,396)
(11,783)
(613)
5.2%
Vehicle maintenance cost
(28,618)
(26,107)
(2,511)
9.6%
ATM and cash handling expenses
(31,448)
(29,952)
(1,496)
5.0%
Costs of outsourcing services related to leasing operations
(918)
(1,445)
527
(36.5%)
Court and notary fees
(53,641)
(49,366)
(4,275)
8.7%
Bank Guarantee Fund fee
(196,335)
(143,992)
(52,343)
36.4%
Commercial Bank Protection Scheme fee
-
-
-
-
Polish Financial Supervision Authority fee
(23,348)
(20,388)
(2,960)
14.5%
Total general administrative expenses
(2,839,585)
(2,837,359)
(2,226)
0.1%
Depreciation and amortisation
(529,082)
(514,450)
(14,632)
2.8%
Total costs
(3,368,667)
(3,351,809)
(16,858)
0.5%
A year-on-year increase in costs was recorded in the following categories:
• Personnel expenses - an increase of PLN 60,715 thousand, i.e. by 3.9%, as a result of: an increase in salary costs by PLN
40,918 thousand (annual increase in basic salaries from March), increased additional charges on salaries by PLN 10,803
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thousand, allocation to the Company Social Benefits Fund up by PLN 4,123 thousand and other costs up by PLN 2,277
thousand (mainly costs of occupational health and safety). The increase in personnel expenses was to some extent offset
by a reduction in the Group’s headcount by 246 active FTEs year on year;
Table 30. Personnel expenses
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Payroll expenses
(1,283,041)
(1,242,123)
(40,918)
3.3%
Payroll charges
(233,386)
(222,583)
(10,803)
4.9%
Employee benefits
(62,053)
(61,562)
(491)
0.8%
Costs of restructuring provision
(1,904)
(649)
(1,255)
193.4%
Costs of provision for future liabilities arising from unused
annual leave and retirement benefits
(7,055)
(6,207)
(848)
13.7%
Appropriations to Social Benefits Fund
(23,535)
(19,412)
(4,123)
21.2%
Other
(3,795)
(1,518)
(2,277)
150.0%
Total personnel expenses
(1,614,769)
(1,554,054)
(60,715)
3.9%
• Bank Guarantee Fund (BFG) fee - an increase of PLN 52,343 thousand i.e. 36.4%:
contribution to the banks’ guarantee fund was PLN 40,218 thousand in 2025 (the Bank did not pay the cost of the
contribution in 2024 as the BFG decided to suspend the charge),
annual contribution to the banks’ resolution fund, recognised in Q1 2025, stood at PLN 156,118 thousand (up by PLN
12,126 thousand year on year);
• IT and telecom expenses - up by PLN 26,718 thousand, or 8.6% - driven by an increase in the Bank’s costs of software
maintenance contracts, licence fees, unamortised expenses, Contact Centre Customer service costs, higher maintenance
costs of business systems and BNP Group systems. IT costs of GSC decreased by PLN 3,148 thousand year on year;
• Marketing costs - an increase of PLN 18,166 thousand, i.e. 17.4% - mainly due to a larger number of broader-scope
campaigns carried out in 2025 (including the Daily Banking – GOdreams and tennis card campaign, the business account
with a fuel card, the 9% savings account, the Pupil (My Pet) card, the “Accelerate Your Business” campaign for
micro-enterprises, the SME/Corporate branding campaign, and Go 4 Funds), higher event organisation costs (a greater
number of events and initiatives – including those related to the Bank’s Strategy and acquisition focused event cycles in
Carrefour), as well as higher sponsorship expenses;
• Cost of short-term leases and maintenance – an increase of PLN 6,193 thousand due to higher costs of cleaning,
renovation, repairs, regular check-ups and maintenance;
• Court and notary fees – an increase of PLN 4,275 thousand;
• Polish Financial Supervision Authority supervision costs – an increase by PLN 2,960 thousand;
• Vehicle maintenance cost (cost of the Bank’s company cars – fuel, charging of electric vehicles, maintenance costs) – an
increase by PLN 2,511 thousand year on year.
The decrease in costs of External services under other contracts and consultancy by PLN 175,488 thousand, i.e. by 49.9%, is
due to lower costs of:
services provided by the Group, down by PLN 114,271 thousand (partial release of provisions set up in 2022-2024),
legal advisory mainly on litigation concerning CHF loans, down by PLN 61,333 thousand,
other advisory services, down by PLN 14,421 thousand,
while the following costs increased:
bulk mailing up by PLN 3,963 thousand,
HR consultancy and recruitment costs up by PLN 2,073 thousand,
external services at the leasing company up by PLN 3,202 thousand,
external services at GSC up by PLN 2,611 thousand.
Total costs related to legal services for CHF loan litigation amounted to PLN 59,674 thousand in 2025 (PLN 116,829
thousand in 2024) and are included under: External services under other contracts and consultancy (PLN 7,197 thousand in
2025 vs. PLN 68,530 thousand in 2024) and Notary and court fees (PLN 52,477 thousand in 2025 vs. PLN 48,299 thousand
in 2024).
Depreciation and amortisation expenses amounted to PLN 529,082 thousand in 2025 and were higher compared to 2024 by
PLN 14,632 thousand, i.e. by 2.8%. This increase was mainly due to the Bank’s further digitalisation and the expenses
incurred for this purpose. Depreciation and amortisation costs in Group companies remained stable year on year.
The Bank’s capital expenditure amounted to PLN 442,242 thousand in 2025 and was stable year on year (PLN 442,757
thousand in 2024). The expenditure mix changed. Expenditure increased year on year in 2025 for computer hardware by
PLN 20,809 thousand and leasehold improvements by PLN 7,424 thousand. At the same time, expenditure on external staff
costs decreased by PLN 14,524 thousand and expenditure for intangible assets decreased by PLN 7,869 thousand. All
projects are analysed from the point of view of rationality and impact on the financial and business situation of the Bank
and the Group.
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Statement of comprehensive income
The Group’s total comprehensive income in 2025 amounted to PLN 3,414,803 thousand, an increase of PLN 1,030,626
thousand, or 43.2%, compared with 2024 (PLN 2,384,177 thousand). The increase in the Group’s comprehensive income was
driven by:
• an increase in net profit by PLN 699,486 thousand, i.e. 29.7% year on year,
• valuation of financial assets measured through other comprehensive income (improvement by PLN 303,531 thousand);
• valuation of cash flow hedging derivatives (improvement by PLN 88,283 thousand).
Table 31. Statement of comprehensive income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Net profit
3,057,754
2,358,268
699,486
29.7%
Other comprehensive income
Items that may be reclassified subsequently to profit or
loss upon fulfilment of certain conditions
356,033
27,255
328,778
1,206.3%
Measurement of financial assets measured at fair
value through other comprehensive income, gross
347,318
43,787
303,531
693.2%
Deferred income tax on the valuation of gross
financial assets measured through other
comprehensive income
(56,160)
(8,320)
(47,840)
575.0%
Measurement of cash flow hedge accounting
derivatives
78,145
(10,138)
88,283
-
Deferred income tax on the valuation of gross
derivatives hedging cash flows
(13,270)
1,926
(15,196)
-
Items that will not be reclassified to profit or loss
1,016
(1,346)
2,362
(175.5%)
Actuarial valuation of employee benefits
1,534
(1,662)
3,196
(192.3%)
Deferred income tax on actuarial valuation of gross
personnel expenses
(518)
316
(834)
(263.9%)
Other comprehensive income (net)
357,049
25,909
331,140
1,278.1%
Total comprehensive income
3,414,803
2,384,177
1,030,626
43.2%
Statement of financial position
Assets
The Group’s total assets as at 31 December 2025 amounted to PLN 180,725,264 thousand, an increase of PLN 13,185,675
thousand, or 7.9%, year on year.
The most significant change in the Group’s asset mix compared to the end of 2024 was an increase in the share of the
securities portfolio by 0.6 p.p., amounts due from banks by 1.7 p.p., and a decrease in the share of cash and balances at
Central Bank by 1.1 p.p. and the loan portfolio by 0.8 p.p. (sum of portfolios measured at amortised cost and at fair value).
The Group’s predominant asset structure category were loans and advances to Customers (the sum of portfolios measured
at amortised cost and at fair value), which accounted for 50.4% of total assets as at 31 December 2025, compared to 51.2%
as at 31 December 2024. Net loans and advances volumes increased by PLN 5,319,839 thousand i.e. 6.2% year on year and
reached PLN 91,173,861 as at 31 December 2025. The retail Customers’ portfolio increased by 5.2% year on year (including
mortgage loans up by 5.9%). The institutional Customers’ loan portfolio increased by 6.8% year on year (mainly as a result
of a 9.8% increase in the portfolio of loans and advances to business entities combined with a decrease in lease receivables
by 3.6%).
The second largest asset item were securities, which accounted for 33.8% of total assets as at 31 December 2025 (33.3% as
at 31 December 2024). Their value increased by PLN 5,427,939 thousand (i.e. by 9.7%) year on year. The largest increase
(by PLN 3,816,076 thousand, i.e. 11.8%) was reported in the portfolio of securities measured at amortised cost (mainly
Treasury bonds and securities issued by domestic banks and other financial institutions). The portfolio of securities
measured at fair value through other comprehensive income increased by PLN 1,692,348 thousand i.t. 7.3% year on year
(increase primarily in Treasury bonds issued by central governments and bonds issued by other financial institutions, partly
offset by a decrease in the portfolio of NBP money bills).
The share of cash and balances at Central Bank (the third largest asset line) was 5.7% (6.8% as at 31 December 2024). Its
value decreased by PLN 1,100,685 thousand (i.e. by 9.7%) year on year and amounted to PLN 10,224,866 thousand. The
share of amounts due from banks increased from 4.7% to 6.4% (in value by PLN 3,744,191 thousand, i.e. by 47.6%).
Table 32. Assets
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Cash and balances at Central Bank
10,224,866
11,325,551
(1,100,685)
(9.7%)
Amounts due from banks
11,616,566
7,872,375
3,744,191
47.6%
Derivative financial instruments
2,359,460
2,440,116
(80,656)
(3.3%)
Differences from hedge accounting
345,550
230,658
114,892
49.8%
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PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Loans and advances to Customers measured at amortised
cost
90,887,678
85,401,516
5,486,162
6.4%
Loans and advances to Customers measured at fair value
through profit or loss
286,183
452,506
(166,323)
(36.8%)
Securities measured at amortised cost
36,180,626
32,364,550
3,816,076
11.8%
Securities measured at fair value through profit or loss
240,949
321,434
(80,485)
(25.0%)
Securities measured at fair value through other
comprehensive income
24,719,802
23,027,454
1,692,348
7.3%
Intangible assets
964,459
975,114
(10,655)
(1.1%)
Property, plant and equipment
947,992
946,971
1,021
0.1%
Deferred tax assets
898,673
859,567
39,106
4.5%
Current tax assets
920
1,515
(595)
(39.3%)
Other assets
1,051,540
1,320,262
(268,722)
(20.4%)
Total assets
180,725,264
167,539,589
13,185,675
7.9%
Loan portfolio
Loan portfolio structure
As at 31 December 2025, gross loans and advances to Customers (the sum of portfolios measured at amortised cost and
measured at fair value) amounted to PLN 93,559,557 thousand and remained stable year on year (an increase of PLN
5,172,302 thousand or 5.9%)
The gross portfolio of loans and advances measured at amortised cost amounted to PLN 93,207,076 thousand as at 31
December 2025 (up by PLN 5,347,316 thousand, i.e. +6.1% year on year).
Table 33. Structure of the loan portfolio measured at amortised cost
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Corporate Customers excluding farmers
41,500,062
36,874,775
4,625,287
12.5%
Farmers
7,296,966
7,769,080
(472,114)
(6.1%)
Individual Customers
34,428,276
32,858,093
1,570,183
4.8%
- mortgage loans
21,335,075
20,207,062
1,128,013
5.6%
PLN
21,062,351
19,779,708
1,282,643
6.5%
foreign currency
272,724
427,354
(154,630)
(36.2%)
- cash loans
8,604,762
8,487,233
117,529
1.4%
- other retail loans
4,488,439
4,163,798
324,641
7.8%
Leasing receivables
6,282,940
6,519,624
(236,684)
(3.6%)
Public sector institutions
218,025
67,960
150,065
220.8%
Non-bank financial institutions
3,480,807
3,770,228
(289,421)
(7.7%)
Gross loans and advances
93,207,076
87,859,760
5,347,316
6.1%
The gross portfolio of loans and advances to corporate Customers (excluding farmers), measured at fair value, amounted to
PLN 41,500,062 thousand (up by PLN 4,625,287 thousand or 12.5% year on year). Their share in the loan portfolio measured
at fair value as at 31 December 2025 was 44.5% (+2.6 p.p. year on year). Overdrafts represent 41.2% of this portfolio (+1.7
p.p. year on year)
Gross loans and advances to individual Customers as at 31 December 2025 amounted to PLN 34,428,276 thousand (up by
PLN 1,570,183 thousand or 4.8% year on year). Their share in the loan portfolio measured at amortised cost was 36.9% as
at 31 December 2025 (down 0.5 p.p. year on year). Mortgage loans, which amounted to PLN 21,335,075 thousand as at 31
December 2025, accounted for 62.0% of the credit exposure of individual Customers (+0.5 p.p. year on year). In the portfolio
of mortgage loans, 98.7% were loans granted in PLN, while 1.2% were loans granted in CHF (the share of CHF loans fell by
0.8 p.p. year on year).
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Chart 16. Loans and advances gross measured at amortised cost – entity structure
31.12.2024 31.12.2025
The volume of loans granted to individual farmers as at 31 December 2025 amounted to PLN 7,296,966 thousand and
decreased by PLN 472,114 thousand i.e. 6.1% year on year.
Lease receivables amounted to PLN 6,282,940 thousand (down 3.6% year on year). Their share in the loan portfolio
measured at amortised cost was 6.7% as at 31 December 2025 (compared with 7.4% as at 31 December 2024).
The volume of loans granted to non-bank financial entities and public sector institutions totalled PLN 3,698,832 thousand
(down 3.6% year on year). Their share in the loan portfolio measured at amortised cost in 2025 was 4.0% (compared with
4.4% as at 31 December 2024).
Quality of the loan portfolio
The share of Stage 3 and POCI non-performing exposures in gross loans and advances to Customers measured at amortised
cost decreased by 0.4 p.p. year on year and stood at 2.8% as at 31 December 2025. The provision coverage of these
exposures as at 31 December 2025 was 54.1% (up 0.1 p.p. year on year).
Table 34. Coverage of the loan portfolio measured at amortised cost with impairment losses
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Gross loans and advances to Customers, total
93,207,076
87,859,760
5,347,316
6.1%
Allowance for receivables
(2,319,398)
(2,458,244)
138,846
(5.6%)
Net loans and advances to Customers, total
90,887,678
85,401,516
5,486,162
6.4%
Gross loans and advances granted to Customers in Stage
1 & 2, and POCI performing
Gross balance sheet exposure
90,605,379
85,012,162
5,593,217
6.6%
Allowance
(912,671)
(921,184)
8,513
(0.9%)
Net balance sheet exposure
89,692,708
84,090,978
5,601,730
6.7%
Gross loans and advances granted to Customers in Stage
3 and POCI non-performing
Gross balance sheet exposure
2,601,697
2,847,598
(245,901)
(8.6%)
Impairment allowance
(1,406,727)
(1,537,060)
130,333
(8.5%)
Net balance sheet exposure
1,194,970
1,310,538
(115,568)
(8.8%)
Indicators
31.12.2025
31.12.2024
change
Share of Stage 3 and POCI non-performing in the gross
portfolio
2.8%
3.2%
(0.4 p.p.)
Provision coverage of Stage 3 and POCI non-performing
exposures
54.1%
54.0%
+0.1 p.p.
Business
entities
excluding
farmers; 42.0%
Individual
Customers; …
Farmers;
8.8%
Lease
receivables;
7.4%
Public
sector
institutions;
0.1%
Non-
banking
financial
institutions;
4.3%
Business
entities
excluding
farmers; 44.5%
Individual
Customers; 36.9%
Farmers;
7.8%
Lease
receivables;
6.7%
Public
sector
institutions;
0.2%
Non-banking
financial
institutions; 3.7%
PLN 93,207
million
PLN 87,860
million
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Table 35. Quality of the loan portfolio measured at amortised cost
PLN’000
31.12.2025
31.12.2024
total gross
NPL*
% share
total gross
NPL*
% share
Corporate Customers excluding
farmers
41,500,062
1,467,281
3.5%
36,874,775
1,529,666
4.1%
Farmers
7,296,966
268,375
3.7%
7,769,080
405,438
5.2%
Individual Customers
34,428,276
655,765
1.9%
32,858,093
715,412
2.2%
- mortgage loans
21,335,075
256,086
1.2%
20,207,062
288,465
1.4%
PLN
21,062,351
157,108
0.7%
19,779,708
172,862
0.9%
foreign currency
272,724
98,978
36.3%
427,354
115,603
27.1%
- cash loans
8,604,762
297,580
3.5%
8,487,233
320,712
3.8%
- other retail loans
4,488,439
102,099
2.3%
4,163,798
106,235
2.6%
Leasing receivables
6,282,940
207,186
3.3%
6,519,624
187,807
2.9%
Public sector institutions
218,025
-
-
67,960
-
-
Non-bank financial entities
3,480,807
3,090
0.1%
3,770,228
9,275
0.2%
Gross loans and advances
93,207,076
2,601,697
2.8%
87,859,760
2,847,598
3.2%
* NPLs defined as loans and advances in Stage 3 and POCI non-performing based on information presented in Note 21 to the Consolidated Financial Statements
The value of collateral held for Customer loans as at 31 December 2025 amounted to PLN 1,592,896 thousand (PLN
1,792,387 thousand as at 31 December 2024). Details of collateral held are presented in Note 54.2. of the Consolidated
Financial Statements for the year ended 31 December 2025.
Securitisation of a loan portfolio
On 28 March 2024, the Bank entered into an agreement with International Finance Corporation ("IFC", "Investor") for a
synthetic securitisation transaction on a portfolio of corporate loans/advances with a total value of PLN 2,180,097 thousand
as at 31 December 2023. The main objective of the transaction was to release capital that the Bank allocated to financing
of climate projects (projects related to climate change mitigation, focusing mainly on renewable energy sources, energy
efficiency and financing green projects).
As part of the transaction, the Bank transferred a significant part of the credit risk from the selected securitised portfolio to
the Investor. The selected loan portfolio covered by the securitisation remains in the Bank’s books.
As at 31 December 2025, the value of the portfolio of transactions included in the balance sheet and off-balance sheet
amounted to PLN 213,638 thousand.
The transaction completion date under the agreement was 31 December 2031 but the securitisation transaction was closed
on 10 January 2026 as the time-call option was exercised.
The risk transfer of the securitised portfolio was effected through a credit protection instrument in the form of a financial
guarantee issued by the Investor for up to PLN 19,377 thousand as at 31 December 2025. Costs on account of this
guarantee are presented in Fee and commission expenses - Guarantees and documentary transactions.
The transaction met the requirements for significant risk transfer set out in the CRR and was structured as meeting the STS
criteria (simple, transparent and standardised securitisation) in accordance with Regulation 2021/557.
The Bank was the arranger of the transaction.
Liabilities and equity
As at 31 December 2025, the Group’s total liabilities amounted to PLN 163,126,956 thousand, up by PLN 10,981,423
thousand or 7.2% year on year. The share of liabilities in the Group’s total liabilities and equity was 90.3% as at 31
December 2025 (90.8% as at 31 December 2024).
Amounts due to Customers are the predominant liabilities category. They stood at PLN 141,338,836 thousand as at 31
December 2025 (up by PLN 10,414,082 thousand i.e. 8.0% year on year) and represented 86.6% of total liabilities (up by 0.6
p.p. year on year). The second largest liabilities category are amounts due to banks which stood at PLN 10,145,231
thousand as at 31 December 2025 (down by PLN 150,429 thousand i.e. 1.5% year on year). Their share was 6.2% as at 31
December 2025 (down by 0.4 p.p. year on year). A new liabilities line are liabilities under issued debt securities including
subordinated issuances (capital bonds), which stood at PLN 4,226,368 thousand as at 31 December 2025 and their share in
total liabilities was 2.6%.
The Group’s equity stood at PLN 17,598,308 thousand as at 31 December 2025, up by PLN 2,204,252 thousand i.e. 14.3%
year on year. The share of equity in total liabilities and equity of the Group was 9.7% as at 31 December 2025 (9.2% as at 31
December 2024).
Table 36. Liabilities and equity
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Amounts due to the Central Bank
-
-
-
-
Amounts due to other banks
10,145,231
9,994,802
150,429
1.5%
Derivative financial instruments
2,276,575
2,311,741
(35,166)
(1.5%)
Differences from hedge accounting
320,087
260,025
60,062
23.1%
Amounts due to Customers
141,338,836
130,924,754
10,414,082
8.0%
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PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Liabilities under issued debt securities (including
subordinated issuances)
4,226,368
-
4,226,368
-
Subordinated liabilities
-
3,420,128
(3,420,128)
(100.0%)
Leasing liabilities
553,436
606,306
(52,870)
(8.7%)
Other liabilities
2,048,795
2,296,756
(247,961)
(10.8%)
Current tax liabilities
177,971
361,641
(183,670)
(50.8%)
Provisions
2,039,657
1,969,380
70,277
3.6%
Total liabilities
163,126,956
152,145,533
10,981,423
7.2%
Share capital
147,880
147,800
80
0.1%
Supplementary capital
9,180,883
9,155,136
25,747
0.3%
Other reserve capital
4,672,514
4,042,815
629,699
15.6%
AT1 Capital bonds
650,000
650,000
-
0.0%
Revaluation reserve
(183,796)
(540,845)
357,049
(66.0%)
Retained earnings
3,130,827
1,939,150
1,191,677
61.5%
- retained profit
73,073
(419,118)
492,191
(117.4%)
- net profit for the period
3,057,754
2,358,268
699,486
29.7%
Total equity
17,598,308
15,394,056
2,204,252
14.3%
Total liabilities and equity
180,725,264
167,539,589
13,185,675
7.9%
Amounts due to Customers
As at 31 December 2025, amounts due to Customers stood at PLN 141,338,836 thousand, up by PLN 10,414,082 thousand
i.e. 8.0% year on year.
The biggest increase in amounts due to Customers by value was reported for amounts due to corporate Customers, which
amounted to PLN 71,765,182 thousand as at 31 December 2025 (up by PLN 4,794,903 thousand i.e. 7.2% year on year).
Current accounts increased (by PLN 3,178,068 thousand), as did term deposits (by PLN 1,586,801 thousand i.e. 10.4%). The
share of this segment in total amounts due to Customers was 50.8% as at 31 December 2025 vs. 51.2% as at 31 December
2024. Amounts due to individual farmers stood at PLN 4,424,592 thousand as at 31 December 2025, up by PLN 106,309
thousand (2.5%). They accounted for 6.2% of amounts due to corporate Customers (down by 0.2 p.p. year on year).
Amounts due to individual Customers stood at PLN 59,183,277 thousand as at 31 December 2025, up by PLN 3,998,880
thousand (7.2%) year on year, mainly due to an increase in current accounts (up by PLN 3,891,356 thousand i.e. 13.01%).
Term deposits decreased modestly by PLN 119,170 thousand i.e. 0.5%. The share of this segment in total amounts due to
Customers was 41.9% (42.1% as at 31 December 2024).
Amounts due to non-bank financial entities and public sector institutions increased by PLN 1,188,079 thousand (21.9%) and
by PLN 432,220 thousand (13.0%) year on year, respectively. The share of these segments in total amounts due to
Customers increased from 4.2% to 4.7% (+0.5 p.p.) for amounts due to non-bank financial institutions and from 2.5% to 2.7%
(+0.2 p.p.) for public sector institutions.
Chart 17. Amounts due to Customers - entity structure
31.12.2024 31.12.2025
Non-banking
financial
institutions;
4.2%
Individual
Customers;
42.1%
Business
entities; 51.2%
Public sector
institutions;
2.5%
Non-banking
financial
institutions;
4.7%
Individual
Customers;
41.9%
Business
entities; 50.8%
Public sector
institutions;
2.7%
PLN 130,925
million
PLN 141,339
million
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Table 37. Amounts due to Customers by product
31.12.2025
31.12.2024
PLN’000
% share
PLN’000
% share
Current accounts
94,195,640
66.6%
86,301,533
65.9%
Term deposits
45,326,169
32.1%
43,070,184
32.9%
Loans and advances received
450,612
0.3%
449,955
0.3%
Other liabilities
1,366,415
1.0%
1,103,082
0.8%
Amounts due to Customers, including:
141,338,836
100.0%
130,924,754
100.0%
deposits
140,888,224
99.7%
130,474,799
99.7%
The share of current accounts in total amounts due to Customers was 66.6% as at 31 December 2025, up by 0.7 p.p. year on
year. Current accounts totalled PLN 94,195,640 thousand, up by PLN 7,894,107 thousand i.e. 9.1%. The increase was driven
by an increase in volumes of retail Customers (up by PLN 3,891,356 thousand i.e. 13.1%) and volumes of corporate
Customers (up by PLN 3,178,068 thousand i.e. 6.2%). Volumes of public sector institutions and non-bank entities increased
by PLN 562,391 thousand and PLN 262,292 thousand, respectively. The share of term deposits in amounts due to
Customers was 32.1% as at 31 December 2025, down by 0.8 p.p. year on year. Term deposits increased in value by PLN
2,255,985 thousand to PLN 45,326,169 thousand, i.e. by 5.2% year on year.
The share of other liabilities and loans and advances received in total amounts due to Customers was 1.3%, up 0.1 p.p. year
on year. The volume stood at PLN 1,817,027 thousand.
The geographic mix of amounts due to the Bank’s Customers as at 31 December 2025 by key regions (management
perspective) is presented below.
Table 38. Geographic structure of amounts due to the Bank’s Customers at the end of 2025
Segment/market
31.12.2025
Retail and Business Banking
56.1%
Białystok
2.8%
Bydgoszcz
2.7%
Gdańsk
3.6%
Katowice
3.1%
Kielce
3.3%
Segment/market
31.12.2025
Kraków
5.0%
Lublin
3.3%
Łódź
3.2%
Olsztyn
2.7%
Poznań
4.3%
Rzeszów
2.9%
Szczecin
2.5%
Warsaw South
3.1%
Warsaw North
7.2%
Wrocław
3.7%
Zielona Góra
2.6%
SME and Corporate Banking
37.2%
East
7.6%
West
7.1%
Strategic Customers Division
22.4%
Other
6.7%
Equity
Equity of the Group stood at PLN 17,598,308 thousand as at 31 December 2025, up by PLN 2,204,252 thousand i.e. 14.3%
year on year.
In accordance with Resolution No. 7 of the Annual General Meeting of BNP Paribas Bank Polska S.A. dated 15 April 2025, the
Bank distributed the net profit earned in 2024, amounting to PLN 2,320,798 thousand, as follows: PLN 1,162,341 thousand
was paid out as a dividend, PLN 658,457 thousand was allocated to the reserve capital, and the remaining amount
remained in retained earnings.
The Group’s equity changed also owing to earnings of the period (net profit of 2025 at PLN 3,057,754 thousand, up by PLN
699,486 thousand i.e. 29.7% year on year).
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Contingent liabilities
The table below shows contingent liabilities granted and received.
Table 39. Contingent liabilities
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Contingent commitments granted
43,328,592
36,666,533
6,662,059
18.2%
financial commitments
28,751,150
23,269,197
5,481,953
23.6%
guarantees
14,577,442
13,397,336
1,180,106
8.8%
Contingent commitments received
57,773,732
55,172,867
2,600,865
4.7%
financial commitments
31,000
551,870
(520,870)
(94.4%)
guarantees
57,742,732
54,620,997
3,121,735
5.7%
Long-term contingent liabilities granted stood at PLN 19,058,230 thousand as at 31 December 2025 (PLN 18,152,339
thousand as at 31 December 2024). Long-term contingent liabilities received stood at PLN 51,141,921 thousand as at 31
December 2025 (PLN 49,217,162 thousand as at 31 December 2024).
Own funds and capital ratios
The calculation of the capital adequacy of the Bank and the Group as at 31 December 2025 was made in accordance with
the provisions of Regulation (EU) No. 575/2013 of the European Parliament and of the Council of 26 June 2013 (CRR) on
prudential requirements for credit institutions and investment firms, as amended by Regulation (EU) 2019/876 of the
European Parliament and of the Council of 20 May 2019 (CRR2 as regards the leverage ratio, the net stable funding ratio,
requirements for own funds and eligible liabilities, counterparty credit risk, market risk, exposures to central
counterparties, exposures to collective investment undertakings, large exposures, reporting and disclosure requirements)
and amended, among others, by Regulation (EU) 2024/1623 of the European Parliament and of the Council of 31 May 2024
(CRR3) amending Regulation (EU) No 575/2013 as regards requirements for credit risk, credit valuation adjustment risk,
operational risk, market risk and the output floor.).
The Group’s own funds at 31 December 2025 consisted of:
• Tier 1 capital of PLN 14,105,949 thousand vs. PLN 12,812,053 thousand as at 31 December 2024 (including Common
Equity Tier 1 capital of PLN 13,455,949 thousand vs. PLN 12,162,053 thousand as at 31 December 2024 and additional
Tier 1 capital (capital bonds worth PLN 650,000 thousand)),
• Tier 2 capital of PLN 3,379,809 thousand vs. PLN 3,150,021 thousand as at 31 December 2024.
Key drivers of own funds in 2025 included:
• addition to consolidated Common Equity Tier 1 capital of the audited consolidated net profit for the period from 1 January
2024 to 31 December 2024 at PLN 1,197,365 thousand (following a decision of the Bank’s Annual General Meeting of 15
April 2025 concerning the distribution of the profit of BNP Paribas Bank Polska S.A. for the financial year 2024),
• improvement of unrealised gains and losses measured at fair value through other comprehensive income by PLN 158,939
thousand,
• increase by PLN 7,547 thousand of the adjustment in Common Equity Tier 1 capital related to the deduction of intangible
assets, taking into account Commission Delegated Regulation (EU) 2020/2176 of 12 November 2020 as regards the
deduction of software assets from Common Equity Tier 1 items,
• reduction of own funds by PLN 24,852 thousand due to deduction of the shortfall in the coverage of non-performing
exposures in accordance with Article 36(1)(m) of the CRR,
• issues of Tier 2 instruments in the amount of EUR 160 million and EUR 630 million linked to repayment of partly
amortised Tier 2 loans in the amount of EUR 40 million, EUR 60 million, CHF 60 million, CHF 90 million and PLN 2,300
million. This added PLN 78,265 thousand to Tier 2 capital.
Total risk exposure amount as at 31 December 2025 stood at PLN 103,722,212 thousand, up by PLN 10,907,286 thousand
year on year. The change was mainly driven by CRR3 which took effect as of 1 January 2025, as well as an increase in total
credit risk weighted assets (mainly corporate exposures and mortgage-backed exposures) and total operational risk
weighted assets.
As a result, the Group’s total capital ratio as at 31 December 2025 stood at 16.86% (down by 0.34 p.p. year on year).
The consolidated Common Equity Tier 1 ratio (CET 1) as at 31 December 2025 was 12.97% (down by 0.13 p.p. year on year)
and the consolidated Tier 1 ratio of the Group as at 31 December 2025 was 13.60% (down by 0.20 p.p. year on year).
Table 40. Own funds and capital ratios of the Group
PLN’000
31.12.2025
31.12.2024
change y/y
PLN’000
%
Common Equity Tier 1 (CET 1)
- share capital
147,880
147,800
81
0.1%
- supplementary capital
7,259,316
7,259,316
0
0.0%
- reserve capital
5,916,927
5,198,711
718,216
13.8%
- general banking risk fund
627,154
627,154
0
0.0%
- intangible assets
(497,514)
(490,732)
(6,782)
1.4%
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PLN’000
31.12.2025
31.12.2024
change y/y
PLN’000
%
- other components of own funds, included in the
calculation of CET 1
2,186
(580,196)
582,382
(100.4%)
Total CET 1
13,455,949
12,162,053
1,293,896
10.6%
Additional Tier 1 capital
650,000
650,000
0
0.0%
Total Tier 1 capital
14,105,949
12,812,053
1,293,896
10.1%
Supplementary funds (Tier II)
- subordinated liabilities included in own funds
3,379,809
3,150,021
229,788
7.3%
Total own funds
17,485,758
15,962,074
1,523,684
9.5%
Risk exposure amount due to
- credit risk
89,675,540
80,634,295
9,041,245
11.2%
- market risks
1,202,181
1,338,766
(136,584)
(10.2%)
- operational risks
12,774,331
10,791,753
1,982,578
18.4%
- credit valuation adjustments
70,160
50,112
20,048
40.0%
Total risk exposure amount
103,722,212
92,814,926
10,907,286
11.8%
Capital ratios of the Group
31.12.2025
31.12.2024
change
Common Equity Tier 1 (CET 1)
12.97%
13.10%
(0.13 p.p.)
Tier 1
13.60%
13.80%
(0.20 p.p.)
Total Capital Ratio (TCR)
16.86%
17.20%
(0.34 p.p.)
Minimum capital requirements
The minimum levels of capital adequacy ratios of the Bank and the Group result from the following external regulations:
• Regulation (EU) No. 575/2013 of the European Parliament and of the Council of 26 June 2013: 4.5% for CET1, 6% for Tier 1
and 8% for TCR,
• The Act of 5 August 2015 on macroprudential supervision over the financial system and crisis management in the
financial sector (Journal of Laws of 2015, item 1513, as amended):
conservation buffer of 2.5% (unchanged compared to 2023),
buffer of another systemically important institution in an amount equivalent to 0025% of the total risk exposure
amount calculated in accordance with Article 92(3) of Regulation (EU) No 575/2013. On 10 September 2025, the Bank
received for information a request from the Polish Financial Supervision Authority regarding an opinion by the
Financial Stability Committee on the amendment of the Polish Financial Supervision Authority decision of 4 October
2016, as amended by the Polish Financial Supervision Authority decision of 6 December 2024, concerning imposition
on the Bank (on a consolidated and separate basis) of a buffer of other systemically important institution in an amount
equivalent to 0.50% of the total risk exposure amount. By its decision of 21 November 2025, the Polish Financial
Supervision Authority amended its decision of 4 October 20216 and imposed on the Bank a buffer of other systemically
important institution in an amount equivalent to 0.25% of the total risk exposure amount,
countercyclical buffer rate - the Bank-specific countercyclical buffer rate, determined in accordance with the
provisions of the Act of August 5, 2015, on macroprudential supervision over the financial system and crisis
management in the financial system as a weighted average of the countercyclical buffer rates applicable in the
jurisdictions where the Bank’s relevant credit exposures are located, was 1 p.p. as at 31 December 2025. The value of
the indicator was influenced by the application of Article 2(5)(b) of Commission Delegated Regulation (EU) No
1152/2024, according to which foreign exposures, whose aggregate does not exceed 2 % of the aggregate of the
general credit, trading book and securitisation exposures of that institution may be allocated to the institution’s home
member state. The countercyclical buffer rate for credit exposures in the territory of the Republic of Poland, which
applied as at 31 December 2025, was 1% in accordance with the Regulation of the Minister of Finance of 18 September
2024 on the countercyclical buffer rate (Journal of Laws, item 1400).
• Act of 29 August 1997 - Banking Law (Journal of Laws 1997 No. 140 item 939): capital charge recommended under Pillar 2
(P2G) - The Polish Financial Supervision Authority, by letter dated 16 December 2024, reported that the Bank’s sensitivity
to the possible materialisation of stress scenarios affecting the level of own funds and risk exposure was assessed as low
in the Bank’s supervisory assessment process. Based on the 2024 Supervisory Stress Tests conducted by the Office of the
Polish Financial Supervision Authority and in accordance with the instruction, the total capital charge recommended
under Pillar 2 offset by a capital buffer requirement was set at 0.00 p.p. on a separate basis and 0.00 p.p. on a
consolidated basis. On 25 November 2025, the Polish Financial Supervision Authority announced that it set no P2G charge
for the Bank and the Group following its 2025 Supervisory Stress Tests.
As a result of the requirements described above, the minimum levels of capital adequacy ratios resulting from the
provisions of law and administrative decisions issued by the Polish Financial Supervision Authority on a consolidated basis
are as follows:
Minimum levels of the Group’s capital ratios
31.12.2025
31.12.2024
change
Common Equity Tier 1 (CET 1)
8.25%
7.50%
0.75 p.p.
Tier 1
9.75%
9.00%
0.75 p.p.
Total Capital Ratio (TCR)
11.75%
11.00%
0.75 p.p.
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As at 31 December 2025, all capital adequacy ratios of the Group were higher than the minimum requirements by:
• 4.72 p.p. for the Common Equity Tier 1 ratio,
• 3.85 p.p. for the Tier 1 ratio,
• 5.11 p.p. for the Total Capital Ratio.
Capital position management
The Group continuously monitors and manages its capital position, including the level of subordinated liabilities classified
as own funds, taking into account the current capital adequacy ratios relative to the minimum regulatory requirements,
current and projected capital needs, as well as the amortisation profile of Tier 2 instruments.
In 2025, the Group adjusted the structure of its Tier 2 instruments by replacing partially amortised subordinated loans with
issuances of 15-year capital bonds. As noted above, these transactions resulted in a slight increase in Tier 2 capital (by PLN
78,265 thousand year on year), while significantly improving the maturity structure of Tier 2 instruments.
The Polish Financial Supervision Authority granted approval for the Bank to classify the capital bonds as Tier 2 instruments:
on 11 August 2025 for the series B capital bonds issued on 6 June 2025 with a total nominal value of EUR 160 million, and
on 21 November 2025 for the series C capital bonds issued on 10 October 2025 with a total nominal value of EUR 630
million.
On 12 August 2025, the Polish Financial Supervision Authority authorised the Bank to redeem Tier 2 instruments prior to
their contractual maturity, including: the subordinated loan dated 10 December 2018 with a total nominal value of EUR 40
million; the subordinated loan dated 15 November 2012, amended on 20 November 2017, with a nominal value of CHF 60
million; and the subordinated loan dated 15 November 2012, amended on 20 November 2017, with a nominal value of EUR
60 million. These prudentially amortised loans were repaid in September 2025.
On 7 November 2025, the Polish Financial Supervision Authority authorised the Bank to redeem Tier 2 instruments prior to
their contractual maturity, including: the subordinated loan dated 12 September 2014, amended on 13 September 2019,
with a total nominal value of CHF 90 million. On 1 December 2025, the Polish Financial Supervision Authority authorised
the Bank to redeem Tier 2 instruments prior to their contractual maturity, including: the subordinated loan dated 7
December 2020 with a total nominal value of PLN 2,300 million. These loans were repaid in November and December 2025,
respectively.
Minimum level of own funds and eligible liabilities (MREL)
The MREL requirement applies on a separate basis, hence the details of this requirement are described in the section on
the Bank’s Financial results.
Financial ratios
The Group’s return on equity (ROE), calculated based on reported figures, stood at 18.7% as at 31 December 2025 and was
up by 1.8 p.p. year on year. Return on assets (ROA), calculated based on reported figures, was 1.8%, up 0.3 p.p. year on year.
The improvement in the return ratios was mainly due to the increase in net banking income, effective cost controlling and
reduction, lower negative impact of the legal risk of foreign currency mortgage loans, and lower credit risk cost.
The cost/income ratio, calculated based on reported figures, was 41.2% (down 2.1 p.p. year on year). This change was due
to income growing faster than costs despite higher regulatory charges (BFG).
The net interest margin calculated in relation to average assets over the year was 3.5% (down by 0.1 p.p. year on year).
The decrease in the margin was due to gradual interest rate cuts in 2025.
The low cost of credit risk, as reported and as adjusted (net of the sale of the loan portfolio), reflects the balanced
approach to risk management and a very good quality of the Group’s loan portfolio.
The level and evolution of ratios which measure net and gross loans to deposits and sources of funding reflect the good
liquidity position observed in 2025 and 2024.
Table 41. Financial ratios
31.12.2025
31.12.2024
31.12.2023
change
2025/2024
Return on equity
18.7%
16.9%
8.2%
+1.8 p.p.
Adjusted return on equity
18.7%
17.3%
7.7%
+1.5 p.p.
Return on assets
1.8%
1.5%
0.7%
+0.3 p.p.
Adjusted return on assets
1.8%
1.5%
0.6%
+0.3 p.p.
Net interest margin
3.5%
3.6%
3.4%
(0.1 p.p.)
Cost/Income
41.2%
43.2%
42.5%
(2.1 p.p.)
Cost/Income excluding the Bank Guarantee Fund, the
Commercial Banks Protection Scheme and the impact of
credit holidays
38.8%
41.0%
41.1%
(2.3 p.p.)
Credit risk costs
(0.19%)
(0.28%)
(0.04%)
+0.09 p.p.
Adjusted credit risk costs
(0.23%)
(0.35%)
(0.07%)
+0.12 p.p.
Net loans/Deposits
64.7%
65.8%
68.1%
(1.1 p.p.)
Gross loans/Total sources of financing
60.8%
62.0%
64.0%
(1.1 p.p.)
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Alternative Performance Measures
The presented ratios and categories are standard and commonly used in financial analysis. They allow for the assessment and comparison of the Group’s profitability and financial position. The presentation of the level of net profit and ratios as
adjusted, i.e. net of the impact of unusual events, is intended to provide additional information allowing for a more adequate assessment of changes in the long term and for assessing the impact of various factors on the Group’s results and financial
position.
Table 42. Alternative Performance Measures
PLN’000 / %
31.12.2025
31.12.2024
31.12.2023
Definitions and assumptions
Net profit
3,057,754
2,358,268
1,012,546
Line in the statement of profit or loss in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the relevant years
Total average equity
16,321,466
13,931,570
12,370,956
Average calculated on the basis of balances at the end of the last 3 quarters for the half year and the last 5 quarters for the full year (line in the statement of financial
position in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group)
Return on equity
18.7%
16.9%
8.2%
Net profit to average equity
Adjusted net profit
3,057,754
2,414,542
967,411
Line in the consolidated statement of profit or loss adjusted for the impact of credit holidays (2024: -PLN 69,474 thousand, 2023: +PLN 55,722 thousand; see chapter
Consolidated statement of profit or loss). Impact of credit holidays on net profit estimated using the 19% income tax rate
Adjusted total average equity
16,332,721
13,983,442
12,496,227
Average total equity adjusted like net profit, adjustments made for each quarter
Adjusted return on capital
18.7%
17.3%
7.7%
Adjusted net profit to adjusted average total equity
Average total assets
170,077,488
161,180,334
152,411,341
Average calculated on the basis of balances at the end of the last 3 quarters for the half year and the last 5 quarters for the full year (line in the statement of financial
position in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group)
Return on assets
1.8%
1.5%
0.7%
Net profit to average total assets
Adjusted average total assets
170,088,743
161,232,207
152,536,612
Average total assets adjusted like net profit, adjustments made for each quarter
Adjusted return on assets
1.8%
1.5%
0.6%
Adjusted net profit to adjusted average total assets
Net interest income
5,892,084
5,741,006
5,225,427
Line in the statement of profit or loss in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the relevant years
Net interest margin
3.5%
3.6%
3.4%
Net interest income to average total assets
Costs
3,368,667
3,351,809
3,095,535
Sum of general administrative expenses and depreciation and amortisation (lines in the statement of profit or loss in the Consolidated Financial Statements of the BNP
Paribas Bank Polska S.A. Group)
Net banking income
8,184,962
7,752,716
7,282,798
Sum of net interest income, net fee and commission income, dividend income, net trading income, result on investment activities, result on hedge accounting, result
on derecognition of assets/liabilities, other operating income and expenses (lines in the statement of profit or loss in the Consolidated Financial Statements of the
BNP Paribas Bank Polska S.A. Group)
Cost/Income
41.2%
43.2%
42.5%
Cost to income
Cost/Income excluding the Bank Guarantee
Fund, IPS, and the impact of credit holidays
38.8%
41.0%
41.1%
The costs were adjusted by the costs of fees for the Bank Guarantee Fund and the Commercial Bank Protection Scheme (IPS, see Note General administrative
expenses in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group) (2025: PLN 196,335 thousand, 2024: PLN 143,992 thousand, 2023: PLN
123,909 thousand and PN 275 thousand IPS). Income in 2024 adjusted by -PLN 69,474 thousand, in 2023 by +PLN 55,722 thousand of impact of credit holidays (see
Consolidated statement of profit or loss).
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PLN’000 / %
31.12.2025
31.12.2024
31.12.2023
Definitions and assumptions
Net allowances on expected credit losses of
financial assets and provisions for
contingent liabilities
(174,499)
(246,192)
(34,369)
Line in the statement of profit or loss in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the relevant years
Average gross loans and advances to
Customers measured at amortised cost
90,022,600
88,195,764
89,280,552
Average calculated on the basis of balances at the end of the last 3 quarters for the half year and the last 5 quarters for the full year (line in the Note: Loans and
advances to Customers measured at amortised cost in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group)
Credit risk costs
(0.19%)
(0.28%)
(0.04%)
Net allowances on expected credit losses on financial assets and provisions for contingent liabilities to average gross loans and advances to Customers measured at
amortised cost
Adjusted net allowances on expected credit
losses of financial assets and provisions for
contingent liabilities
(202,671)
(305,458)
(60,885)
Net allowances on expected credit losses of financial assets and provisions for contingent liabilities adjusted for the impact of sales of a loan portfolio (2025: +PLN
28,172 thousand, 2024: +PLN 59,266 thousand, 2023: +PLN 26,516 thousand)
Adjusted credit risk costs
(0.23%)
(0.35%)
(0.07%)
Adjusted net allowances on expected credit losses of financial assets and provisions for contingent liabilities to the average balance of gross loans and advances to
Customers measured at amortised cost
Net loans
91,173,861
85,854,022
86,248,098
Sum of net loans and advances to Customers measured at amortised cost and net loans and advances to Customers measured at fair value through profit or loss – in
Notes to the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group. Balances at the end of periods
Deposits
140,888,224
130,474,799
126,713,938
Amounts due to Customers less Loans and advances received from non-bank financial entities – in the Note Amounts due to Customers in the Consolidated Financial
Statements of the BNP Paribas Bank Polska S.A. Group. Balances at the end of periods
Net loans/Deposits
64.7%
65.8%
68.1%
Net loans to deposits
Loans and advances granted to Customers
Stage 3 and POCI non-performing
2,601,697
2,847,598
2,640,799
Lines in the Note: Loans and advances to Customers measured at amortised cost in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group
(Tables: Loans and advances to Customers broken down by Stages and segmentation of POCI loans and advances - gross presentation)
Gross loans and advances to Customers
measured at amortised cost
93,207,076
87,859,760
88,111,833
Line in the Note: Loans and advances to Customers measured at amortised cost in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group
Share of Stage 3 and POCI non-performing
in the gross portfolio
2.8%
3.2%
3.0%
Loans and advances to Customers Stage 3 and POCI non-performing to gross loans and advances to Customers measured at amortised cost, at the end of the period
Impairment allowances (for Stage 3
receivables and POCI non-performing)
1,406,727
1,537,060
1,581,566
Lines in the Note: Loans and advances to Customers measured at amortised cost in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group
(Tables: Loans and advances to Customers broken down by Stages and segmentation of POCI loans and advances)
Provision coverage of Stage 3 and POCI non-
performing exposures
54.1%
54.0%
59.9%
Impairment allowances (for Stage 3 receivables and POCI non-performing) to Loans and advances to Customers Stage 3 and POCI non-performing
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Results of the business segments
Retail and Business Banking
Commercial volumes
As at 31 December 2025, deposits of Retail and Business Banking Customers on a consolidated basis stood at PLN
79,658,247 thousand, up by PLN 6,995,316 thousand i.e. 9.6% year on year. The biggest increase by value was reported for
savings accounts (by PLN 2,867,518 thousand i.e. 22.5%) and current accounts (by PLN 2,584,488 thousand i.e. 7.9%). Term
deposits increased by PLN 1,235,365 thousand i.e. 4.7% year on year.
The largest category of deposits by maturity are current accounts with a share of 44.5% as at 31 December 2025 (-0.7 p.p.
year on year). The share of savings accounts increased by 2.1 p.p. to 19.6% while the share of term deposits decreased (by
1.7 p.p. to 34.8%).
The net portfolio of loans and advances in Retail and Business Banking on a consolidated basis as at 31 December 2025
was PLN 43,784,123 thousand, an increase of PLN 1,355,376 thousand i.e. 3.2% year on year. The biggest increase by value
was reported for mortgage loans by PLN 1,161,283 thousand i.e. 5.8%. Consumer loans increased by PLN 513,669 thousand
i.e. 4.5% while investment loans increased by PLN 305,975 thousand i.e. 6.8%.
The volume of gross foreign currency housing loans (no longer offered since 2008-2009) was PLN 272,724 thousand as at
31 December 2025 (PLN 427,354 thousand as at 31 December 2024). CHF loans represented 93.2% of the portfolio. The
reduction in the portfolio was the result of repayments and settlements with Customers. The portfolio value in CHF
decreased by 37.4% year on year. The share of these loans in the total gross loan portfolio measured at amortised cost
decreased to 0.3% as at 31 December 2025 (from 0.5% as at 31 December 2024).
Table 43. Retail and Business Banking deposits and loans
1
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Current accounts
35,443,485
32,858,997
2,584,488
7.9%
Savings accounts
15,614,583
12,747,065
2,867,518
22.5%
Term deposits
27,734,042
26,498,676
1,235,365
4.7%
Overnight
866,137
558,192
307,945
55.2%
Accounts and deposits
79,658,247
72,662,930
6,995,316
9.6%
Consumer loans
11,856,910
11,343,241
513,669
4.5%
1
The volumes of deposits and loans for selected segments are presented on the basis of management information system data, due to the availability of more
detailed product information. To ensure comparability, the data as at 31 December 2024 are presented in accordance with the segmentation applied in 2025. The
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Investment loans
4,808,021
4,502,047
305,975
6.8%
Overdrafts
3,353,744
3,935,083
(581,339)
(14.8%)
Mortgage loans
21,086,473
19,925,190
1,161,283
5.8%
Leasing receivables
1,898,101
1,894,859
3,242
0.2%
Credit cards
779,415
826,376
(46,961)
(5.7%)
Other loans
1,458
1,951
(492)
(25.2%)
Loans and advances (net)
43,784,123
42,428,747
1,355,376
3.2%
Profit before tax
Retail and Business Banking generated a profit before tax of PLN 1,079,492 thousand in 2025 (PLN 742,607 thousand in
2024), up by PLN 336,885 thousand i.e. 45.4% year on year, mainly due to a lower negative impact of the legal risk of
foreign currency loans (improvement by PLN 296,977 thousand i.e. 37.3%).
Net banking income was PLN 3,997,677 thousand in 2025, up by PLN 120,879 thousand i.e. 3.1% year on year. Net interest
income and net fee and commission income increased year on year by PLN 61,172 thousand (PLN 1.9%) and by PLN 29,346
thousand (4.4%), respectively.
Net banking income represented 48.7% of the Group’s profit in 2025. Personal Finance contributed 21.4% of net banking
income of Retail and Business Banking (down by 1.3 p.p. year on year).
As at 31 December 2025, Retail and Business Banking served 2,659,100 Customers (individuals and micro-enterprises).
The year-on-year decrease in the number of Customers was the result of a review of the Customer base in 2025, closing of
inactive accounts, and changes to the definition of retail Customer: under the new definition, retail Customers have an
active contractual relationship.
deposit volume does not include the balances of certain credit institutions which, in management reporting, are treated as interbank deposits, whereas in financial
reporting they are recognised under Customer deposits; moreover, the balances do not include accrued but not yet due interest.
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Table 44. Profit before tax of the Retail and Business Banking segment
2
PLN’000
12 months
12 months
change
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Net interest income
3,226,340
3,165,168
61,172
1.9%
Net fee and commission income
701,317
671,971
29,346
4.4%
Net trading and other income
70,020
39,659
30,361
76.6%
Net banking income
3,997,677
3,876,798
120,879
3.1%
Net allowances on expected credit losses
(6,447)
(1,369)
(5,078)
370.9%
Result on legal risk related to foreign currency loans
(498,751)
(795,728)
296,977
(37.3%)
Operating expenses and depreciation and amortisation
(1,322,663)
(1,232,443)
(90,220)
7.3%
Cost allocation
(879,473)
(919,912)
40,439
(4.4%)
Operating profit
1,290,343
927,345
362,998
39.1%
Tax on financial institutions
(210,851)
(184,739)
(26,112)
14.1%
Segment profit before tax
1,079,492
742,606
336,886
45.4%
Bank guarantees
In 2025, the Bank issued 17 bank guarantees for Business Banking Customers in the total amount of PLN 2.2 million.
Corporate and SME Banking
Commercial volumes
Corporate Banking
As at 31 December 2025, deposit of Corporate Banking Customers stood at PLN 43,967,963 thousand, up by PLN 2,711,949
thousand i.e. 6.6% year on year. The share of term deposits in the mix increased (from 22.1% as at 31 December 2024 to
2
Data based on the segment note included in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the year ended 31 December
2025.
3
The volumes of deposits and loans for selected segments are presented on the basis of management information system data, due to the availability of more
detailed product information. To ensure comparability, the data as at 31 December 2024 are presented in accordance with the segmentation applied in 2025. The
24.5% as at 31 December 2025) while the share of current accounts decreased (from 77.0% as at 31 December 2024 to
74.9% as at 31 December 2025).
The net portfolio of loans and advances in Corporate Banking Customers on a consolidated basis as at 31 December 2025
stood at PLN 32,192,258 thousand, up by PLN 3,177,004 thousand i.e. 10.9% year on year. The biggest increase by value was
reported for overdrafts (by PLN 2,388,166 thousand) and investment loans (by PLN 882,357 thousand).
Table 45. Corporate Banking deposits and loans
3
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Current accounts
32,950,982
31,785,313
1,165,669
3.7%
Savings accounts
1,798
2,416
(618)
(25.6%)
Term deposits
10,769,771
9,097,787
1,671,984
18.4%
Overnight
245,412
370,497
(125,085)
(33.8%)
Accounts and deposits
43,967,963
41,256,014
2,711,949
6.6%
Investment loans
18,036,509
17,154,152
882,357
5.1%
Overdrafts
12,080,049
9,691,883
2,388,166
24.6%
Leasing receivables
1,819,250
1,926,914
(107,664)
(5.6%)
Factoring
255,206
239,727
15,479
6.5%
Other loans
1,245
2,578
(1,333)
(51.7%)
Loans and advances (net)
32,192,258
29,015,254
3,177,004
10.9%
Small and Medium-sized Enterprise Banking
As at 31 December 2025, deposits of SME Banking Customers on a consolidated basis stood at PLN 17,014,663 thousand, up
by PLN 488,994 thousand i.e. 3.0% year on year. The increase was reported in current accounts, up by PLN 802,043
thousand i.e. 6.3%. This was partly offset by a decrease in term deposits by PLN 280,814 thousand i.e. 7.7%. Current
accounts represented 80.1% of deposits of SME Banking Customers and their share increased from 77.6% as at 31 December
2024. The share of term deposits decreased from 21.9% as at 31 December 2024 to 19.7% as at 31 December 2025.
The net portfolio of loans and advances in SME Banking on a consolidated basis remained stable. It stood at PLN 6,054,517
thousand as at 31 December 2025, down modestly by PLN 41,956 thousand (0.7%) year on year. Investment loans increased
deposit volume does not include the balances of certain credit institutions which, in management reporting, are treated as interbank deposits, whereas in financial
reporting they are recognised under Customer deposits; moreover, the balances do not include accrued but not yet due interest
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by PLN 72,684 thousand while overdrafts decreased (by PLN 67,144 thousand), as did lease receivables (by PLN 47,570
thousand).
Table 46. Small and Medium-sized Enterprise Banking
deposits and loans
4
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Current accounts
13,632,036
12,829,993
802,043
6.3%
Savings accounts
29,142
53,756
(24,614)
(45.8%)
Term deposits
3,345,309
3,626,124
(280,814)
(7.7%)
Overnight
8,174
15,795
(7,620)
(48.2%)
Accounts and deposits
17,014,663
16,525,668
488,994
3.0%
Investment loans
3,062,090
2,989,406
72,684
2.4%
Overdrafts
2,523,095
2,590,239
(67,144)
(2.6%)
Leasing receivables
467,335
514,905
(47,570)
(9.2%)
Factoring
247
249
(2)
(0.7%)
Other Loans
1,749
1,673
77
4.6%
Loans and advances (net)
6,054,517
6,096,472
(41,956)
(0.7%)
Profit before tax
Corporate Banking
Corporate Banking generated a profit before tax of PLN 1,284,790 thousand in 2025 (PLN 1,310,851 thousand in 2024, down
by PLN 26,061 thousand i.e. 2.0% year on year). The decrease in profit before tax was mainly due to lower net banking
income (down by PLN 72,543 thousand i.e. 3.1% year on year), partly offset by lower negative impact of impairment (by PLN
44.842 thousand i.e. 21.7% year on year).
Net banking income of Corporate Banking was PLN 2,246,474 thousand, down by PLN 72,543 thousand i.e. 3.1% year on year
due to lower net interest income, down by PLN 117,700 thousand i.e. 7.4% year on year. Net fee and commission income
4
The volumes of deposits and loans for selected segments are presented on the basis of management information system data, due to the availability of more
detailed product information. To ensure comparability, the data as at 31 December 2024 are presented in accordance with the segmentation applied in 2025. The
deposit volume does not include the balances of certain credit institutions which, in management reporting, are treated as interbank deposits, whereas in financial
reporting they are recognised under Customer deposits; moreover, the balances do not include accrued but not yet due interest.
increased by PLN 7,692 thousand i.e. 2.0% year on year while net trading income and other income increased by PLN 37,465
thousand i.e. 10.5%. Net banking income of Corporate Banking contributed 27.4% to the Group’s net banking income in 2025.
Operating expenses, depreciation and amortisation, and allocated expenses remained stable at PLN 677,117 thousand in
2025 (+0.1% year on year).
Table 47. Profit before tax of the Corporate Banking segment
5
PLN’000
12 months
12 months
change
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Net interest income
1,464,281
1,581,981
(117,700)
(7.4%)
Net fee and commission income
388,384
380,692
7,692
2.0%
Net trading and other income
393,809
356,344
37,465
10.5%
Net banking income
2,246,474
2,319,017
(72,543)
(3.1%)
Net allowances on expected credit losses
(161,511)
(206,353)
44,842
(21.7%)
Operating expenses and depreciation and amortisation
(491,188)
(449,459)
(41,729)
9.3%
Cost allocation
(185,929)
(227,015)
41,086
(18.1%)
Operating profit
1,407,846
1,436,190
(28,344)
(2.0%)
Tax on financial institutions
(123,056)
(125,339)
2,283
(1.8%)
Segment profit before tax
1,284,790
1,310,851
(26,061)
(2.0%)
SME Banking
SME Banking generated a profit before tax of PLN 475,168 thousand in 2025 (PLN 441,352 thousand in 2024, up by PLN
33,816 thousand i.e. 7.7% year on year). The increase in profit before tax was mainly due to high positive contribution of
impairment (+PLN 56,619 thousand in 2025 vs. +PLN 555 thousand in 2024) and lower operating expenses.
Net banking income of SME Banking was PLN 791,721 thousand in 2025, down by PLN 34,729 thousand i.e. 4.2% year in
year as a result of lower net interest income (down by PLN 43,842 thousand i.e. 7.1% year on year) and lower net fee and
commission income (down by PLN 4,087 thousand i.e. 3.1% year on year) combined with an increase in net trading income
5
Data based on the segment note included in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the year ended 31 December
2025.
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and other income by PLN 13,200 thousand i.e. 17.9%. Net banking income of SME Banking contributed 9.7% to the Group’s
net banking income in 2025.
Operating expenses, depreciation and amortisation, and allocated expenses in 2025 decreased by PLN 18,017 thousand i.e.
5.0% year on year.
Table 48. Profit before tax of the Small and Medium-sized Enterprises Banking segment
6
PLN’000
12 months
12 months
change
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Net interest income
577,160
621,002
(43,842)
(7.1%)
Net fee and commission income
127,683
131,770
(4,087)
(3.1%)
Net trading and other income
86,878
73,678
13,200
17.9%
Net banking income
791,721
826,450
(34,729)
(4.2%)
Net allowances on expected credit losses
56,619
555
56,064
10,101.6%
Operating expenses and depreciation and amortisation
(106,491)
(130,377)
23,886
(18.3%)
Cost allocation
(234,928)
(229,059)
(5,869)
2.6%
Operating profit
506,921
467,570
39,351
8.4%
Tax on financial institutions
(31,753)
(26,218)
(5,535)
21.1%
Segment profit before tax
475,168
441,352
33,816
7.7%
6
Data based on the segment note included in the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the year ended 31 December
2025.
Bank guarantees
With guarantees and letters of credit, the Bank offers quick and comprehensive service based on dedicated IT solutions.
In 2025, by order of Customers of:
• Corporate Banking, the Bank issued 5,794 bank guarantees in a total amount of PLN 4,042.9 million, opened 900 import
letters of credit in a total amount of PLN 606.4 million, and processed 314 export letters of credit in a total amount of
PLN 804.5 million issued by third-party banks to Customers,
• SME Banking, the Bank issued 651 bank guarantees in a total amount of PLN 174.5 million, opened 76 import letters of
credit in a total amount of PLN 20.2 million, and processed 48 export letters of credit in a total amount of PLN 43.2
million issued by third-party banks to Customers.
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Financial results of the Bank
Separate statement of profit or loss
The Bank’s net banking income in 2025 stood at PLN 7,979,642 thousand, up by PLN 417,959 thousand i.e. 5.5% year on
year. Significant factors influencing net banking income in 2025 and in 2024 included macroeconomic conditions and the
interest rate policy of central banks, impacting among others Customers’ economic activity and the situation on the
financial markets. The key factors driving the Bank’s results included:
• NBP interest rates. From October 2023 until early May 2025, the NBP interest rates remained unchanged (5.75% for the
reference rate). In 2025, the Monetary Policy Council (RPP) introduced six rate cuts, bringing the reference rate down to
4.00%. These reductions contributed to lower profitability of PLN loans with variable interest rates in 2025 compared with
2024. A potential continuation of rate cuts in 2026 would negatively affect PLN margins generated by banks,
• the monetary policy easing cycle launched by the European Central Bank in June 2024. By the end of July 2025, nine rate
cuts had been implemented, reducing the deposit facility rate by 200 bps (to 2.0%). These changes lowered the
profitability of variable rate loans granted in EUR,
• a strong liquidity position of Customers, leading to an increase in deposit volumes, enabling further growth in the scale of
operations,
• the absence of a negative impact on the 2025 net interest income from the amendment to the statutory mortgage
payment holiday scheme, which took effect in mid-May 2024,
• volatility in financial markets, including fluctuations in the PLN exchange rate against major currencies in the first half of
2025, driven among other factors by geopolitical conditions (including U.S. trade policy) and political uncertainty
(including the presidential election in Poland). This volatility increased Customer demand for hedging instruments,
positively impacting banks’ financial results,
• favourable market conditions and rising stock prices on the Warsaw Stock Exchange, combined with declining deposit
interest rates, which supported Customer interest in asset management and brokerage services and contributed to higher
fee and commission income for banks.
Net interest income, which is the biggest item of net banking income, stood at PLN 5,780,421 thousand in 2025, up by PLN
148,608 thousand (2.6%) year on year. Despite falling profitability of loans, this was possible thanks to gains on liquidity
invested in securities and financial instruments, higher interest income on hedging derivatives, and optimised cost of
deposits.
The net banking income item to improve the most was net trading income, which stood at PLN 1,076,959 thousand in 2025
(up by PLN 211,752 thousand or 24.5% year on year). The improvement was driven among others by higher gains on
financial instrument transactions in asset and liability management, higher gains on margins on currency exchange and
derivatives transactions with Customers (including several large transactions with Customers in H1 2025), and improved
gains on equity investments.
The negative impact of the legal risk of court cases concerning foreign currency mortgage loans remains a significant factor
affecting the Group’s net profit. In 2025, thanks to gradual reduction of the portfolio and an observed decrease in the
number of new court cases, the charge to the Group’s results was PLN 498,751 thousand, down by PLN 296,977 thousand
year on year.
The quality of the loan portfolio remained strong in 2025, as confirmed by lower migration to Stage 3 and recovery on non-
performing loans combined with no additional provisions for expected future materialisation of the cost of risk in the
institutional portfolio (Post Model Adjustment), which had been set up in 2024. As a result, the negative impact on
provisions for expected credit losses on financial assets and provisions for contingent liabilities stood at PLN 155,350
thousand in 2025, compared to a negative impact of PLN 225,350 thousand in 2024 (improvement by PLN 70,000
thousand).
General administrative expenses, depreciation and amortisation stood at PLN 3,240,933 thousand in 2025, up by only PLN
8,938 thousand (0.3%) year on year, despite an increase in the total cost of the Bank Guarantee Fund by PLN 52,343
thousand (net of the BFG cost, total costs would have decreased by PLN 43,405 thousand, i.e. 1.4%). General administrative
expenses in 2025 were positively impacted by a review of the cost base, in particular the costs of advisory services,
including services provided by the Group, and the costs of legal advisory on the CHF mortgage loan portfolio.
A change of the corporate income tax rate under the Act amending the Corporate Income Tax Act and the Act on Tax on
Certain Financial Institutions adopted in Q4 2025 resulted in reevaluation of the deferred tax asset and liability using the
future tax rates. The positive impact of the reevaluation on the Group’s result as at 31 December 2025 was PLN 174,116
thousand, recognised by the Group in Q4 2025.
A positive financial impact of deferred tax, based on provisions against future payments relating to the cancellation of CHF
loans, was recognised at PLN 135,535 thousand in 2024.
BNP Paribas Bank Polska S.A. generated a net profit of PLN 3,012,195 thousand in 2025, up by PLN 691,397
thousand i.e. 29.8% year on year.
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Table 49. Statement of profit or loss
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Net interest income
5,780,421
5,631,813
148,608
2.6%
Net fee and commission income
1,181,514
1,188,293
(6,779)
(0.6%)
Dividend income
18,118
13,147
4,971
37.8%
Net trading income
1,076,959
865,207
211,752
24.5%
Result on investment activities
(2,340)
14,374
(16,714)
-
Result on hedge accounting
(11,161)
1,946
(13,107)
-
Result on derecognition of financial assets measured at
amortized cost due to significant modification
(19,698)
(35,739)
16,041
(44.9%)
Other operating income and expenses
(44,171)
(117,358)
73,187
(62.4%)
Net banking income
7,979,642
7,561,683
417,959
5.5%
Net allowances on expected credit losses on financial
assets and provisions for contingent liabilities
(155,350)
(225,350)
70,000
(31.1%)
Result on legal risk related to foreign currency loans
(498,751)
(795,728)
296,977
(37.3%)
General administrative expenses
(2,712,043)
(2,717,137)
5,094
(0.2%)
Depreciation and amortisation
(528,890)
(514,858)
(14,032)
2.7%
Operating profit
4,084,608
3,308,610
775,998
23.5%
Tax on financial institutions
(393,352)
(404,971)
11,619
(2.9%)
Profit before tax
3,691,256
2,903,639
787,617
27.1%
Income tax expenses
(679,061)
(582,841)
(96,220)
16.5%
Net profit
3,012,195
2,320,798
691,397
29.8%
Note: Due to rounding, individual values presented in the tables and charts of these Financial Statements may not sum up.
Net interest income
Net interest income, which is the Bank’s biggest revenue stream, stood at PLN 5,780,421 thousand in 2025, up by PLN
148,608 thousand i.e. 2.6% year on year. Interest income in 2025 was down by PLN 322,270 thousand i.e. 3.3% year on year
while interest expenses went down by PLN 470,878 thousand i.e. 11.0%.
Table 50. Net interest income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Amounts due from banks
512,156
423,790
88,366
20.9%
Loans and advances to Customers measured at amortised
cost
5,999,884
6,404,285
(404,401)
(6.3%)
Loans and advances to Customers measured at fair value
through profit or loss
29,955
50,227
(20,272)
(40.4%)
Debt instruments measured at amortised cost
1,335,267
972,653
362,614
37.3%
Debt instruments measured at fair value through profit or
loss
5,216
7,466
(2,250)
(30.1%)
Debt instruments measured at fair value through other
comprehensive income
922,091
850,362
71,729
8.4%
Derivative instruments as part of fair value hedge
accounting
737,283
854,393
(117,110)
(13.7%)
Derivative instruments as part of cash flow hedge
accounting
39,312
11,628
27,684
238.1%
Repo transactions
2,003
330,633
(328,630)
(99.4%)
Total interest income
9,583,167
9,905,437
(322,270)
(3.3%)
Amounts due to banks
(399,902)
(496,001)
96,099
(19.4%)
Liabilities under issued debt securities
(42,071)
-
(42,071)
-
Amounts due to Customers
(2,275,268)
(2,436,587)
161,319
(6.6%)
Lease liabilities
(20,748)
(23,274)
2,526
(10.9%)
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PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Derivative instruments as part of fair value hedge
accounting
(980,603)
(1,275,490)
294,887
(23.1%)
Derivative instruments as part of cash flow hedge
accounting
(63,816)
(36,561)
(27,255)
74.5%
Repo transactions
(20,338)
(5,711)
(14,627)
256.1%
Others related to financial assets
-
-
-
-
Total interest expense
(3,802,746)
(4,273,624)
470,878
(11.0%)
Net interest income
5,780,421
5,631,813
148,608
2.6%
Net fee and commission income
The Bank’s net fee and commission income was PLN 1,181,514 thousand in 2025, down by PLN 20,997 thousand i.e. 1.7%
year on year. The decrease was mainly due to lower income on loans in Retail and Business Banking, including loans to
farmers, lower income on settlements with Cardif in respect of sales of life insurance linked to cash loans and mortgage
loans, and income on bank accounts.
Table 51. Net fee and commission income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Fee and commission income
loans, advances and leases
251,909
269,543
(17,634)
(6.5%)
account maintenance
223,030
232,545
(9,515)
(4.1%)
cash service
30,353
31,462
(1,109)
(3.5%)
cash transfers and e-banking
101,898
108,047
(6,149)
(5.7%)
guarantees and documentary operations
76,384
77,320
(936)
(1.2%)
asset management and brokerage operations
118,389
103,118
15,271
14.8%
payment and credit cards
423,611
414,307
9,304
2.2%
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
insurance mediation activity
137,856
148,945
(11,089)
(7.4%)
product sale mediation and Customer acquisition
22,185
23,781
(1,596)
(6.7%)
other commissions
53,861
57,990
(4,129)
(7.1%)
Total fee and commission income
1,439,476
1,467,058
(27,582)
(1.9%)
Fee and commission expense
loans, advances and leases
(458)
(998)
540
(54.1%)
account maintenance
(9,398)
(9,774)
376
(3.8%)
cash service
(30,466)
(28,566)
(1,900)
6.7%
cash transfers and e-banking
(3,369)
(2,765)
(604)
21.8%
guarantees and documentary transactions
(4,337)
(9,120)
4,783
(52.4%)
asset management and brokerage operations
(7,279)
(5,428)
(1,851)
34.1%
payment and credit cards
(108,468)
(121,800)
13,332
(10.9%)
insurance mediation activity
(19,692)
(21,487)
1,795
(8.4%)
product sale mediation and Customer acquisition
(23,742)
(23,011)
(731)
3.2%
other commissions
(50,753)
(55,816)
5,063
(9.1%)
Total fee and commission expenses
(257,962)
(278,765)
20,803
(7.5%)
Net fee and commission income
1,181,514
1,188,293
(6,779)
(0.6%)
Dividend income
Dividend income in 2025 totalled PLN 18,118 thousand and was paid from the profits of companies for 2024 in which the
Bank held a minority interest, i.e.: among others, Biuro Informacji Kredytowej S.A. (PLN 4,251 thousand), Krajowa Izba
Rozliczeniowa S.A. (PLN 2,473 thousand), VISA (PLN 328 thousand) and Mastercard (PLN 125 thousand).
Dividend income in 2024 totalled PLN 13,147 thousand and was paid the profits of companies for 2023 in which the Bank
held a minority interest, i.e.: among others, Biuro Informacji Kredytowej S.A. (PLN 4,131 thousand), Krajowa Izba
Rozliczeniowa S.A. (PLN 2,125 thousand), VISA (PLN 1,614 thousand) and Mastercard (PLN 235 thousand).
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Net trading income and result on investment activities
Net trading income was PLN 1,076,959 thousand in 2025, up by PLN 211,752 thousand i.e. 24.5% year on year. The level
and volatility of this result are mainly shaped by the result on foreign exchange and derivative transactions with
Customers, the result on transactions concluded by CIB and the Asset and Liability Management Division, and the valuation
of equity instruments.
The result on investment activities in 2025 was PLN 673 thousand, down by PLN 16,714 thousand i.e. 16.3% year on year.
Other operating income
Other operating income was PLN 206,186 thousand in 2025, up by PLN 89,556 thousand i.e. 76.8% year on year.
Table 52. Other operating income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Sale or liquidation of property, plant and equipment and
intangible assets
32,579
19,233
13,346
69.4%
Impairment allowances on other receivables
5,011
7,907
(2,896)
(36.6%)
Sale of goods and services
17,592
8,651
8,941
103.4%
Release of provisions for litigation and claims and other
liabilities
83,212
19,460
63,752
327.6%
Recovery of debt enforcement costs
18,039
19,723
(1,684)
(8.5%)
Recovered compensation
-
-
-
-
Leasing operations
15,555
18,940
(3,385)
(17.9%)
Other operating income
34,198
36,934
(2,736)
(7.4%)
Total other operating income
206,186
130,848
75,338
57.6%
Other operating costs
Other operating costs stood at PLN 250,357 thousand in 2025, up by PLN 2,151 thousand i.e. 0.9% year on year.
Table 53. Other operating expenses
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Loss on sale or liquidation of property, plant and
equipment and intangible assets
(10,095)
(13,614)
3,519
(25.8%)
Impairment allowances on other receivables
(6,893)
(10,836)
3,943
(36.4%)
Provisions for litigation and claims and branches
restructuring
(48,051)
(59,407)
11,356
(19.1%)
Debt enforcement
(31,993)
(36,200)
4,207
(11.6%)
Donations made
(9,304)
(7,779)
(1,525)
19.6%
Costs of leasing operations
(12,278)
(20,318)
8,040
(39.6%)
Costs of compensations, penalties and fines
-
-
-
-
Other operating expenses
(131,743)
(100,052)
(31,691)
31.7%
Total other operating expenses
(250,357)
(248,206)
(2,151)
0.9%
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Net allowances on expected credit losses of financial assets and provisions for contingent liabilities
Net allowances on expected credit losses of financial assets and provisions for contingent liabilities in 2025 stood at
a negative PLN 155,350 thousand compared to a negative PLN 225,350 thousand in 2024 (improvement by PLN 70,000
thousand i.e. 31.1% year on year).
In 2025, the Bank entered into agreements to sell retail, SME and corporate portfolios. The gross carrying amount of the
sold portfolio measured at amortised cost was PLN 273,916 thousand, the amount of impairment allowances created was
PLN 219,696 thousand. The contractual price for the sale of these portfolios was set at PLN 82,392 thousand. The net
impact on the Bank’s result due to the sale of portfolios amounted to PLN 28,172 thousand and is presented under Net
allowances on expected credit losses of financial assets and provisions for contingent liabilities.
In 2024, the Bank entered into agreements to sell retail, SME and corporate portfolios. The gross carrying amount of the
sold portfolio measured at amortised cost was PLN 430,520 thousand, the amount of impairment allowances created was
PLN 291,643 thousand. The contractual price for the sale of these portfolios was set at PLN 198,143 thousand. The net
impact on the Bank’s result due to the sale of portfolios amounted to PLN 59,266 thousand and is presented under Net
allowances on expected credit losses of financial assets and provisions for contingent liabilities.
The cost of credit risk, measured as the result on allowances to the average gross loans and advances to Customers
measured at amortised cost (calculated on the basis of balances at the end of each quarter), was 0.18% in 2025 compared
with 0.27% in 2024. Net of the impact of the sale of loans, the estimated cost of risk would be 0.21% in 2025 and 0.34% in
2024.
General administrative expenses, depreciation and amortisation
General administrative expenses (combined with depreciation and amortisation) of the Bank stood at PLN 3,240,933
thousand in 2025, up by PLN 8,939 thousand i.e. 3.0% year on year.
Table 54. General administrative expenses and depreciation and amortisation
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Personnel expenses
(1,586,863)
(1,528,680)
(58,183)
3.8%
Marketing
(121,595)
(103,893)
(17,702)
17.0%
IT and telecom expenses
(334,468)
(305,169)
(29,299)
9.6%
Short-term leases and exploitation
(88,863)
(82,622)
(6,241)
7.6%
Other non-personnel expenses
(141,122)
(148,261)
7,139
(4.8%)
External services under other contracts and consulting
(93,460)
(265,940)
172,480
(64.9%)
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Business travel
(12,107)
(11,631)
(476)
4.1%
Vehicle maintenance costs
(28,397)
(26,107)
(2,290)
8.8%
ATM and cash handling expenses
(31,448)
(29,952)
(1,496)
5.0%
Costs of outsourcing services related to leasing operations
(918)
(1,445)
527
(36.5%)
Court and notary fees
(53,626)
(49,366)
(4,260)
8.6%
Bank Guarantee Fund fee
(196,335)
(143,992)
(52,343)
36.4%
Commercial Bank Protection Scheme fee
-
-
-
-
Cost of PFSA supervision
(22,841)
(20,079)
(2,762)
13.8%
Total general administrative expenses
(2,712,043)
(2,717,137)
5,094
(0.2%)
Depreciation and amortisation
(528,890)
(514,858)
(14,032)
2.7%
Total expenses
(3,240,933)
(3,231,995)
(8,938)
0.3%
Table 55. Personnel expenses
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Payroll expenses
(1,265,223)
(1,226,044)
(39,179)
3.2%
Payroll charges
(228,361)
(218,156)
(10,205)
4.7%
Employee benefits
(58,456)
(58,002)
(454)
0.8%
Costs of restructuring provision
(1,904)
(649)
(1,255)
193.4%
Costs of provision for future liabilities arising from unused
annual leave and retirement benefits
(5,966)
(5,237)
(729)
13.9%
Appropriations to Social Benefits Fund
(23,160)
(19,074)
(4,086)
21.4%
Other
(3,793)
(1,518)
(2,275)
149.9%
Total personnel expenses
(1,586,863)
(1,528,680)
(58,183)
3.8%
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The Bank’s capital expenditure amounted to PLN 442,242 thousand in 2025 and was stable year on year (PLN 442,757
thousand in 2024). The expenditure mix changed. Expenditure increased year on year in 2025 for computer hardware by
PLN 20,809 thousand and leasehold improvements by PLN 7,424 thousand. At the same time, expenditure on external staff
costs decreased by PLN 14,524 thousand and expenditure for intangible assets decreased by PLN 7,869 thousand. Capital
expenditure is aligned with the Bank’s current needs and capabilities. All projects are analysed from the point of view of
rationality and impact on the financial and business situation of the Bank and the Group.
Statement of comprehensive income
The Bank’s total comprehensive income in 2025 amounted to PLN 3,369,278 thousand, an increase of PLN 1,022,600
thousand, or 43.6%, compared with 2024 (PLN 2,346,678 thousand). The increase in comprehensive income was driven by:
• an increase in net profit by PLN 691,397 thousand, i.e. 29.8% year on year,
• valuation of financial assets measured through other comprehensive income (improvement by PLN 303,531 thousand);
• valuation of cash flow hedging derivatives (improvement by PLN 88,283 thousand).
Table 56. Statement of comprehensive income
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Net profit
3,012,195
2,320,798
691,397
29.8%
Other comprehensive income
Items that may be reclassified subsequently to profit or
loss upon fulfilment of certain conditions
356,033
27,255
328,778
1,206.3%
Measurement of financial assets measured at fair
value through other comprehensive income, gross
347,318
43,787
303,531
693.2%
Deferred income tax on the valuation of gross
financial assets measured through other
comprehensive income
(56,160)
(8,320)
(47,840)
575.0%
Measurement of cash flow hedge accounting
derivatives
78,145
(10,138)
88,283
-
Deferred income tax on valuation of gross derivatives
hedging cash flows
(13,270)
1,926
(15,196)
-
Items that will not be reclassified to profit or loss
1,050
(1,375)
2,425
(176.4%)
PLN’000
12 months
12 months
change y/y
ended
31.12.2025
ended
31.12.2024
PLN’000
%
Actuary valuation of employee benefits
1,576
(1,698)
3,274
(192.8%)
Deferred income tax on actuarial valuation of gross
personnel expenses
(526)
323
(849)
(262.8%)
Other comprehensive income (net)
357,083
25,880
331,203
1,279.8%
Total comprehensive income
3,369,278
2,346,678
1,022,600
43.6%
Statement of financial position
Assets
The Bank’s total assets as at 31 December 2025 stood at PLN 176,310,134 thousand, up by PLN 13,222,633 i.e. 8.1% year on
year.
Table 57. Assets
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Cash and balances at Central Bank
10,224,866
11,325,551
(1,100,685)
(9.7%)
Amounts due from banks
11,524,131
7,789,297
3,734,834
47.9%
Derivative financial instruments
2,359,460
2,440,116
(80,656)
(3.3%)
Differences from hedge accounting
345,550
230,658
114,892
49.8%
Loans and advances to Customers measured at amortised
cost
86,786,401
81,189,258
5,597,143
6.9%
Loans and advances to Customers measured at fair value
through profit or loss
286,183
452,506
(166,323)
(36.8%)
Securities measured at amortised cost
36,180,626
32,364,550
3,816,076
11.8%
Securities measured at fair value through profit or loss
240,409
320,925
(80,516)
(25.1%)
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PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Securities at fair value through other comprehensive
income
24,719,802
23,027,454
1,692,348
7.3%
Intangible assets
965,224
978,163
(12,939)
(1.3%)
Property, plant and equipment
947,435
946,796
639
0.1%
Deferred tax assets
710,964
685,634
25,330
3.7%
Current income tax assets
-
-
-
-
Other assets
910,657
1,228,167
(317,510)
(25.9%)
Total assets
176,310,134
163,087,501
13,222,633
8.1%
Loan portfolio
Loan portfolio structure
As at 31 December 2025, gross loans and advances to Customers (the sum of portfolios measured at amortised cost and
measured at fair value) stood at PLN 89,322,538 thousand, up by PLN 5,273,494 thousand i.e. 6.3% year on year.
Table 58. Structure of the loan portfolio measured at amortised cost
PLN’000
31.12.2025
31.12.2024
total gross
% share
total gross
% share
Corporate Customers, excluding farmers
40,807,638
45.9%
36,190,293
43.3%
Farmers
7,296,966
8.2%
7,769,080
9.3%
Retail Customers
34,428,276
38.7%
32,858,093
39.3%
- mortgage loans
21,335,075
24.0%
20,207,062
24.2%
PLN
21,062,351
23.7%
19,779,708
23.7%
foreign currency
272,724
0.3%
427,354
0.5%
- cash loans
8,604,762
9.7%
8,487,233
10.2%
- other retail loans
4,488,439
5.0%
4,163,798
5.0%
Lease receivables
96,632
0.1%
151,860
0.2%
PLN’000
31.12.2025
31.12.2024
total gross
% share
total gross
% share
Public sector institutions
218,025
0.2%
67,960
0.1%
Non-bank financial entities
6,122,520
6.9%
6,484,263
7.8%
Gross loans and advances
88,970,057
100.0%
83,521,549
100.0%
Quality of the loan portfolio
The share of Stage 3 and POCI non-performing exposures in gross loans and advances to Customers measured at amortised
cost stood at 2.7% as at 31 December 2025, a decrease by 0.5 p.p. year on year The provision coverage of impaired
exposures as at 31 December 2025 was 56.1% (up 0.3 p.p. year on year).
Table 59. Coverage of the loan portfolio measured at amortised cost with impairment losses
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Gross loans and advances to Customers, total
88,970,057
83,521,549
5,448,508
6.5%
Allowances for receivables
(2,183,656)
(2,332,291)
148,635
(6.4%)
Net loans and advances to Customers, total
86,786,401
81,189,258
5,597,143
6.9%
Non-impaired exposures (Stage 1 and 2) and POCI
performing
Gross balance sheet exposure
86,606,901
80,886,813
5,720,088
7.1%
Allowance
(857,073)
(860,335)
3,262
(0.4%)
Net balance sheet exposure
85,749,828
80,026,478
5,723,350
7.2%
Impaired exposures (Stage 3) and POCI non-performing
Gross balance sheet exposure
2,363,156
2,634,736
(271,580)
(10.3%)
Impairment allowance
(1,326,583)
(1,471,956)
145,373
(9.9%)
Net balance sheet exposure
1,036,573
1,162,780
(126,207)
(10.9%)
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Indicators
31.12.2025
31.12.2024
change
Share of Stage 3 and POCI non-performing in the gross
portfolio
2.7%
3.2%
(0.5 p.p.)
Provision coverage of Stage 3 and POCI non-performing
exposures
56.1%
55.9%
+0.3 p.p.
Table 60. Quality of the loan portfolio measured at amortised cost
PLN’000
31.12.2025
31.12.2024
total gross
NPL*
% share
total gross
NPL*
% share
Corporate Customers, excluding
farmers
40,807,638
1,428,061
3.5%
36,190,293
1,479,716
4.1%
Farmers
7,296,966
268,375
3.7%
7,769,080
405,438
5.2%
Retail Customers
34,428,276
655,764
1.9%
32,858,093
715,413
2.2%
- mortgage loans
21,335,075
256,086
1.2%
20,207,062
288,465
1.4%
PLN
21,062,351
157,108
0.7%
19,779,708
172,862
0.9%
foreign currency
272,724
98,978
36.3%
427,354
115,603
27.1%
- cash loans
8,604,762
297,580
3.5%
8,487,233
320,712
3.8%
- other retail loans
4,488,439
102,098
2.3%
4,163,798
106,236
2.6%
Lease receivables
96,632
7,867
8.1%
151,860
24,894
16.4%
Public sector institutions
218,025
-
-
67,960
-
-
Non-bank financial entities
6,122,520
3,089
0.1%
6,484,263
9,275
0.1%
Gross loans and advances
88,970,057
2,363,156
2.7%
83,521,549
2,634,736
3.2%
* NPL defined as loans and advances in Stage 3 and POCI non-performing according to the information presented in Note 21 to the Separate Financial Statements
The value of collateral held for Customer loans as at 31 December 2025 amounted to PLN 1,592,896 thousand
(PLN 1,792,387 thousand as at 31 December 2024). Details of collateral held are presented in Note 55.2. of the Separate
Financial Statements for the year ended 31 December 2025.
Liabilities and equity
As at 31 December 2025, the Bank’s total liabilities stood at PLN 158,839,504 thousand, up by PLN 11,063,912 thousand
i.e. 7.5% year on year. The share of liabilities in the Bank’s total liabilities and equity was 90.1% as at 31 December 2025
(-0.5 p.p. year on year).
Table 61. Liabilities and equity
PLN’000
31.12.2025
31.12.2024
change
PLN’000
%
Amounts due to the Central Bank
-
-
-
-
Amounts due to other banks
5,923,407
5,757,872
165,535
2.9%
Derivative financial instruments
2,276,575
2,311,741
(35,166)
(1.5%)
Differences from hedge accounting
320,087
260,025
60,062
23.1%
Amounts due to Customers
141,355,067
130,830,128
10,524,939
8.0%
Liabilities under issued debt securities (including
subordinated issuances)
4,226,368
-
4,226,368
-
Subordinated liabilities
-
3,420,128
(3,420,128)
(100.0%)
Leasing liabilities
553,267
606,204
(52,937)
(8.7%)
Other liabilities
1,977,881
2,262,300
(284,419)
(12.6%)
Current tax liabilities
172,523
358,468
(185,945)
(51.9%)
Provisions
2,034,329
1,968,726
65,603
3.3%
Total liabilities
158,839,504
147,775,592
11,063,912
7.5%
Share capital
147,880
147,800
80
0.1%
Supplementary capital
9,110,976
9,110,976
0
0.0%
Other reserve capital
4,648,934
4,024,205
624,729
15.5%
AT1 Capital bonds
650,000
650,000
-
0.0%
Revaluation reserve
(184,001)
(541,084)
357,083
(66.0%)
Retained earnings
3,096,841
1,920,012
1,176,829
61.3%
- retained profit
84,646
(400,786)
485,432
(121.1%)
- net profit for the period
3,012,195
2,320,798
691,397
29.8%
Total equity
17,470,630
15,311,909
2,158,721
14.1%
Total liabilities and equity
176,310,134
163,087,501
13,222,633
8.1%
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Equity as at 31 December 2025 stood at PLN 17,470,630 thousand, up by PLN 2,158,721 thousand i.e. 14.1% year on year.
The share of equity in the Bank’s total liabilities and equity was 9.9% as at 31 December 2025 (9.4% as at 31 December
2024).
Amounts due to Customers
As at 31 December 2025, amounts due to Customers stood at PLN 141,355,067 thousand, up by PLN 10,524,939 thousand
i.e. 8.0% year on year.
Table 62. Amounts due to Customers by product
31.12.2025
31.12.2024
PLN’000
% share
PLN’000
% share
Current accounts
94,309,802
66.7%
86,336,306
66.0%
Term deposits
45,326,169
32.1%
43,070,184
32.9%
Loans and advances received
450,612
0.3%
449,955
0.3%
Other liabilities
1,268,484
0.9%
973,683
0.7%
Amounts due to Customers, including:
141,355,067
100.0%
130,830,128
100.0%
deposits
140,904,455
99.7%
130,380,173
99.7%
Equity
Equity of the Bank stood at PLN 17,470,630 thousand as at 31 December 2025, up by PLN 2,158,721 thousand i.e. 14.1%
year on year. In accordance with Resolution No. 7 of the Annual General Meeting of BNP Paribas Bank Polska S.A. dated 15
April 2025, the Bank distributed the net profit earned in 2024, amounting to PLN 2,320,798 thousand, as follows: PLN
1,162,341 thousand was paid out as a dividend, PLN 658,457 thousand was allocated to the reserve capital, and the
remaining amount remained in retained earnings.
The Bank’s equity changed also owing to earnings of the period (net profit of 2025 at PLN 3,012,195 thousand, up by PLN
691,397 thousand i.e. 29.8% year on year).
Own funds and capital ratios
The Bank’s total capital ratio as at 31 December 2025 stood at 17.00% (down by 0.58 p.p. year on year). The separate
Common Equity Tier 1 ratio (CET 1) as at 31 December 2025 was 13.06% (down by 0.32 p.p. year on year) and the separate
Tier 1 ratio of the Bank as at 31 December 2025 was 13.70% (down by 0.40 p.p. year on year).
The decrease in the capital ratios was mainly driven by CRR3 which took effect as of 1 January 2025, as well as an increase
in total credit risk weighted assets (mainly corporate exposures and mortgage-backed exposures) and total operational risk
weighted assets.
As at 31 December 2025, total own funds increased by PLN 1,490,091 thousand year on year and total risk exposure
amount was PLN 11,867,235 thousand.
Table 63. Own funds and capital ratios of the Bank
PLN’000
31.12.2025
31.12.2024
change y/y
PLN’000
%
Common Equity Tier 1 (CET 1)
- share capital
147,880
147,800
81
0.1%
- supplementary capital
7,259,316
7,259,316
-
0.0%
- reserve capital
5,823,440
5,198,711
624,729
12.0%
- general banking risk fund
627,154
627,154
-
0.0%
- intangible assets
(498,279)
(545,689)
47,410
(8.7%)
- other components of own funds, included in the
calculation of CET 1
17,681
(570,403)
588,083
(103.1%)
Total CET 1
13,377,192
12,116,889
1,260,302
10.4%
Additional Tier 1 capital
650,000
650,000
(0)
(0.0%)
Total Tier 1 capital
14,027,192
12,766,889
1,260,302
9.9%
Supplementary funds (Tier II)
- subordinated liabilities included in own funds
3,379,809
3,150,021
229,788
7.3%
Total own funds
17,407,001
15,916,910
1,490,091
9.4%
Risk exposure amount due to
- credit risk
88,771,493
78,742,649
10,028,844
12.7%
- market risks
1,202,181
1,338,766
(136,584)
(10.2%)
- operational risks
12,377,475
10,422,548
1,954,927
18.8%
- credit valuation adjustments
70,160
50,112
20,048
40.0%
Total risk exposure amount
102,421,309
90,554,074
11,867,235
13.1%
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Capital ratios of the Bank
31.12.2025
31.12.2024
change
Common Equity Tier 1 (CET 1)
13.06%
13.38%
(0.32 p.p.)
Tier 1
13.70%
14.10%
(0.40 p.p.)
Total Capital Ratio (TCR)
17.00%
17.58%
(0.58 p.p.)
The minimum levels of capital adequacy ratios on a separate basis under external regulations and administrative decisions
issued by the Polish Financial Supervision Authority are as follows:
Minimum levels of the Bank’s capital ratios
31.12.2025
31.12.2024
change
Common Equity Tier 1 (CET 1)
8.25%
7.50%
0.75 p.p.
Tier 1
9.75%
9.00%
0.75 p.p.
Total Capital Ratio (TCR)
11.75%
11.00%
0.75 p.p.
As at 31 December 2025, all capital adequacy ratios of the Bank were higher than the minimum requirements by:
• 4.81 p.p. for the Common Equity Tier 1 ratio,
• 3.95 p.p. for the Tier 1 ratio,
• 5.25 p.p. for the Total Capital Ratio.
Minimum level of own funds and eligible liabilities (MREL)
On 20 June 2023, the Bank received a letter from the BGF regarding the joint decision of the resolution authorities, i.e. the
Single Resolution Board (“SRB”) and the BGF on the minimum level of own funds and eligible liabilities (“MREL”). The joint
decision indicates that the Group’s restructuring plan envisages a Single Point of Entry (SPE) strategy for mandatory
restructuring. The Bank’s preferred tool for mandatory restructuring is the open bank bail-in tool.
The MREL requirement for the Bank was set on the separate basis at 16.11% of the total risk exposure amount (“TREA”) and
5.91% of the total exposure measure (“TEM”). This requirement was binding from 31 December 2023.
On 8 May 2025, the Bank received an updated letter from the BFG regarding the MREL requirement. The MREL requirement
for the Bank was set on the separate basis at 15.93% of the total risk exposure amount (“TREA”) and 5.91% of the total
exposure measure (“TEM”). This requirement is binding from 8 May 2025.
The entire MREL requirement should be met in the form of own funds and liabilities meeting the criteria set out in Article
98 of the BFG Act, which transposes Article 45f(2) BRRD. According to the BGF’s expectations, the part of MREL
corresponding to the recapitalisation amount (“RCA”) will be met in the form of AT1, T2 instruments and other
subordinated eligible liabilities acquired directly or indirectly by the parent company. The Bank meets the requirement.
At the same time, the BFG indicated that Common Equity Tier 1 (“CET1”) instruments held by the Bank for the purposes of
the combined buffer requirement cannot be counted towards the MREL requirement expressed as a percentage of TREA.
This rule does not apply to the MREL requirement expressed as a TEM percentage.
Changes to the funding structure
In 2025, the Bank adjusted the structure of its Tier 2 instruments by replacing partially amortised subordinated loans with
issuances of 15-year capital bonds. These transactions resulted in a slight increase in Tier 2 capital (by PLN 78,265
thousand year on year), while significantly improving the maturity structure of Tier 2 instruments.
On 18 August 2025, the Bank notified BNP Paribas S.A. (the lender) of its decision to exercise the early repayment option for
subordinated loans classified as Tier 2 capital amounting to EUR 40 million obtained under the agreement dated 10
December 2018, CHF 60 million obtained under the agreement dated 15 November 2012 (as amended on 20 November
2017), and EUR 60 million obtained under the agreement dated 15 November 2012 (as amended on 20 November 2017).
These loans were repaid in September 2025, following prior approval from the Polish Financial Supervision Authority.
On 7 November 2025 and 2 December 2025, the Bank notified BNP Paribas S.A. (the lender) of its decision to exercise the
early repayment option for subordinated loans classified as Tier 2 capital amounting to CHF 90 million obtained under the
agreement dated 12 September 2014 (as amended on 13 September 2019), and PLN 2,300 million obtained under the
agreement dated 7 December 2020. These loans were repaid in November and December 2025, respectively, following prior
approval from the Polish Financial Supervision Authority.
The above instruments were replaced by series B capital bonds issued by the Bank on 6 June 2025 with a total nominal
value of EUR 160 million and series C capital bonds issued on 10 October 2025 with a total nominal value of EUR 630
million.
On 17 December 2025, the Bank notified the European Bank for Reconstruction and Development of its decision to exercise
the early repayment option for a PLN 450 million loan obtained under the agreement dated 7 December 2021. Repayment
of the loan together with accrued interest was scheduled for 19 January 2026.
On 1 December 2025, the Bank concluded an agreement with BNP Paribas S.A. for the issuance of series D Senior
Non-Preferred capital bonds in the amount of EUR 200 million.
These instruments were recognised for the purpose of meeting the MREL requirements in relation to TREA and TEM
The Bank meets the MREL requirements as at 31 December 2025.
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MREL requirement
requirement as at
31.12.2025
requirement as at
31.12.2025
including CBR
31.12.2025
31.12.2024
TREA
15.93%
19.68%
21.73%
22.83%
TEM
5.91%
5.91%
11.34%
11.61%
Financial ratios
The Bank’s return on equity (ROE), calculated based on reported figures, stood at 18.6% as at 31 December 2025 and was
up by 1.8 p.p. year on year. Return on assets (ROA), calculated based on reported figures, was 1.8%, up 0.3 p.p. year on year.
The improvement in the return ratios was mainly due to the increase in net banking income, effective cost controlling and
reduction, lower negative impact of the legal risk of foreign currency mortgage loans, and lower credit risk cost.
The cost/income ratio, calculated based on reported figures, was 40.6% (down 2.1 p.p. year on year). This change was due
to income growing faster than costs despite higher regulatory charges (BFG).
The net interest margin calculated in relation to average assets over the year was 3.5% (down by 0.1 p.p. year on year). The
decrease in the margin was due to gradual interest rate cuts in 2025.
The low cost of credit risk, as reported and as adjusted (net of the sale of the loan portfolio), reflects the balanced
approach to risk management and a very good quality of the Bank’s loan portfolio.
The level and evolution of ratios which measure net and gross loans to deposits and sources of funding reflect the good
liquidity position observed in 2025 and 2024.
Table 64. Financial ratios
31.12.2025
31.12.2024
31.12.2023
change
2025/2024
Return on capital
(1)
18.6%
16.7%
8.2%
+1.8 p.p.
Return on assets
(2)
1.8%
1.5%
0.7%
+0.3 p.p.
Net interest margin
(3)
3.5%
3.6%
3.5%
(0.1 p.p.)
Costs/income
(4)
40.6%
42.7%
41.7%
(2.1 p.p.)
Costs/income without BFG, IPS and credit holidays
38.2%
40.5%
40.3%
(2.3 p.p.)
Credit risk costs
(5)
(0.18%)
(0.27%)
(0.03%)
+0.09 p.p.
Credit risk costs without impact of sale of
loans
(6)
(0.21%)
(0.34%)
(0.06%)
+0.13 p.p.
31.12.2025
31.12.2024
31.12.2023
change
2025/2024
Net loans/deposits
(7)
61.8%
62.6%
64.6%
(0.8 p.p.)
(1) Net profit to average equity calculated on an end-of-quarter basis.
(2) Net profit to average assets calculated on a quarter-end basis.
(3) Net interest income to average assets calculated on a quarter-end basis. Net interest income annualised taking into account the actual number of days.
(4) General administrative expenses and depreciation and amortisation to net banking income, calculated as the sum of net interest income, net fee and commission income, dividend income, net trading
income, result on investing activities, result on hedge accounting and other operating income and expenses.
(5) Result on impairment losses on financial assets and provisions for contingent liabilities to average gross loans and advances to Customers, measured at amortised cost, calculated on a quarter-end
basis. Result of impairment losses annualised taking into account the actual number of days.
(6) Calculation made net of the impact of the sale of non-performing loan portfolios (in 2024: +PLN 59,266 thousand, in 2023: +PLN 26,516 thousand, in 2022: +PLN 34,044 thousand).
(7) Loans and advances to Customers (net) to Customer deposits. Balance at the end of the period
Average interest rates used by the Bank
Table 65. Average interest rates at the Bank*
Product
PLN
EUR
2025
2024
2025
2024
Deposits (categories below)
1.91%
2.16%
Households and non-commercial institutions
1.92%
2.09%
Non-financial entities
1.90%
2.24%
Loans (categories below)
7.66%
8.00%
3.34%
4.84%
Households and non-commercial institutions
8.07%
8.24%
4.23%
5.40%
Non-financial entities
6.92%
7.52%
3.33%
4.83%
* based on the Bank’s mandatory reporting to the NBP Statistics Department
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Risks and
opportunities
115 Risk management system
118 Principal types of risk
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Risk management system
The risk management system is an integrated set of principles, mechanisms and tools (including policies and procedures)
relating to risk processes. Risk management is part of the overall Bank management system. In addition to regulatory
requirements, the Bank takes into account the specific nature, scale and complexity of its business activities and the
associated risk. The main objectives of the risk management system:
• ensuring early identification and appropriate management of all significant types of risk associated with the conducted
activity,
• supporting the implementation of the business strategy through effective risk control and maintaining risk within the
accepted risk appetite,
• reflecting the Bank’s adopted risk attitude and risk culture,
• measurement or estimation and monitoring of risk, including securing potential losses through appropriate control
mechanisms,
• limiting risk by determining a system of limits and procedures to be followed in case of their exceedance,
• defining an organisational structure adapted to the size and profile of the risk incurred.
The risk management system operating in the Bank is organized based on the three independent lines of defence, used to
define roles and scopes of responsibility for effective supervision and organisation of risk management in the Bank:
• first line of defence is made up of business units, which are responsible for managing risk in the Bank’s operational
activity, including compliance with control mechanisms,
• second line of defence is made up of designated organisational units of the Risk Area, Finance Area, Compliance
Monitoring Division, and Legal Division, which are responsible for managing individual risks, including measuring,
monitoring, controlling, and reporting risks, independently of the first line,
• third line of defence is the activity of the Internal Audit Division, which makes independent assessments of actions related
to risk management carried out by both the first and second line of defence.
The supreme role in the risk management system in the Bank is played by the Bank’s Management Board, which sets the
risk management strategy, defines risk appetite, adopts risk management policies, and sets limits for significant types of
risk and risk control procedures. The principles of risk management originate from the BNP Paribas Bank Polska S.A. Risk
Management Strategy defined by the Bank’s Management Board and approved by the Supervisory Board.
The organisation of the risk management system in the Bank primarily takes into account the role of the Supervisory Board,
the Management Board, dedicated committees (Audit Committee and Risk Committee of the Supervisory Board, Asset and
Liability Management Committee (ALCO), Risk Management Committee, Retail Banking Risk Committee, Personal Finance
Risk Committee, Credit Committee, Difficult Loans Committee, TAC/NAC Committee and Internal Control Committee), Risk
Area, Compliance Monitoring Division, and Security and Business Continuity Management Division.
Internal capital adequacy assessment
The purpose of the internal capital adequacy assessment process is to monitor and control the level of the Bank’s internal
capital. The implementation of the ICAAP process is dictated by the objective of maintaining the Bank’s stable financial
situation, guaranteeing the Bank’s operation despite incurring unexpected losses. The Bank has a duty to ensure that the
risk management process is consistent with the Bank’s risk profile and that it limits excessive risk in its operation. The
details of the process are defined in the Policy for estimating internal capital at BNP Paribas Bank Polska S.A.
The Bank has developed comprehensive principles for identifying and assessing risks in response to the requirements of the
supervisory review and evaluation process. The principles aim to identify and assess all risks to which the Bank is or may
be exposed, taking into account regulatory requirements, best practices, and the use of the Bank’s proven existing risk
management processes. The Bank takes into account the specific nature, scale, and complexity of its business activity and
the associated risk, ensuring that all significant types of risk in the Bank’s activity are measured and limited. The Bank
seeks to identify and assess threats from both the internal and external environment that could have a significant impact
on the Bank’s financial stability.
The identification of potentially material risks involves distinguishing threats and potential risks that may occur in the
future with an appropriate degree of probability.
The risk management process is aimed at:
• protecting the Bank from risk materialisation,
• ensuring an adequate assessment of capital needs necessary for identified risks.
The risk identification process is carried out annually in the Bank.
The assessment of the significance level of the risks identified in the identification process includes:
• defining the concept of risk significance,
• defining the factors determining the significance of risks,
• carrying out a risk significance assessment,
• preparing a report from the conducted assessment.
The process of assessing the significance of risks is carried out annually in the Bank.
The Bank identifies the following types of risks:
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• permanently significant - inherently linked to the profile of the activity carried out (do not require periodic significance
assessment),
• significant:
− risks for which the Bank has incurred costs related to their materialisation in the past,
− exposure to risk, severity of losses, and lack of suitable risk mitigation processes and procedures expose the Bank to
unexpected financial losses (risks for which the significance assessment is at least medium),
• insignificant – risks for which the significance assessment is low.
As a result of the risk identification process and materiality assessment conducted in 2025, the structure of identified risks
is as follows:
Internal capital reporting focuses on presenting the results of monitoring the level of internal capital and the main factors
determining its level. The Bank reports capital on a monthly basis on a separate and consolidated basis. The reports are
presented at the Risk Management Committee meeting on a monthly basis and to the Bank’s Management Board and
Supervisory Board on a quarterly basis.
A review of the capital adequacy process is conducted once a year, and the review report is submitted to the Bank’s
Management Board and Supervisory Board. In addition, internal audit regularly conducts an independent review of the
ICAAP process.
In order to measure risk, the Bank uses two approaches: quantitative and qualitative. The use of a particular approach is
related to the characteristics of the risk.
Risk measurement methods:
• quantitative methods - used when the Bank has information about the materialisation of risk and is able to measure
a quantitative feature,
• qualitative methods - used when the Bank does not have information on the historical materialisation of risk or the effect
of risk measure variability is determined by many risk factors, from which the Bank cannot distinguish the effect related
to the source of the assessed risk. The Bank considers the risk to be hard to measure and conducts an assessment using a
qualitative method, presenting qualitative characteristics of risk materialisation.
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Chart 18. Structure of internal capital in the BNP Paribas Bank Polska S.A. Group as at 31 December 2025
Risk appetite
For identified significant risks, the Bank defines risk appetite. By setting the level of risk appetite, the Bank defines its risk
profile and adopted risk posture. Risk appetite specifies the maximum level of risk that the Bank is ready to accept in
pursuing the assumptions of the business strategy and financial plan.
Risk appetite, within the boundaries set by risk tolerance, determines how the Bank uses its ability to take on risk by
specifying for each type of risk the degree of exposure that a given area can take. The Bank sets the level of risk appetite in
the form of risk measures that reflect the Bank’s current and future readiness to take on risk. All methods and procedures
are subject to periodic reviews for their adequacy and accuracy. The level of risk appetite is set by the Bank’s Management
Board, requiring approval from the Supervisory Board.
Additionally, the Bank monitors individual types of risks using a formal limit system, which is set in such a way as to:
• ensure that the Bank complies with supervisory standards,
• maintain the desired risk profile defined in the business strategy and risk management strategy of the Bank,
• the limits do not exceed the level of risk acceptable by BNP Paribas Group.
In case of limit exceedances, corrective actions are taken to reduce the value of a given risk in line with existing procedures
in the Bank. The information system used in risk management ensures the collection of data on operations and
transactions and their impact on the Bank’s risk profile. The Bank has rules for risk control and risk management that
include procedures for dealing with crisis events.
Stress tests
In accordance with the Methodology of the Stress Test Programme in BNP Paribas Bank Polska S.A., the Bank performs,
among others, the following types of bottom-up tests:
• stress tests based on the recommendations of the Polish Financial Supervision Authority,
• business model stress tests,
• internal capital stress tests,
• reverse stress tests,
• climate stress tests,
• recovery plan stress tests.
Stress tests are an important tool in the risk management process. They allow extending risk measurement to sensitivity to
non-standard changes in market parameters, significantly deviating from changes observed during normal functioning of
financial markets. The aim of the stress test programme is to estimate potential risks to which the Bank is exposed under
hypothetical market conditions. Macroeconomic assumptions are developed by the Bank’s Chief Economist. The stress test
programme fulfils the requirements of EBA/GL/2018/04 Guidelines of 19 July 2018 on stress testing.
The stress tests program covers:
• sensitivity analysis,
• scenario analysis,
• reverse stress testing.
The Bank conducts tests referring to the level of risk appetite expressed in the form of risk appetite measures and capital
targets set out in the Capital Management Policy in BNP Paribas Bank Polska S.A. Through stress tests, the Bank assesses
the credibility of its financial plan and capital plan under extreme conditions, to ensure that the Bank meets the capital
requirements that apply to it. The Bank’s Management Board approves the stress test program and supervises its
implementation and results.
credit risk ; 56.20%
operational risk;
13.96%
credit spread risk in the banking
book; 13.98%
interest rate risk in the
banking book; 6.95%
business risk; 5.59%
ESG risk; 0.98%
counterparty risk; 0.56%
capital risk; 0.45%
model risk; 0.90%
market risk; 0.41%
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Principal types of risk
Credit risk
Credit risk is the risk of the Bank incurring a loss due to a failure to fulfil obligations within the time specified in the
agreement as a result of a deterioration or loss of creditworthiness by the Customer.
The Bank’s credit risk management system is defined in the Credit Policy of BNP Paribas Bank Polska S.A. adopted by the
Management Board. Detailed rules and criteria for financing within the product offer of a given business line, types of
available loans, financing objectives, conditions and limits are set out in the credit policies for individual business lines. The
Bank’s intention, in accordance with the criteria of the credit policy, is to cooperate with Customers characterized by a good
reputation and a good economic and financial situation.
Credit policies also establish detailed rules for identifying, measuring, and accepting risk, securing the repayment of the
loan, and monitoring Customers during the term of the loan agreement.
The credit risk management process is organisationally adapted to the business line structure adopted in the Bank. A key
role in the credit risk management system is played by the organisationally distinct Risk Area, which is headed by a
member of the Management Board (Chief Risk Officer). Activities in the area of credit risk management are supported by the
Risk Management Committee and the Retail Banking & Personal Finance Risk Committee.
The Bank assesses the risk of borrowers using rating and scoring classification systems and risk classification according to
IFRS standards.
Credit decisions are made in accordance with the decision-making model approved by the Bank’s Management Board and
adapted to the standards applicable in the BNP Paribas group. The decision-making model takes into account the structure
of business lines, establishes the number of decision-making levels, the scope of their competences, and the rules, criteria,
and conditions for making credit decisions. The thresholds for decision-making powers depend on criteria such as the
Customer segment, Customer risk profile, and lending term. At all competence levels, credit decisions are made by two
persons (the "four eyes" principle) by a representative of the business line and a representative of the organisational unit
responsible for an independent assessment of the Customer’s risk and transaction. For Customers whose credit risk
assessment is made using simplified risk assessment rules or risk assessment models, including scoring models approved
by the Risk Management Committee or the Retail Banking & Personal Finance Risk Committee, credit decisions can be made
unilaterally by representatives of business lines.
In credit risk management, the Bank is guided by the following principles:
• each credit transaction requires a comprehensive assessment of credit risk, the result of which is an internal rating or
scoring,
• a thorough and careful financial analysis forms the basis for recognizing the credibility of the Customer’s financial data
and information about the value of collateral; the Bank’s prudent analyses always take into account the necessary safety
margin,
• as a general rule, the basis for financing a Customer is their ability to generate cash flows that ensure repayment of
obligations to the Bank,
• the prepared credit risk assessment is subject to additional verification by credit risk assessment services independent of
business services,
• the pricing conditions of the credit transaction must cover the risk of this transaction,
• credit risk is diversified in terms of geographical areas, economic sectors, products, and Customers,
• only authorized persons can make credit decisions,
• the Customer and the transactions concluded with the Customer are monitored in a manner transparent to the Customer
and strengthening relations with the Customer.
Credit risk management in the Bank’s subsidiaries
The principles of the Bank’s oversight of credit risk generated by the subsidiaries are defined in the Credit Policy of BNP
Paribas Bank Polska S.A.
The Bank recommends, reviews, and accepts the policies, principles, and methodologies used by the subsidiaries in
managing credit risk.
In the Bank and its subsidiaries, methods of credit risk management are used in parallel, including:
• a rating system for Corporate Banking and SME Banking Customers,
• risk classification system according to the IFRS standards,
• assessment of the creditworthiness of the Bank’s and subsidiaries’ shared Customers,
• credit decision-making model,
• the Bank’s internal limit system for concentration risk, including limits on receivables portfolios of subsidiaries.
Measurement of impairment of financial assets
The principles used by the Group in measuring impairment are described in Note 3a. Impairment of financial assets of the
Consolidated Annual Report for the 12-month period ended 31 December 2025.
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In 2025, as part of adjusting the level of provisions to expectations regarding the future macroeconomic situation, the level
of provisions increased by PLN 5,679 thousand due to updating the forecasts of macroeconomic variables included in the
IFRS 9 model used. In Q2 2025, due to significant market uncertainty, the Group decided not to include the impact of
changes to macroeconomic factor projections in the Bank’s profit, thus maintaining a more conservative approach to
provision estimations.
In 2025, the Group made the following significant changes to the IFRS 9 model:
• change in EAD amortisation granularity in the ECL calculation formula. Following the modification, ECL for Stage 1 and
Stage 2 portfolios is calculated on a quarterly rather than annual basis and then aggregated to the appropriate horizon,
taking into account the discounting effect. The change resulted in a reduction of impairment charges by PLN 46,226
thousand,
• update of the PD model for a portfolio of businesses carrying full books of account, resulting in release of PLN 18,889
thousand provisions. The change calibrated the model estimating the impact of macroeconomic factors on credit loss by
incorporating observations from June 2023 to June 2024. The adjustment ensured a better modelling of dependence and
eliminated the unrealised conservatism of previous projections.
In 2025, the Group verified its Post Model Adjustments (PMA) in 2025. As a result of the review, additional allowances for
sensitive customers using credit holidays were released. In particular, this was due to the stable quality of the portfolio
after the credit holiday scheme was terminated. The adjustment on estimated and planned changes to the LGD model was
reversed as the changes were reflected directly in the LGD model.
As a result of an analysis of the corporate loan portfolio, allowances for specific risks of selected sectors were reviewed.
Following these measures, PMA went down by PLN 88,679 thousand in 2025 and reached PLN 143,352 thousand as at 31
December 2025. Detailed information on the PMA (Post Model Adjustment) verification carried out in 2025 is presented in
Note 3a Impairment of financial assets of the Consolidated Annual Report for the 12-month period ended 31 December
2025 (in the section “Description of methods used for determining expected credit loss allowances”).
In 2025, as part of adjusting the level of impairment allowances to expectations regarding the future macroeconomic
situation, the level of allowances increased by PLN 5,679 thousand. This resulted from the update of macroeconomic factor
forecasts incorporated into the IFRS 9 model, performed in the first quarter of 2025. In the following quarters, due to high
market uncertainty, the Group decided not to reflect the impact of changes in macroeconomic projections in the Group’s
results, thereby maintaining more conservative assumptions for estimating allowances. It should also be noted that the
Group is working on changes to the model for incorporating macroeconomic forecasts into the ECL scenario weights, which
– according to the Group’s expectations – should partially neutralise the unrecognised reversals resulting from changes in
macroeconomic forecasts.
Debt restructuring and debt enforcement
In 2025, a total of PLN 1,690.8 million in receivables were collected, of which:
• PLN 527.0 million - as a result of portfolio restructuring (corporate Customers PLN 377.0 million, SMEs PLN 134.5 million,
retail Customers PLN 4.7 million, micro-enterprises PLN 8.9 million, mortgages PLN 2.0 million),
• PLN 1,083.4 million - as a result of debt enforcement (retail Customers PLN 539.7 million, micro-enterprises PLN 293.9
million, corporate Customers PLN 58.3 million, SMEs PLN 43.8 million, Personal Finance PLN 2.5 million),
• PLN 80.4 million - as a result of the sale of a portfolio with impairment.
Loan portfolio quality
The share of NPLs in the portfolio measured at amortised cost (NPL - defined as Stage 3 and POCI non-performing loans as
presented in the note to the Consolidated Financial Statements at 31 December 2025) stood at 2.8%. Maintaining the ratio
at a low level was possible thanks to the high efficiency of actions at the various stages of processing non-performing loans
in the process of proactive NPL portfolio management and, in particular, to the effective monitoring of Customers
potentially at risk of entering Stage 3 and the high efficiency of debt enforcement.
Chart 19. NPL ratio
As at 31 December 2025, the coverage rate for Stage 3 and POCI non-performing loans and advances was 54.1%, a slight
increase of 0.1 p.p. compared to the coverage level observed at the end of 2024.
2.8%
3.0%
3.2%
3.2%
3.2%
4Q 253Q 252Q 251Q 254Q 24
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Chart 20. NPL provision coverage
Detailed information on the quality of the portfolio is presented in the financial performance section, loan portfolio.
The Group actively monitors the structure of the loan portfolio, including in particular the industry structure. Details are
described under Concentration risk.
Concentration risk
Concentration risk is an inherent risk that the Bank takes as part of its statutory activities and is subject to a specific
process and management rules.
The Management Board assesses the adopted concentration risk management policy in terms of how it is applied,
particularly in terms of checking its effectiveness and adequacy of the implementation of principles in the context of
current and planned activities and taking into account the risk management strategy. In the event of significant changes in
the Bank’s environment or risk management strategy, the adequacy of the concentration risk management process is
reviewed immediately after this event occurs.
To limit concentration risk, mechanisms for identifying and measuring concentration risk and concentration limits,
including large exposure limits, are used. They allow for monitoring and maintaining diversification of the credit portfolio at
levels consistent with the Bank’s strategy and risk appetite. The Bank’s limit system also takes into account external
conditions and macroeconomic and sector perspectives.
As of the end of December 2025, the limits on a consolidated and separate basis as defined in Article 395 of Regulation EU
No. 575/2013 were not exceeded in relation to entities of the BNP Paribas S.A. Group and amounted to 11.20% of Tier 1
capital on a consolidated basis.
In the case of the exposure limit to entities outside the BNP Paribas S.A. Group, the limits were also not exceeded, the
largest exposure constituted 19.88% of Tier 1 capital on a consolidated basis.
Internal limits for credit concentration risk are set, among others, for:
• selected economic sectors/industries,
• exposures denominated in foreign currency,
• Customer segment (internal Customer segmentation),
• loans secured by a particular type of collateral,
• geographic regions,
• average probability of default (PD),
• exposures with a specific rating (the Bank’s internal rating scale),
• exposures with a specific debt-to-income ratio,
• exposures with a specific loan-to-value ratio.
Actions limiting the Bank’s exposure to concentration risk can include system-wide actions as well as actions related to
individual/specific decisions and transactions. The Bank includes the following in system-wide actions:
• limiting the scope of lending to a particular type of Customer, by modifying the conducted credit policy,
• reducing limits on concentration risk,
• diversification of asset types at the level of the Bank’s financial statements,
• changing the business strategy in such a way as to counteract excessive concentration,
• diversification in terms of the types of accepted collateral.
The Bank defines actions limiting single / specific decisions and transactions as follows:
• limiting further transactions with a given Customer or group of related Customers,
• sale of selected assets / credit portfolios,
• securitisation of assets,
• establishing new security for existing or new credit exposures.
68.5%
67.8%
67.5%
67.2%
67.0%
54.1%
54.6%
52.0%
51.5%
54.0%
49.2%
49.9%
46.9%
46.1%
49.6%
4Q 253Q 252Q 251Q 254Q 24
Individual Customer loans Gross Customer loans Institutional Customer loans
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The industry concentration analysis conducted by the Bank covers all of the Bank’s credit exposures to institutional
Customers.
Chart 21. Industry participation in the portfolio of institutional Customers’ loans (industries above 5%)
Chart 22. Share of loans with recognized impairment (over 5%) in the portfolio of a given industry
"Industrial Processing" has the highest share, where the share of risk loans is 6%. The industry with the highest share of
risk loans is "Accommodation and catering services", which constitutes only 1% of the balance sheet exposure to
institutional Customers.
More detailed information about the industry exposures can be found in note 54 of the Consolidated Annual Report for the
12-month period ended 31 December 2025.
In connection with the ongoing war in Ukraine and economic sanctions imposed on Russia and Belarus, the Bank has
analysed credit exposures directly related to these countries and on this basis has not identified significant exposures in
the institutional Customers and retail Customers portfolios.
14%
9%
9%
7%
14%
11%
9%
7%
0% 2% 4% 6% 8% 10% 12% 14% 16%
Manufacturing
Agriculture, forestry and fishing
Wholesale and retail trade; repair of motor vehicles
and motorcycles
Real estate activities
31.12.2025 31.12.2024
11%
7%
6%
2%
12%
6%
0% 2% 4% 6% 8% 10% 12% 14%
Water supply; sewerage, waste management and
remediation activities
Accomodation and food service activities
Manufacturing
31.12.2025 31.12.2024
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Counterparty risk
Counterparty risk is the credit risk of a counterparty to financial market transactions, where the amount of the obligation
can assume different values over time, depending on market parameters. Therefore, counterparty risk is associated with
transactions whose value can change over time depending on factors such as interest rates or exchange rates. A different
exposure value can affect the Customer’s solvency and is crucial for the Customer’s ability to fulfil its obligations at the
time of transaction settlement. The Bank determines the level of exposure based on the current valuation of contracts and
the potential future change in exposure value, which depends on the type of transaction, the type of Customer, and
settlement dates.
As at 31 December 2025, the counterparty risk calculation included the following types of transactions: foreign exchange
transactions, interest rate swaps, currency options, interest rate options, and commodity derivatives.
The assessment of counterparty credit risk for transactions generating counterparty risk is the same as in granting credit
products. This means that these transactions are covered in the credit process by limits whose value directly results from
the assessment of Customers’ creditworthiness, carried out similarly to the needs of offering credit products. The
assessment also takes into account the specific nature of the transactions, especially their variable value over time, or
their direct dependence on market parameters.
The rules for concluding foreign exchange transactions, derivative transactions, and granting, utilizing, and monitoring
credit limits for transactions covered by counterparty risk limits are governed by dedicated procedures. According to the
adopted policy, the Bank concludes all transactions based on individually granted limits and takes into account its
knowledge of the Customer. The Bank has defined product groups which are offered to Customers depending on their
knowledge, experience, and risk tolerance. The Bank has transparent rules for securing counterparty risk exposure.
ESG risk
ESG risk management
The risk identification and assessment principles developed by the Bank in 2021 defined a separate group of risk factors
related to environmental, social and governance factors. Since then, the Bank has been continuously improving the
process of identifying and managing ESG risk. In 2025, the risk identification process confirmed the material impact of ESG
factors on credit, business, operational and liquidity risk. Because ESG factors are not yet comprehensively incorporated
into the quantitative measurement of credit risk, a decision was made to classify ESG risk as a hard-to-measure risk
category until ESG factors are fully reflected in credit parameters. As a result, in 2021 the Bank integrated ESG risk into its
internal risk management framework by including ESG risk as a subtype of credit risk in the Risk Management Strategy
and the Risk Appetite. To support the mitigation and control of this risk, the Bank developed principles for measuring ESG
risk within the Internal Capital Adequacy Assessment Process (ICAAP). The capital plan was supplemented with limits for
ESG risk, determined on the basis of the completed risk assessment. In 2021, the Bank developed the ESG Risk
Management Principles, which include provisions on risk monitoring, reporting and stress testing. These principles are
subject to at least annual updates.
Factors considered in ESG risk analysis
Environment:
• greenhouse gas emissions,
• energy consumption and efficiency,
• water, air and soil pollution,
• effective water-use management (risk of freshwater scarcity),
• soil degradation,
• deforestation,
• consumption of natural resources,
• waste management,
• biodiversity and ecosystem protection,
• risk of insufficient energy transition,
• development of low-emission and other environmental technologies (transition risk),
• regulatory constraints, including additional taxes and fees, e.g. carbon tax (transition risk),
• physical risks related to climate change (extreme weather events and gradually deteriorating climatic conditions),
including the effects of natural disasters that may, among other impacts, reduce asset values,
• changes in consumer sentiment and preferences driven by increasing awareness of environmental risks,
• risk of financial liability for negative impacts of business activities (compensation, penalties).
Social:
• integration of different social groups,
• supporting social cohesion,
• respect for diversity,
• whistleblower protection,
• investment in human capital and communities,
• preventing discrimination of any kind,
• combating inequalities and promoting equal opportunities,
• a safe and healthy working environment,
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• health and safety of Customers, local communities and the broader environment,
• protection of Customer privacy,
• training and development,
• violations of human rights (forced labour, child labour, modern slavery),
• violations of labour rights: freedom of association, right to strike, collective bargaining rights, ethical employment
standards,
• risk of insufficient prevention of terrorism and cybercrime threats,
• infectious diseases (affecting humans or animals),
• risk of financial liability for negative impacts of business activities (compensation, penalties).
Governance:
• unethical and unfair business practices,
• non-compliance with corporate governance standards (code of ethics, complaint and whistleblowing mechanisms,
information transparency),
• gender diversity in corporate bodies,
• internal audit,
• board independence,
• executive remuneration,
• fraud and corrupt practices,
• shareholder rights,
• stakeholder engagement,
• defective ESG risk control systems,
• supply chain requirements,
• compliance with non-financial sector regulations,
• risk of financial liability for negative impacts of business activities (compensation, penalties).
The Bank recognises that risks related to environmental protection, social policy and corporate governance may constitute
material risks for enterprises and systemic risks for the economy. To manage these risks, the Bank monitors the work of
supervisory authorities as well as legislative proposals concerning the financial sector.
ESG analysis in the credit process
In 2021, in response to the requirements of the EBA Guidelines EBA/GL/2020/06 of 29 May 2020 on loan origination
and monitoring, the Bank developed ESG assessment questionnaires, which were implemented in the credit process for
corporate, SME and micro-enterprise Customers. The purpose of the assessment is to identify any risks related to ESG
factors that may affect the financial situation of Customers, as well as the impact of Customers’ business activities on ESG
factors. The Bank continuously undertakes actions to improve its approach to assessing and managing ESG risk, in line
with regulatory, scientific and methodological developments and with the increasing availability of reliable data. In 2025,
in the micro-enterprise segment, the Bank replaced the questionnaire with an internal ESG risk measurement model.
The Bank also applies a comprehensive assessment of the level of advancement of sustainability practices among its
Customers (ESG Assessment). The analysis is based on questionnaires aligned with EU sustainability regulations and
focused on ESG factors material to each industry. Owing to the breadth of the topics analysed, the Bank:
• assesses the scale of Customers’ engagement in key areas of their social and environmental impact,
• determines whether Customers are aware of sustainability challenges and what commitments and actions they
undertake,
• monitors progress in implementing ESG practices.
Until recently, the ESG Assessment process covered only Strategic Customers. Since 2024, the Bank has extended the
analysis to lower segments of Corporate Customers.
The Bank also applies the Equator Principles (EP), which serve to identify, assess and manage risks associated with the
financing of specific projects and their impact on the natural environment and society. The principles ensure minimum
standards for project due diligence processes.
The Bank also adheres to:
• the Ocean Protection Policy, which sets financing criteria for activities considered environmentally risky and harmful to
ocean biodiversity,
• the Human Rights Policy, which establishes ethical standards and ensures respect for human rights in all actions
undertaken by the Bank.
Sectoral policies
The sectoral policies applied by the Bank identify nine sectors considered particularly sensitive due to ESG risk. These
sectors include: coal-based energy, mining, oil and gas, nuclear, forestry – wood pulp, forestry – palm oil, tobacco,
agro-food, and defence and security.
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All entities operating in these sectors that wish to become Customers of the Bank or obtain financing are required to meet
the criteria set out in the Bank’s sectoral policies. At the same time, the Bank has made a strategic decision to discontinue
servicing the sectors most harmful from a sustainability perspective.
More information on the Sectoral Policies can be found in the section Actions and resources in relation to climate change
policies (E1-3) in the Sustainability Statement.
Table 66. Sectors covered by the Bank’s Sectoral Policies
Sector
Bank’s commitments
Coal-based energy
• The Bank will not enter into cooperation with any new Customer that derives more
than 25% of its revenue from coal-based energy or coal-related activities.
• The Bank will cooperate only with those coal-energy enterprises that have a strategy
to exit coal by 2030, covering both the coal-fired power plants they own and those
they operate.
• The Bank will not provide financial products or services for new coal-energy projects,
regardless of their location, nor for the modernisation of existing coal-fired power
plants or combined heat-and-power plants where the purpose is to extend their
operational life or increase production capacity.
Mining
• The Bank will not provide any financial products or services to infrastructure
companies that are significantly involved in the thermal-coal industry.
• The Bank will not provide any financial products or services to entities belonging to
mining groups that produce more than 10 million tonnes of thermal coal per year or
derive more than 20% of their revenue from thermal coal.
• The Bank will not provide any financial products or services for mining projects related
to the extraction of thermal coal or metallurgical coal.
Oil and gas
• The Bank will not finance the development of new oil and natural-gas fields.
• The Bank does not provide financing for investments related to the exploration and
extraction of oil and gas from unconventional deposits, nor for pipelines and export
terminals primarily supplied with unconventional LNG.
• The Bank does not finance any oil-and-gas projects or infrastructure related to such
projects in the Arctic and Amazon regions, or in the Esmeraldas province in Ecuador.
Nuclear
• As a financial institution, the Bank may offer its products and financial services to
government entities that support enterprises developing non-military nuclear energy.
The Bank believes that for countries planning to develop nuclear power or build new
nuclear plants, as well as for the international community, it is essential not only to
comply with safety and population protection requirements, but also to act with future
generations and environmental protection in mind.
• Through the application of its Sectoral Policy, the Bank aims to ensure that any
projects it might finance are aligned with the principles of monitoring and mitigating
the social and environmental impacts of the nuclear energy sector.
Forestry – wood pulp
• The Bank has observed that, due to the pulp production process, the activities of the
heavy industry sector have a significant impact on the environment, including water,
soil and air pollution, as well as on the health and safety of pulp-mill workers and
surrounding communities.
• The Bank aims to support responsible producers that apply sustainable development
practices in the wood pulp sector.
Forestry – palm oil
• The Bank refrains from financing or investing in companies whose activities actively
contribute to deforestation or that violate the rights of local communities.
• The Bank aims to support responsible producers that apply sustainable development
practices in the palm oil sector.
232
Customers in sensitive sectors covered by
assessment under Sectoral Policies
539
ESG assessments
131
Customers covered by ESG
Assessment
3
lines of defence underlying integrated
ESG data management in the Bank’s
overall corporate governance
framework
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Tobacco
• The Bank is phasing out the financing of tobacco product manufacturers as well as
growers and wholesalers whose core business is related to tobacco.
Agro-food sector
• The Bank provides a wide range of financial products and services for the agro-food
sector across the entire value chain. The Bank’s partners are distinguished by a high
level of responsibility, reflected in their commitment to providing people with healthy
and safe products in a way that does not jeopardise food supplies for future
generations.
• Since 2021, the Bank has applied new criteria for companies involved in activities
related to soy and beef in the Brazilian Amazon and Cerrado regions. The Bank will
offer financial products or services only to companies that have adopted a
zero-deforestation strategy in their production and supply chains no later than 2025.
• In the case of the Amazon, the Bank will not finance Customers producing or
purchasing beef or soy from areas deforested or converted after 2008; in the case of
the Cerrado, from areas cleared or converted after 1 January 2020, in line with global
standards.
• For all Customers, the Bank will require full traceability of beef and soy supply chains
(both direct and indirect) by 2025.
• The Bank encourages Customers to transition to cage-free infrastructure systems for
broilers and laying hens by 2025 and to implement the Responsible Minimum
Standards of the FARMS Initiative, encouraging all poultry-farming companies (broilers
and laying hens) to comply with a maximum stocking density of 30 kg/m².
Market risk (including interest rate risk in the trading book and currency risk)
The process of managing market risk in the Bank is divided into managing interest rate risk in the trading book and
currency risk. The process is centralized, which means that all transactions exposing the Bank to the above-mentioned
risks are transferred to the Financial Markets Division, which is the unit responsible for operational risk management
within the granted limits. The unit responsible for measuring and monitoring the level of market risk is the Market and
Counterparty Risk Department, organisationally separate up to the level of the Bank’s Management Board from the units
conducting activities exposing the Bank to risk. The key participants in the market risk management process are the Risk
Management Committee, the Management Board and the Supervisory Board, which, within the competences and
responsibilities set out in written regulations, grant and allocate amounts of market risk limits, the level of risk appetite,
and monitor their use and the compliance of the conducted activities with the adopted strategy.
In measuring market risk, the Bank uses, among other methods, the Value at Risk (VaR) method. This is the change in the
market value of an asset component or asset portfolio under specific assumptions regarding market parameters, in a
specified time period and with a given probability. It is assumed that VaR for currency risk monitoring purposes is
determined with a 99% confidence level in a one-day time horizon. The VaR methodology is subject to at least an annual
process of evaluating the quality of the implemented models, including by performing a test that involves comparing
forecast values and values determined based on actual changes in risk factors, assuming a constant open position (back
testing).
In addition to VaR, in the process of managing market risk, the Bank used a number of other measures, such as open
position limits for a given risk factor, loss limits, the analysis of the results of stress tests, as well as gamma and vega
limits for option instruments.
Interest rate risk in the trading book is the risk of adverse changes in the Bank’s financial result or the value of the Bank’s
capital, due to one of the following reasons:
• differences in the timing of interest rate changes on the Bank’s assets and the liabilities financing them (gap risk),
• differences in the base rates that form the basis for determining the interest rate on positions with the same revaluation
term (base risk),
• changes in market interest rates, which affect the fair value of the Bank’s open positions (interest rate variation risk).
Interest rate risk in the trading book has been classified as significant, and the economic capital allocated to this type of
risk constitutes less than 1% of the Bank’s total economic capital.
Exposures to interest rate risk were the main source of risk in the trading book. The Bank assesses this risk level as
moderate. In addition to linear risk instruments, the Bank maintained a small open position in interest rate options to
ensure the possibility of servicing Customer transactions at more favourable pricing conditions.
The following table shows the level of interest rate risk in the trading book in terms of Value at Risk with a 99% confidence
level in a one-day time horizon, allowing to estimate the sensitivity of the Bank’s result to changes in market interest
rates, including in particular potential losses.
Table 67. Interest rate risk in the trading book: Value at Risk with a 99% confidence level in a one-day time horizon
IR VaR (PLN’000)
2025
2024
Average
2,210
2,672
Maximum
3,679
4,266
Minimum
1,553
1,655
Foreign exchange risk is the risk of adverse changes to the Bank’s financial result due to changes in market exchange
rates.
The Bank conducts activities resulting in currency positions sensitive to changes in exchange rates. At the same time, it
strives to limit exposure to foreign exchange risk arising from offering Customers products in foreign currencies. The Bank
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conducts limited activity on the foreign exchange market aimed at realizing gains on short-term arbitration positions. In
addition to instruments with linear risk characteristics, the Bank maintained a small open position in currency options to
ensure the possibility of servicing Customer transactions at more favourable pricing conditions.
Foreign exchange risk has been classified as significant, and the economic capital allocated to this type of risk constitutes
less than 1% of the Bank’s total economic capital.
The following table presents the level of currency risk in terms of Value at Risk with a 99% confidence level in a one-day
time horizon, allowing to estimate the sensitivity of the Bank’s result to changes in market currency rates, including in
particular potential losses.
Table 68. Foreign exchange risk: Value at Risk with a 99% confidence level in a one-day time horizon
FX VaR (PLN’000)
2025
2024
Average
273
315
Maximum
1,693
1,600
Minimum
25
21
Interest rate risk in the banking book
The Group’s core business activity - granting loans and accepting deposits from Customers - results in the creation of
open interest rate risk positions, which are transferred from business lines to portfolios managed by the Asset and Liability
Management Division through a transfer pricing system.
Structural elements (a stable part of current accounts insensitive to interest rate changes and capital) are hedged with
transactions with longer maturities. The Group’s intention for the remaining portfolio is to close the interest rate risk.
When defining the interest rate risk profile, the Group takes into account not only contractual parameters, but also the
actual characteristics of products resulting from Customer behavioural behaviours and embedded options using models
e.g., for current accounts, savings accounts, fixed-rate loans, credit cards.
Modelling product behaviour divided into business lines allows for the separation of stable and unstable parts, responding
in different ways to interest rate changes.
The Group’s policy on interest rate risk defines the following basic types of interest rate risk analysis (combined and
broken down into major currencies):
• maturity gap in assets and liabilities ("gapping") for the banking book,
• outlier test of net interest income sensitivity (SOT NII) in accordance with regulatory guidelines,
• outlier test of the economic value of capital (SOT EVE) in accordance with regulatory guidelines,
• sensitivity of interest income to defined - expected and crisis - scenarios of shifts in interest rate curves, assuming
different scenarios of interest rate curves (EaR),
• the amount of interest income under defined scenarios of changing interest rate curves for the position effectively
managed by the Asset and Liability Management Division (NII),
• sensitivity due to different reference rates (base risk),
• average duration of capital investments and non-interest bearing current accounts (structural elements),
• sensitivity of fair value to parallel shift in interest rate curves by 1 basis point and to shift in interest rate curves by 1
basis point at a selected curve node,
• sensitivity of fair value, expressed as notional amount of an annual transaction (position) with the same sensitivity
(OYE).
The above analyses are a fundamental part of the system for limiting interest rate risk in the banking book. Individual
analyses are carried out on a daily, monthly or quarterly basis. In addition, the Group conducts sensitivity analyses for
extreme conditions for the banking book, using significantly larger changes in interest rates than those usually observed
(stress tests).
The table below presents the interest rate gap for the banking book as at 31 December 2025. The gap shows net
revaluation amounts in individual time intervals for positions, broken down by product. The use of established limits is
below the maximum values.
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Table 69. Interest rate gap
PLN’000
up to 1 month
1-3 months
3-12 months
1-5 years
over 5 years
total
Cash and balances at Central Bank
10,224,866
-
-
-
-
10,224,866
Amounts due from banks
11,503,131
-
21,000
-
-
11,524,131
Loans granted to Customers
29,866,518
30,610,710
13,604,923
14,184,347
1,697,123
89,963,621
Investment securities
2,295,000
2,758,540
4,022,134
30,890,999
20,795,741
60,762,414
Other assets
1,375,821
115,977
300,227
1,609,139
750,435
4,151,599
Total assets
55,265,336
33,485,227
17,948,284
46,684,485
23,243,299
176,626,631
Amounts due to banks
(5,776,742)
(3,936,995)
(126,653)
(291,822)
(500)
(10,132,712)
Amounts due to Customers
(50,929,637)
(24,027,571)
(24,726,078)
(27,216,481)
(14,019,654)
(140,919,421)
Other borrowings
(4,184,433)
(650,000)
-
-
-
(4,834,433)
Capital
92,057
(357,526)
(4,334,217)
(8,580,629)
(4,290,314)
(17,470,629)
Other liabilities
(4,896,603)
(4,667)
(12,964)
(21,968)
(782)
(4,936,984)
Total liabilities
(65,695,358)
(28,976,759)
(29,199,912)
(36,110,900)
(18,311,250)
(178,294,179)
Net off-balance-sheet liabilities
1,821,830
(3,149,021)
3,649,356
-1,758,185
(363,380)
200,600
Interest rate gap
(8,608,192)
1,359,447
(7,602,272)
8,815,400
4,568,669
(1,466,948)
The average period of capital investments and non-interest-bearing current accounts as at 31 December 2025 was 4.7
years.
The sensitivity of net interest income to shifts in interest rate curves largely depends on the share of non-interest-bearing
and low-interest-bearing deposits in the total deposit base, assumptions about the behaviour of the non-stable part of the
deposit base and assumptions made about changes in the balance sheet structure.
Table 70 shows the sensitivity of net interest income as at 31 December 2025 to an immediate 100 bps change in interest
rates in all currencies over a 12-month horizon. The most likely assumption was made that there would be no shifts
between non-interest-bearing current accounts and interest-bearing deposits resulting from high levels of interest rates in
PLN. In the sensitivity analysis of net interest income, an assumption was made about an increase/decrease in the business
margin in the event of an increase/decrease in interest rates. A factor that has a significant impact on the sensitivity of net
interest income is the large proportion of non-interest-bearing current accounts, some of which, for prudential reasons, are
hedged (from the point of view of interest rate risk) with short-term (O/N/1M) financial transactions. The impact of
maturity gaps between assets and liabilities on the sensitivity of net interest income is low.
The increase in the sensitivity of net interest income at the end of 2025 is mainly due to an increase in non-interest-
bearing account balances.
Table 70. Net interest income sensitivity as at 31 December 2025.
Change in interest rates (PLN million)
+100 bps
-100 bps
For PLN
236
(243)
For all currencies combined
349
(356)
The Bank performs the supervisory outlier test of net interest income in the banking book (SOT NII) in full compliance with
the guidelines of the Commission Delegated Regulation EU 2024/856 (the non-stable part of deposits negatively affects the
measure). The value of the measure as at 31 December 2025 was 4.68% of Tier 1 capital which is below the applicable
regulatory limit of 5% of Tier 1 capital.
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The supervisory outlier test for the Group’s economic value of capital (SOT EVE) (the change in fair value of the Group’s
assets and liabilities excluding own funds, at internal prices, with assumed changes in interest rate curves) remains
materially below the regulatory limit of 15% of Tier 1 capital. As at 31 December 2025, the maximum SOT EVE was -6.35%.
As at 31 December 2025, the Group applies hedge accounting:
• macro fair value hedge - the hedged risk is interest rate risk, in particular changes in the fair value of fixed-rate assets
and liabilities, due to changes in certain reference rates. The hedged items are current accounts with a fixed interest rate
in PLN, EUR and USD. The hedging instruments are standard interest rate swaps (IRS): plain vanilla IRS in PLN, EUR and
USD, under which the Bank receives a fixed interest rate and pays a variable rate based on WIBOR 6M, WIBOR 3M,
EURIBOR 6M, EURIBOR 3M, EUR ESTR, USD SOFR.
• micro fair value hedge - the hedged risk is interest rate risk, in particular changes in the fair value of fixed-rate assets
and liabilities, due to changes in a certain reference rate. The hedged items are fixed-coupon bonds in EUR and USD. The
hedging instruments are standard interest rate swaps (IRS): plain vanilla IRS in EUR and USD, under which the Bank pays
a fixed interest rate and receives a variable rate based on EURIBOR 3M, EUR ESTR and USD SOFR.
• cash-flow hedge - the hedged risk is interest rate risk, in particular the lack of variability of interest flows on the hedged
security, caused by changes in a certain reference rate. The hedged items are variable-coupon bonds WZ1131 and
WZ0330. The hedging instruments are standard interest rate swaps (IRS): plain vanilla IRS in PLN, under which the Bank
receives a fixed interest rate and pays a variable rate based on WIBOR 6M.
The war in Ukraine has essentially not affected the way interest rate risk is managed in the banking book.
Liquidity risk
Liquidity risk is defined as the risk of the Bank losing the ability to meet its financial obligations, where liquidity is defined
as the ability to:
• finance assets and meet obligations on time in the course of the Bank’s normal operations or under other conditions,
without incurring a loss, where - given that maintaining liquidity is a priority for the Bank - optimizing liquidity costs is a
factor considered last,
• obtain alternative and supplementary funds to those currently held, in case of their non-renewal and/or early
withdrawal, to meet the current or potential demand for funds from current depositors, to cover lending and other
potential liabilities associated with, among others, settlement of derivative transactions or collateral established by the
Bank,
• generate positive net cash flows by the Bank over a certain time horizon, regardless of macroeconomic developments, the
implementation of business plans, and changes in the regulatory environment.
The Bank operates in an environment based on free market rules as a participant in the financial market, in particular the
retail, corporate and interbank markets. This means a wide spectrum of possibilities for regulating the level of liquidity, but
at the same time makes the Bank sensitive to crises in any of these environments. The Bank has an automated risk
monitoring system that allows daily information to be obtained about the current level of future liquidity risk and online
information about the level of intraday liquidity risk.
The Bank distinguishes the following types of liquidity:
• immediate (intraday) liquidity - during the current day,
• future liquidity - in the period beyond the current day, with an additional breakdown into:
• current liquidity - in a period up to 7 days,
• short-term liquidity - in a period longer than 7 days up to 1 month,
• medium and long-term liquidity - in a period longer than 1 month.
The Bank defines liquidity risk as the risk of losing its ability to:
• settle payment obligations on time,
• obtain alternative and supplementary funds to those currently held,
• generate positive net cash flows over a certain time horizon.
The Bank’s policy of liquidity risk management involves:
• balanced, organic balance sheet growth (asset growth must be linked to a corresponding increase in financing these
assets with stable liabilities) and off-balance-sheet transactions and liabilities;
• limiting the Bank’s dependence on volatility of external conditions and ensuring that in a crisis situation - local, global, or
directly affecting the Bank - the Bank will be able to meet its obligations in the short term without limiting the range of
services provided and initiating changes in the core business profile. In the case of a longer-term crisis situation, the
Bank’s policy assumes maintaining liquidity, but allows for changes in development directions and the introduction of
costly processes to change the business profile;
• actively reducing the likelihood of adverse events that may affect the Bank’s liquidity position. This applies in particular to
events that may cause reputational risk. In such a case, the Bank will take action to restore the trust of Customers and
financial institutions as quickly as possible;
• ensuring high-quality standards for liquidity management processes. Actions aimed at improving the quality of liquidity
management processes are of the highest priority in the Bank.
The main sources of funding are liabilities to Customers, supplemented by medium and long-term credit lines and capital.
Medium- and long-term credit lines, taking into account subordinated loans and funds obtained in the process of issuing
the Bank’s debt, mainly come from the BNP Paribas Group, as well as the European Bank for Reconstruction and
Development (EBRD), the European Investment Bank (EIB), the Council of Europe Development Bank (CEB) and other
financial institutions. The Bank’s policy also allows for other sources of financing, such as structured transactions.
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Loan financing structure
The Group limits financing risk, which is associated with the threat of having insufficient stable sources of financing in the
medium and long term and the need to incur an unacceptable level of losses.
The Bank mainly finances loans using funds placed by Customers in current and term deposits, striving to maintain a stable
relationship between these positions and funds placed on the accounts of non-bank financial institutions, as shown in the
table below:
Table 71. Structure of the Group’s loan portfolio financing
PLN million
31.12.2025
31.12.2024
Net loans
91,174
85,854
Total sources of funding
155,710
144,340
Customer deposits, including:
141,339
130,925
- Retail Customers
59,183
55,184
- Corporate Customers
71,765
66,970
- Non-bank financial institutions
6,622
5,434
- Public sector institutions
3,769
3,336
Amounts due to banks *
10,145
13,415
Debt securities issued
4,226
-
*including subordinated liabilities
In 2025, the Group made changes to the structure of Tier 2 supplementary capital by replacing partially amortised
subordinated loans with issuances of 15-year capital bonds.
On 6 June 2025, the Bank issued series B capital bonds with a total nominal value of EUR 160 million; on 10 October 2025,
series C capital bonds with a total nominal value of EUR 630 million; and on 1 December 2025, series D Senior
Non-Preferred bonds in the amount of EUR 200 million. These issuances replaced the repaid subordinated loans of: EUR 40
million (from 10 December 2018), CHF 60 million (from 15 November 2012, amended on 20 November 2017), EUR 60
million (from 15 November 2012, amended on 20 November 2017), CHF 90 million (from 12 September 2014, amended on
13 September 2019), and PLN 2,300 million (from 7 December 2020).
The Bank finances its loans in foreign currencies with deposits accepted from Customers using, where necessary, foreign
exchange transactions. If necessary, the Bank may use medium and long-term loans from the BNP Paribas Group, which
provides stable funding to cover shortfalls in EUR, USD, CHF. At the end of 2025, the CHF mortgage portfolio, in the part not
covered by the provisions made, was financed with Customer deposits in CHF.
As at 31 December 2025, the structure of long-term credit lines activated within the Group was as follows:
Table 72. Structure of loans from the BNP Paribas Group in original currency
PLN million
31.12.2025
31.12.2024
CHF
0
150
EUR
2,496
1,591
PLN
4,079
6,336
Table 73. Structure of loans from the EBRD, EIB and CEB
PLN million
31.12.2025
31.12.2024
PLN
400
1,003
EUR
25
10
The net liquidity coverage ratio (LCR) for the Group was 292.8% at the end of 2025, an increase of 45.6 p.p. compared with
the end of 2024 (247.21%). LCR measures were maintained at similar levels during the year.
The Net Stable Funding Ratio (NSFR) stood at 169.63% as at 31 December 2025 for the Bank and 167.01% for the Group, an
increase of 7.53 p.p. and 7.26 p.p. year on year, respectively.
The ongoing war in Ukraine did not affect the Bank’s overall liquidity situation. Gradual NBP interest rate cuts in 2025 and
macroeconomic factors (e.g., gradually declining inflation but with continued uncertainty, moderate pace of economic
growth, wage pressure) translated into lower demand for loans among Customers and lower loan sales in 2025.
Operational risk
The Bank defines operational risk, in accordance with the requirements of the Polish Financial Supervision Authority
included in Recommendation M and the requirements of CRR3, as risk caused by inappropriate or failed internal processes,
people, systems or external factors, which includes among others legal risk, model risk and ICT risk but not but strategic
risk or reputational risk.
The Bank identifies operational risk as permanently significant.
Operational risk is inherent in all kinds of banking activity; the Bank also recognizes the consequences of materializing of
compliance risk as operational risk events and losses.
Goals of operational risk management
The Bank’s goals in operational risk management are, in particular, to maintain a high standard of operational risk
management, ensuring the security of Customer deposits, the Bank’s capital, stability of the Bank’s financial result, and
keeping operational risk within the accepted operational risk appetite and tolerance. The basic measure used to assess risk
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within the accepted operational risk appetite is the indicator of operational losses recorded by the Bank over a given period
of time. In developing the operational risk management system, the Bank follows legal requirements, including in particular
the recommendations and resolutions of the national financial supervision and the standards of the BNP Paribas Group.
Operational risk management strategy and policy
The operational risk management strategy is described in the document "Operational Risk Management and Internal
Control Strategy at BNP Paribas Bank Polska S.A." approved by the Bank’s Management Board and accepted by the
Supervisory Board. The Strategy is reviewed at least once a year, and the results of the review are reported to the Bank’s
Supervisory Board by the Bank’s Management Board. Changes to the Strategy require the acceptance of the Supervisory
Board, which assesses the implementation of the strategic assumptions for operational risk at least once a year.
The priority of the Strategy is to ensure that the Bank achieves its business objectives in a safe manner, accepting a level of
risk only within the accepted risk appetite, eliminating unacceptable events, limiting the possibility of unexpected events
with severe consequences for the Bank, and actively responding to and addressing identified events that could cause such
consequences. Achieving the above priority includes promoting an appropriate operational risk management culture within
the Bank. The objectives of the Strategy, which the Bank implemented in 2025, included compliance with laws and
regulations, monitoring and mitigating legal risk, ICT risk, risk of fraud including cybercrime, mitigating the materialisation
of risks in the Bank’s operations, and optimizing the internal control environment.
The Bank’s Management Board is regularly informed about the scale and types of operational risk to which the Bank is
exposed, its effects, and methods of operational risk management. In particular, both the Bank’s Management Board and
the Supervisory Board are regularly informed about the operational risk appetite measures defined in the Operational Risk
Management Strategy.
The Operational Risk Management Strategy covers the Bank’s subsidiaries. According to supervisory regulations, the Bank
supervises the operational risk associated with the activities of its subsidiaries. Operational risk management in
subsidiaries is carried out by dedicated units/persons appointed for this purpose. The means and methods of managing
operational risk in subsidiaries are organized adequately to the scope of the entity’s operation and the profile of its activity,
in accordance with the principles applicable in the Bank.
The organisational framework and standards for operational risk management are defined in the "Operational Risk Policy of
BNP Paribas Bank Polska S.A.", adopted by the Bank’s Risk Management Committee. According to the "Operational Risk
Policy of BNP Paribas Bank Polska S.A.", the operational risk management processes include, among others:
• identification and assessment of operational risk, including gathering information about operational events, assessing risk
in processes and products, and determining key risk indicators,
• setting the appetite and limits for operational risk at the level of the Bank and individual business areas, analysis of
operational risk and its monitoring and ongoing control,
• counteracting an elevated level of operational risk, including risk transfer.
Operational risk management organisation
The Bank maintains and develops an operational risk management system that comprehensively integrates the
management of individual types of operational risk in all areas of the Bank’s activity. The aim of the operational risk
management system is to ensure the safety of the Bank’s operational activity by implementing effective mechanisms for
identifying, assessing and quantifying, monitoring, controlling, reporting, and taking actions to limit operational risk. These
actions take into account structures, processes, resources, and scopes of responsibility at various organisational levels of
the Bank.
The Bank precisely defines the division of responsibilities for operational risk management, which is adapted to its
organisational structure. The operational risk management process is carried out within three lines of defence. The first
line of defence is the management of risk in the Bank’s operational activity. The second line of defence are Risk Area units
responsible for managing risks, including risk measurement, monitoring, controlling and reporting, independently of the
first line of defence, the Second Line of Defence Office of the Finance Area, the Legal Division, the Custody Services
Department Supervision Officer, the Regulations and Supervision Team in the Brokerage Office, and Compliance Monitoring.
The third line of defence is the Internal Audit Division.
As part of the second line of defence, comprehensive supervision over the organisation of standards and methods of
operational risk management is exercised by the Operational Risk, Internal Control and Anti-Fraud Division operating within
the Risk area. The Division’s responsibilities include, among others, issues related to operational risk management,
including ICT risk, combating fraud against the Bank, and supervision of internal control, including control of personal data
protection processes.
The determination and implementation of the Bank’s strategy regarding insurance as a method of risk limitation is the
competence of the Real Estate and Administration Department. Business continuity management, including issues related
to business continuity plans ensuring continuous and undisturbed operation of the Bank and contingency plans ensuring
the possibility of conducting the Bank’s current operations, is the responsibility of the Security and Continuity Management
Division.
As part of legal risk management, the Legal Division monitors, identifies, and analyses changes in law, their impact on the
Bank’s operations, and court and administrative proceedings concerning the Bank. The Compliance Monitoring Department
is responsible for the ongoing examination of compliance risk and the development and improvement of adequate control
techniques.
Other significant areas of operational risk management include:
• HR risk management,
• outsourcing risk management,
• model risk management,
• IT systems risk management and cyber-security (ICT risk) management,
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• conduct risk management,
for which risk management policies and procedures are defined - in accordance with the scope of competences - by
designated organisational units of the Bank.
The Bank periodically verifies the functioning of the implemented operational risk management system and its adequacy to
the current risk profile of the Bank. Reviews of the organisation of the operational risk management system are carried out
as part of regular control by the Internal Audit Division, which does not directly participate in the operational risk
management process, but provides a professional and independent opinion, supporting the achievement of the Bank’s
goals.
Supervision over the control of the operational risk management system is exercised by the Bank’s Supervisory Board,
which assesses its adequacy and effectiveness.
Risk identification and assessment tools
The Bank places particular emphasis on the processes of identifying and assessing the causes of current exposure to
operational risk within banking products. The Bank aims to reduce the level of operational risk by improving internal
processes and to limit the operational risk associated with the introduction of new products and services, and outsourcing.
According to the “Operational Risk Policy of BNP Paribas Bank Polska S.A.”, operational risk analysis aims to understand the
relationships between the factors generating this risk and the types of operational events, and its most important result is
the determination of the operational risk profile.
The Bank manages operational risk using, among others, the following tools:
TOOLS USED
MAIN PURPOSE OF TOOL USE
OPERATIONAL RISK EVENT
REGISTRATION
• Effective analysis and monitoring of operational risk
• Responding to identified vulnerabilities to operational risk
SELF-ASSESSMENT OF
OPERATIONAL RISK AND
CONTROL (RCSA)
• Building awareness about operational risk
• Identification of operational risk, determination of threats and identification of their
sources, determination of the size and potential consequences of threats
• Evaluation of control mechanisms used to limit identified threats
• Improving processes and reducing identified operational risks
• Ensuring adequate risk control in processes exposed to operational risk
TOOLS USED
MAIN PURPOSE OF TOOL USE
OPERATIONAL RISK SCENARIO
ANALYSIS (SA)
• Identifying events characterized by low frequency but high losses
• Assessing the impact of possible extreme events on the Bank’s operations by
estimating the probability of occurrence and the anticipated severity of the
scenarios under consideration
• Raising the Bank’s awareness by providing information about possible operational
risk scenarios
• Supporting the process of creating action plans for identified risks
KEY RISK INDICATORS (KRI)
• Continuous monitoring and reporting of exposure to operational risk
• Providing warning signals about the functioning and exposure to operational risk of
processes and areas of the Bank’s activities
• Monitoring changes in risk level over time
RISK ASSESSMENT OF
ONGOING PROJECTS
• Identification and assessment of operational risk associated with projects
undertaken by the Bank, including implemented or modified products
• Independent verification and checking by the second line of defence of the
correctness of risk identification and limitation by the first line of defence units
• Recommending actions to reduce risk
OPERATIONAL RISK
IDENTIFICATION FOR
CONTRACTS WITH
EXTERNAL SUPPLIERS
(OUTSOURCING)
• Ensuring proper identification and assessment, control and monitoring, and
mitigation of operational risk
• Ensuring compliance with regulatory requirements regarding the process of
outsourcing tasks by the Bank to external suppliers
OPERATIONAL RISK
REPORTING
• Providing current and periodic, management-tailored information on operational
risk: to the Bank’s Management Board, Committees responsible for risk
management, Supervisory Board, and other members of the Bank’s management,
according to the scope of responsibility
• Allowing for the assessment of the Bank’s exposure to operational risk and the
effectiveness of its management
• Disclosure of information about operational risk in accordance with Directive
2013/36/EU of the European Parliament and of the Council of 26 June 2013 on
access to the activity of credit institutions and the prudential supervision of credit
institutions and investment firms and amending Directive 2002/87/EC and
repealing Directives 2006/48/EC and 2006/49/EC, as amended (CRD IV) and the
standards required by the institutions supervising the Bank’s activities.
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The operational risk profile is understood as the identification of the main areas in which the Bank is exposed to adverse
operational events, as well as the indication of the most significant potential operational events that may (or do) result in
negative consequences for the Bank, i.e. financial and non-financial losses. The periodic evaluation and review of the Bank’s
operational risk profile are conducted based on an analysis of the Bank’s current risk parameters, changes and risks
occurring in the Bank’s environment, the implementation of business strategy, as well as an assessment of the adequacy of
the organisational structure and the effectiveness of the risk management system and internal control system functioning
in the Bank.
The Bank, in accordance with the requirements of CRR3, determines regulatory capital to cover operational risk based on
the new standardised approach for operational risk.
Operational risk control and monitoring
The purpose of internal control is effective risk control, including preventing the emergence of risk or its early detection.
The role of the internal control system is to achieve the general and specific objectives of the internal control system,
which should be taken into account when designing control mechanisms. The principles of the internal control system are
defined in the "Policy on Internal Control in BNP Paribas Bank Polska S.A.", approved by the Bank’s Management Board.
This document defines the main principles, organisational framework, and standards for the functioning of the Bank’s
control environment, in compliance with the requirements of the PFSA as defined in Recommendation H. Detailed internal
regulations related to specific areas of the Bank’s operations are adapted to the specifics of the Bank’s operations. The
appropriate organisational units of the Bank are responsible for developing detailed regulations relating to the area of
internal control, in accordance with the scope of tasks assigned to them.
The Bank’s internal control system is based on the three lines of defence model.
The Bank ensures the exercise of internal control through independent monitoring of compliance with control mechanisms,
including ongoing verification and testing.
Limiting operational risk
In 2025, the Bank undertook and continued a number of actions limiting operational risk and strengthening the control
mechanisms and processes over this type of risk. The Bank focused on geopolitical, regulatory and operational factors
impacting the operational risk profile and on cybersecurity threats which remain an important risk of rising importance. In
particular, processes and tools for countering and combating fraud to the Bank’s detriment were strengthened, including,
among others, combating credit fraud and phishing. The Bank continued a program to reduce the risk of internal fraud. The
Bank constantly monitored exposure to legal risk, including the risk arising from ongoing court cases related to CHF-
denominated loans, in order to adequately respond to changes in the level of risk. In connection with the ongoing war in
Ukraine, the Bank continuously monitored potential threats to the Bank, including security and business continuity threats.
The effectiveness of the solutions implemented by the Bank is periodically reported, in particular, to the Bank’s
Management Board and the Risk Committee at the Supervisory Board.
External environment, including geopolitical risk
In the area of operational risk management, the Bank continuously analyses risks related to the consequences of the war in
Ukraine, as well as the growing geopolitical tensions in the Middle East. These events may lead to increased cybercriminal
activity, physical attacks, and disruptions to global supply chains and critical infrastructure, including payment and banking
infrastructure. The Bank undertakes appropriate measures to ensure the safety of both its employees and Customers, as
well as to maintain business continuity and the uninterrupted execution of processes related to its operations.
Compliance risk
The Bank defines compliance risk as the risk of adverse effects, including legal and regulatory sanctions, financial penalties,
and reputation loss, in connection with the Bank’s non-compliance with laws, supervisory standards and recommendations,
ethical and market standards, and internal regulations applicable in the Bank.
Compliance assurance system
The compliance assurance system consists of organisational solutions, processes, and control mechanisms aimed at
ensuring the Bank’s compliance with laws, internal regulations, and market standards. This system operates within the
internal control system and is implemented on three lines of defence:
• first line of defence includes all organisational units responsible for the Bank’s operational functioning. These units are
obliged to comply with internal regulations, apply the control mechanisms and compliance risk control mechanisms
established in the Bank, and ensure independent horizontal monitoring of compliance with control mechanisms aimed at
ensuring compliance,
• second line of defence consists of managing compliance risk by independent organisational units appointed for this
purpose - the Compliance Monitoring Division responsible for implementing the compliance risk management process
and other organisational units of the Bank responsible for ensuring compliance in their areas of competence (e.g., risk
monitoring units, legal function, and supervision officers for brokerage and custody activities),
• third line of defence includes the activity of internal audit responsible for examining the adequacy and effectiveness of
the internal control system.
The Compliance Monitoring Division assists, in terms of compliance risk, the Bank’s Management Board in introducing and
ensuring the operation of an adequate and effective internal control system and the Supervisory Board in supervising it.
The manner of organisation and operation of the compliance system at the Bank, including the rules of compliance risk
management, is governed by the Compliance Policy at BNP Paribas Bank Polska S.A. (the Policy). All employees of the Bank
are obliged to comply with the law, internal regulations and market standards adopted by the Bank. The conduct of
employees should be consistent with the provisions of the Policy and the BNP Paribas Group Code of Conduct. In order to
strengthen the Bank’s compliance culture, the Compliance Monitoring Division ensures training of the Bank’s employees in
the scope covered by the Policy, according to the reported needs and as part of training for newly hired employees.
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Role of the compliance function
The Bank has a separate, independent compliance function: the Compliance Monitoring Division. The activity of this unit
aims to implement the process of managing compliance risk, i.e., introducing solutions that allow for the identification,
assessment, control and monitoring of compliance risk. This unit is also responsible for reporting in this area to the Bank’s
Management Board and the Supervisory Board, including the Audit Committee.
As part of the compliance assurance system, the activities of the Compliance Monitoring Division also include: designing
and implementing internal regulations, consulting, conducting investigations, developing compliance risk control
mechanisms, vertical ongoing verifications, and vertical and horizontal testing of the effectiveness of control mechanisms
ensuring the Bank’s compliance with laws, internal regulations and market standards, including adherence by the Bank’s
first line of defence of the internal control system, with particular emphasis on the following areas:
• anti-money laundering and counter-terrorist financing,
• compliance with international embargoes and sanctions,
• protection of Customer interests,
• professional ethics and anti-corruption,
• conduct on financial markets,
• counteracting market manipulations and the use of inside information,
• managing conflicts of interest,
• compliance by the Bank and its Customers with regulations on tax avoidance and those related to financial markets, with
a transnational scope
• Appropriate mechanisms have been implemented in the Bank to ensure the independence of the compliance function and
to enable it to perform its tasks.
As part of the Bank’s organisational structure, the Director of the Compliance Monitoring Division reports directly to the
President of the Bank’s Management Board, and the regulations governing the operation of this Division and the necessary
mechanisms to ensure its independence are approved by the Bank’s Supervisory Board. Furthermore, there is a special
procedure in the Bank for appointing and dismissing the person leading the compliance function, and necessary rules are in
place to protect the employees of this function from unjustified termination of employment.
Key measures to mitigate compliance risk
To ensure compliance with regulatory requirements and to strengthen the Bank’s internal control system, a number of
significant actions were carried out in 2025, contributing to the mitigation of the risk of non-compliance with applicable
regulations and supervisory recommendations.
As part of the implementation of recommendations issued by the Polish Financial Supervision Authority (UKNF), the
customer risk assessment matrix was updated to reflect new regulatory guidelines. The review period for customers
assessed as standard-risk was shortened to a maximum of five years. Detection scenarios for money laundering risks were
also modified by lowering value thresholds that trigger alerts in selected customer groups and scenarios, enabling earlier
identification of potential threats. A new customer data update process was introduced, based on verification of information
in official public registers, which increased data reliability and improved the quality of customer assessments.
In response to evolving geopolitical conditions, in 2025 the Bank blocked the execution of transfers to and from Russia and
Belarus. This decision reflected the growing exposure to various risks associated with cooperation with these countries.
The Bank continued its systematic educational campaign aimed at employees, designed to strengthen awareness of ethical
standards, including anti-corruption measures and the protection of inside information.
Control mechanisms were also reinforced in particularly sensitive areas, including oversight of reference rate quotation, the
flow of inside information, and the management of conflicts of interest. In particular, additional control procedures were
introduced in connection with employees’ personal transactions, which contributed to greater transparency and
compliance with ethical principles.
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Sustainability
Statement
135 General Disclosures (ESRS 2)
160 Climate change (ESRS E1)
177 Taxonomy disclosures
181 Own workforce (ESRS S1)
201 Consumers and end-users (ESRS S4)
212 Business conduct (ESRS G1)
219 Additional information on the entity
225 Appendix 1
228 Appendix 2
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Introduction
This chapter presents information on the sustainability (sustainability reporting hereafter referred to as the Sustainability
Statement) of the BNP Paribas Bank Polska S.A. Capital Group in accordance with the information requirements under the
amended Accounting Act (as a result of the transposition of the Corporate Sustainability Reporting Directive (CSRD),
Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 and the European
Sustainability Reporting Standards (ESRS).
Sustainability reporting requires a description of all material impacts, risks and opportunities, their integration into the
Group’s strategy, governance, action plans, measures and targets. The Group conducted this analysis and assessed the four
material topics detailed in this report: climate change, own workforce, consumers and end-users, business conduct and
entity-specific disclosures including market integrity, financial security and cybersecurity.
The following definitions are used in this Sustainability Statement:
• the Bank - BNP Paribas Bank Polska S.A.
• the Group - BNP Paribas Bank Polska S.A. Group
• the BNP Paribas Group - the international banking group BNP Paribas, which is the strategic shareholder of the Bank.
Disclaimer
Despite the changes in the standardisation of methodologies for quantitative analyses of ESG factors and their impact on
traditional financial risks in recent years, they should be interpreted with caution in light of their limitations.
The quantitative information presented in this statement should be read in conjunction with the methodologies and
definitions used in the accompanying narrative.
The Group gradually adapts its methodologies, taking into account developments in knowledge, data availability and the
creation or updating of recognised databases / data sources and standards.
General Disclosures (ESRS 2)
Basis for preparation
General basis for preparation of the sustainability statement (BP-1)
The BNP Paribas Bank Polska S.A. Capital Group prepares its sustainability statement on a consolidated basis.
Information presented in the Sustainability Statement relates to the period from 1 January 2025 to 31 December 2025,
unless otherwise specified in the Sustainability Statement. The Sustainability Statement presents the information on the
operations and the financial data as well as the sustainability information of the BNP Paribas Bank Polska S.A. Capital
Group which includes BNP Paribas Bank Polska S.A. as a parent entity as well as companies of the BNP Paribas Bank Polska
S.A. Capital Group as at 31 December 2024 including:
• BNP Paribas Towarzystwo Funduszy Inwestycyjnych S.A.
• BNP Paribas Leasing Services Sp. z o.o.
• BNP Paribas Group Service Center S.A.
The scope of consolidation is the same as the Consolidated Financial Statements of the BNP Paribas Bank Polska S.A.
Capital Group for the year ended 31 December 2025.
No subsidiary of the Bank exceeds the thresholds set out in the Polish Accounting Act and is not required to prepare its own
sustainability statement in accordance with the ESRS.
The Sustainability Statement covers the Group’s entire value chain, where indicated, i.e. its own operations, as well as the
upstream and downstream value chains. The Group’s value chain is described in this chapter under Strategy, business
model and value chain (SBM-1).
In the preparation of this Statement, we used the option of omitting certain information related to intellectual property,
know-how, and innovation. We are not disclosing sensitive information which is key to our business strategy and
development plans in order to protect our competitive position. The foregoing is without prejudice to the general
materiality of the disclosures.
Governance
The role of the administrative, management and supervisory bodies (GOV-1, GOV-2)
Sustainability governance structure
As of 2022, the Bank has a Sustainability Area, with the Chief Sustainability Officer (CSO) as its Executive Director. The CSO
acts as the main coordinator for sustainability in the organisation, heads the Sustainability Council, and reports on ESG
issues directly to the CEO, who oversees the implementation of the strategic integration of sustainability aspects into the
organisation’s activities. The main tasks of the Sustainability Area include developing and coordinating the implementation
of the Bank’s sustainability strategy, as well as initiating, implementing and reporting on sustainability-related initiatives,
projects and programmes. The sustainability strategy is an integral part of the Group’s business strategy, hence a number
of organisational units in the Bank and its subsidiaries are involved in its implementation. Since January 2026,
Sustainability Area has been merged with Food & Agro; the new Sustainability & Agrobusiness Area is headed by the new
Executive Director and Chief Sustainability Officer (CSO).
The Management Board is kept informed on sustainability issues, including the impacts, risks and opportunities associated
with them, through the committees operating within the Bank and the units within the scope of their responsibilities.
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A number of the Bank’s collegiate bodies, including the Credit Committee, the Internal Control Committee, the Risk
Management Committee, the Retail Banking/Personal Finance Risk Committee, the Ethics and Standards of Conduct
Committee, report on specific sustainability issues (including risks and negative impacts). A Sustainability Council has been
established as an advisory body to comprehensively monitor ESG issues in various aspects of the Bank’s activities and at
various organisational levels, and to discuss the assumptions of the Strategy, in particular the Bank’s ESG plans and
declarations.
Sustainability issues are of interest to the Supervisory Board, which oversees the Bank’s activities, including the
implementation of the sustainability strategy, which is implemented by the Bank’s Management Board as the main
managing body of BNP Paribas Bank Polska. There are Supervisory Board committees with decision-making powers on
specific aspects considered to be related to, among others, sustainable development, as described in the further part of this
chapter.
The Bank has the competence to carry out double materiality assessment, which have been mapped in the preparation of
this year’s disclosures. The Target Operating Model defines units and persons responsible at the Bank for impacts, risks and
opportunities (IRO) identified in the materiality assessment and described in detail under Description of the process to
identify and assess material impacts, risks and opportunities (IRO-1).
Group’s sustainability governance structure in 2025
Supervisory Board
provides continuous oversight of the Bank’s activities in all aspects of its operation
Audit Committee
Risk Committee
Nominations Committee
Remuneration Committee
Management Board
is responsible for the management and effective functioning of all units and the strategy of the Bank. The Management Board represents the Bank externally and before the owner
Sustainability
implements the
sustainability
strategy
Risk Processes and
Reporting
Department
is responsible for
analysing risks
(including climate
risks) and the
calculation of Scope
3 Cat.15 emissions
Management
Accounting and
Investor Relations
Division
coordinates the flow
of financial and non-
financial data and is
responsible for
sustainability
reporting and
assurance
HR
pursues its HR
mission and strategy
by focusing on
people,
development,
automation and
optimisation, as well
as security
Operations &
Support
provide support to
all units of the Bank
Compliance
Monitoring Division
ensures the Bank’s
compliance and
manages compliance
risk
Strategy and Market
Analysis Division
implements new
requirements into
the Bank’s business
strategy
Business lines
implement the
business strategy
and serve customers
Sustainability Council
monitors the implementation of the Group’s sustainability strategy and related indicators
Credit Committee
makes credit assessment decisions taking into account ESG considerations
Internal Control Committee
oversees the consistency, effectiveness and completeness of the internal control system including ESG reporting
Risk Management Committee
monitors and oversees the Bank’s principal risks (including ESG risks)
Retail Banking/Personal Finance Risk Committee
supports credit risk management including ESG risks
Ethics and Standards of Conduct Committee
is responsible for KPIs related to compliance with the Code of Conduct and assessment of risks and actions related to standards of conduct
Ethics Officer
supports reinforcing of ethical attitudes and consults employees
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Management and supervisory bodies and sustainability information provided to them
Management Board
The Management Board is the main body responsible for management of the BNP Paribas Bank Polska S.A. It is responsible
for the implementation of the strategy based on the long term vision, considering the sustainable development of the entire
organisation, and acts in an interest of the Group and its stakeholders, especially the shareholders and investors. It defines
the directions of the operations of the Group. It ensures that they are executed by the top and lower level management, in
line with its interest, considering environmental, social and governance factors.
The role of the Bank’s Management Board and other bodies is described in detail in the Bank’s Articles of Association, which
is available at the Bank’s website and under Statutory bodies of the Bank in the Management Board Report of the Group.
The organisation of the Bank’s risk management system (described in more detail in the chapter Risk and opportunities)
primarily takes into account the roles of the Bank’s Management Board, Supervisory Board, dedicated committees (Audit
Committee and Risk Committee of the Supervisory Board), Assets and Liabilities Committee (ALCO), Risk Management
Committee, Retail Banking Risk Committee, Personal Finance Risk Committee, Credit Committee, Problem Assets Committee,
TAC/NAC Committee, and Internal Control Committee, the Risk Area, the Finance Area, the Compliance Division and the
Legal Division.
Composition and diversity of the Bank’s Management Board as at 31 December 2025:
• the Management Board consists of eight Board Members;
• the percentage of women is 37.5% (three women and five men);
• three nationalities were represented (Polish, Belgian and Ukrainian).
All Management Board members have expertise in sustainability in relation to the implementation of the strategy, which
applies to all areas overseen by them.
On 21 October 2025, Andre Boulanger resigned as Vice-President, Head of CIB effective as of 31 December 2025. As of 1
January 2025, Natalie Yacoubian joined the Management Board of the Bank. On 2 January 2026, Agnieszka Wolska resigned
as Vice-President, Head of SME and Corporate Banking. Following the changes on the Management Board, the percentage
of women on the Management Board was 42.9% as at the date of this publication.
The progress of the sustainability strategy is presented quarterly to the Management Board and Supervisory Board by the
Executive Director of the Sustainability Area.
The Bank’s Management Board meets weekly, or more frequently if circumstances or the Group’s interests require so, and
the topics discussed include sustainability impacts, risks and opportunities. The Management Board discussed
sustainability approximately 40 times in 2025, addressing topics including:
• sustainability reporting status and plan and updated Double Materiality Assessment (DMA) process for 2025 based on the
2024 report benchmarks; the Management Board reviewed the process and methodology applied to conduct the DMA and
approved the results of the double materiality assessment, which defines the scope of annual sustainability reporting by
key topics as required by the ESRS;
• selection of the audit firm to provide assurance of the Bank’s and the Group’s sustainability reporting for 2025,
• climate issues, e.g. financing the energy transition, classification of the sustainable financing portfolio, results of the
portfolio and proprietary activity carbon analysis, efforts to develop the Bank’s approach to decarbonisation and
prudential transition plan;
• ESG risk;
• the Bank’s strategy for ESG-related services;
• human resources, e.g. equality and inclusion, salaries;
• Customer’s Voice: a report on complaint handling and priority actions to improve the NPS;
• corporate governance, e.g. key indicators for compliance with ethics and standards of conduct, whistleblowing policy.
Supervisory Board
The Supervisory Board exercises continuous oversight of the Bank’s activities in all aspects of its operation. The Supervisory
Board approved the Group’s new strategy in December 2025 (which includes the sustainability strategy) for 2026-2030. The
Supervisory Board o approves the strategic objectives and certain policies related to sustainability. It is also responsible for
verifying that the members of the Management Board and executive directors have met the ESG criteria on which part of
their variable annual remuneration depends and monitors integration of risks including ESG risks. The Supervisory Board
also monitors the work of the Management Board to the extent of its objectives.
The committees of the Supervisory Board (Audit Committee, Risk Committee, Remuneration Committee and Nominations
Committee), consisting of members of the Supervisory Board, have a consultative and advisory function for the Supervisory
Board and enhance its work.
Composition and diversity of the Supervisory Board as at 31 December 2025:
• The Supervisory Board consists of 12 persons;
• The percentage of women is 50% (six women and six men);
• Three nationalities were represented (Polish, French and Belgian);
• 50% of independent members in accordance with the independence criteria.
More information regarding the Supervisory Board is included in the chapter Corporate governance, section Supervisory
Board.
The Audit Committee supports the Supervisory Board with regard to, among others, monitoring the integrity of financial
information and carrying out auditing activities involving non-financial information published by the Bank. The Audit
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Committee is also responsible for ensuring the information flow and good cooperation between the external auditor
(statutory auditor), internal audit and the Supervisory Board.
In 2024, the Audit Committee monitored the implementation of the CSRD at the Bank. In 2025, the Audit Committee
reviewed the Sustainability Statement of the BNP Paribas Bank Polska S.A. for 2024 and the results of independent
verification of ESG data. The Audit Committee was informed of the results of the double materiality assessment for 2025
disclosures and recommended that the Supervisory Board select Ernst & Young Audyt Polska Sp. z o.o. Sp.k. as the auditor
to provide assurance of the Sustainability Statement for 2025.
During its meetings, the Audit Committee reviewed the execution of the complaint handling process, the NPS results and
action plan, a report on compliance with the principles of ethics, a review of breaches of regulations, and a report on the
Bank’s compliance with the Best Practice for WSE Listed Companies 2021. The Audit Committee discussed the annual and
semi-annual Management Board reports and the 2025 Sustainability Statement work plan.
The Risk Committee supports the Supervisory Board in overseeing the area of risk management. The Risk Committee issues
opinions on the Bank’s overall current and future risk appetite, the risk management strategy for the Bank’s activities
developed by the Management Board and the information submitted by the Management Board on the implementation of
this strategy. The Risk Committee ensures appropriate risk identification, assessment and mitigation, including through
integration of sustainability risks into the risk management framework.
In 2025, in its discussions of credit risk, the Risk Committee addressed the level of physical risk, transition risk, risk appetite
and the results of ESG questionnaires that are filled out when providing financing to customers. In addition, the Risk
Committee discussed ESG risks including information on regulatory risks and greenwashing risks. The Risk Committee
reviewed reports on progress of the decarbonisation strategy and data collection for setting emission reduction targets. The
Risk Committee reviewed a presentation comparing the Bank with other banks in this regard.
The Remuneration Committee and Nominations Committee support the Supervisory Board in its supervisory duties in the
area of human resources management, as referred to in Own workforce (ESRS S1). The competences of the Remuneration
Committee include, among others, analysing the performance of the members of the Management Board, its consistency
with the strategic goals, ethical standards and regulatory requirements, and making suggestions to the Supervisory Board
in this respect, as well as recommending key performance indicators to the Supervisory Board for the members of the
Management Board. At least once a year, the Nominations Committee performs an individual and collective assessment of
the suitability of the members of the Supervisory Board, which includes an evaluation of their knowledge, skills and
professional experience.
In 2025, the Remuneration Committee discussed, among others, the adjusted and unadjusted pay gap of the Bank and the
outcome of the resulting salary raises.
A description of the composition and tasks of the various committees of the Supervisory Board can be found in the chapter
Corporate governance, section Committees of the Supervisory Board
In 2016, the Group adopted a Code of Conduct that sets out standards of conduct in line with the values and mission
defined by the BNP Paribas Group. The Bank’s Management Board is accountable to the Supervisory Board for compliance
with the provisions of the Code by all employees. Once a year, the Bank’s Supervisory Board reviews the results of the
assessment of compliance with the ethical principles at the Bank. The Code is regularly updated and its current version is
available on the Bank’s website.
Depending on the escalation path, whistleblowing reports are forwarded to dedicated email inboxes to which the President
of the Management Board or the Chairperson of the Supervisory Board has access. An important element of the
implementation of the whistleblowing policy is the whistleblowing process governed by the Whistleblowing Policy at BNP
Paribas Bank Polska S.A., which is designed to protect the interests of the Bank, employees, customers, third parties and to
monitor compliance with the law. Whistleblowing Officers are responsible for receiving reports at the Bank (for more
details, see the section: Business conduct policies and corporate culture (G1-1)).
Expertise and skills of members of the Supervisory Board and Management Board
All members of the Supervisory Board and the Management Board have a variety of skills and experience in the field of
sustainability that they have acquired during their careers. More detailed information on the expertise of each member of
the Bank’s Management Board and Supervisory Board is presented in the chapter Corporate governance, section Statutory
bodies of the Bank.
The top management make every effort to broaden their range of competences in the area of sustainability, climate change
and climate policy at advanced international training courses (e.g. Cambridge Institute for Sustainability Leadership) and
meetings with recognised experts and researchers. They regularly participate in sustainability conferences.
The Management Board and the Supervisory Board of the Bank are composed of persons with the necessary skills and
competences to monitor the Bank’s and the Group’s material impacts, risks and opportunities.
Expertise and skills of the members of the Bank’s Management Board
At the date of publication of the report, all members of the Management Board and the Supervisory Board have
documented trainings in sustainability. The table below summarises training completed in 2025. Additional skills are
included in the CVs of the members of the Management Board and the Supervisory Board presented in the chapter
Corporate governance, section Management Board and Supervisory Board.
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Table 74. Training of members of the Supervisory Board and Management Board with sustainability content
Management Board
Supervisory Board of the Bank
Training completed in 2025 / Member of
the body
Przemysław
Gdański
Andre Boulanger
Małgorzata
Dąbrowska
Wojciech
Kembłowski
Piotr Konieczny
Magdalena
Nowicka
Volodymyr Radin
Agnieszka
Wolska
Lucyna
Stańczak
-
Wuczyńska
Francois
Benaroya
Jean
-Charles
Aranda
Małgorzata
Chruściak
Sophie Heller
Monika Kaczorek
Bożena
Leśniewska
Vincent Metz
Piotr Mietkowski
Khatleen
Pauwels
Jacques Rinino
Mariusz Warych
Code of Conduct 2025
Protecting customer interests
Conflicts of interest
Golden rules of cybersecurity 2025
Financial security
Market trends and outlook for Supervisory
Board and Management Board members
Preventing bribery and corruption – Most
exposed employees
Cyberdefence Awareness
Integration of sustainability-related performance in incentive schemes (GOV-3)
The Group aspires to ensure competitive, fair remuneration for all employees and managers. The remuneration principles
for members of the Bank’s Supervisory Board and persons with a significant impact on the Bank’s risk profile, including
members of the Bank’s Management Board, are described in the chapter Corporate governance, section Remuneration of
the Management Board and the Supervisory Board. Those rules are governed by the Remuneration Policy for Members of
the Supervisory Board of BNP Paribas Bank Polska S.A. and the Remuneration Policy for persons with a significant impact on
the risk profile of the Bank.
The Supervisory Board receives only a fixed remuneration from BNP Paribas Bank Polska S.A. (members of the Supervisory
Board who are at the same time employed in any entity of the BNP Paribas Group do not receive any remuneration for their
function as a member of the Bank’s Supervisory Board) and, therefore, the members of the Supervisory Board do not receive
a variable remuneration linked to the sustainability objectives.
The members of the Bank’s Management Board may acquire an entitlement to variable remuneration, the amount of which
is determined on the basis of the Bank’s performance, the performance of the business area and individual performance
and is subject to change in line with changes in this performance. Targets are set individually for each member of the
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Bank’s Management Board. The targets are reviewed by the Remuneration Committee and are approved by the Bank’s
Supervisory Board and are then cascaded within the Bank’s structures.
Sustainability was one of the four key pillars of the strategy GObeyond for 2022-2025 (Pillar POSITIVE); sustainability
objectives are therefore included in the targets of the Management Board members, however, it is not possible to
determine a direct percentage relationship between the variable remuneration of the members of the Management Board
and the achievement of sustainability targets.
In 2025, the targets for the members of the Bank’s Management Board included the following sustainability targets:
• As part of the Bank’s strategic financial targets: new volume of sustainable financing in 2025 – the target represented
between 2.5% and 7.5% of annual targets depending on the member of the Management Board. The target did not apply
to the member of the Management Board responsible for risk (Chief Risk Officer), who was set a target related to active
support and development of sustainability, processes and strategies.
• As part of strategic and non-financial targets representing between 40% (Management Board members) and 50% (CEO) of
annual targets:
target regarding the Code of Conduct, completion of compliance training and implementation of audit
recommendations,
target for employee engagement and eNPS (for all Management Board members),
target for customer satisfaction and NPS (of the Bank or the area, depending on the member of the Management
Board),
targets related to identification and promotion of Green IT initiatives (for the Management Board member responsible
for New Technologies and IT Security),
sustainable finance leadership targets: share of sustainable finance in the Group’s loan portfolio (for all Management
Board members).
The Remuneration Policy for Members of the Supervisory Board and the Remuneration Policy for persons with a significant
impact on the risk profile of BNP Paribas Bank Polska S.A. (including members of the Management Board of the Bank) are
voted by the General Meeting.
The Remuneration Policy for the Bank’s employees including incentive programmes is approved by the Bank’s Supervisory
Board.
Remuneration rules for employees of subsidiaries are approved by the subsidiary’s Supervisory Board or Management
Board.
All the strategic objectives of the POSITIVE pillar were included in the Bank’s 2025 Sustainability Area Executive Director’s
targets. In addition, 2025 sustainability targets were set for senior managers, all employees in the Sustainability Area units
and persons responsible for developing and selling sustainable products and services. We are committed to ensuring that
all employees adhere to the principles of sustainability as the basis of the organisational culture and meet measurable
sustainability targets.
The variable remuneration policy for persons performing portfolio management or investment advisory activities in the
Group, within the meaning of the Sustainability Finance Disclosure Regulation (SFDR), takes into account the principle of
not encouraging excessive risk-taking with regard to sustainability risks and is linked to risk-adjusted performance.
Statement on due diligence (GOV-4)
The Group operates in a responsible manner, respecting human rights, labour standards and anti-corruption regulations.
A description of the due diligence that the Group exercises in the context of sustainable development can be found in
various sections of this statement. It covers both its own operations and its approach to the entire value chain.
The table below presents the key elements of due diligence for each section of the Sustainability Statement.
Key elements of due diligence
Section in the Sustainability Statement
Embed due diligence into governance, strategy and business model
The role of the administrative, management and
supervisory bodies (GOV-1, GOV-2),
Strategy, business model and value chain (SBM-1),
Policies related to own workforce (S1-1),
Policies related to consumers and end-users (S4-1)
Engage with affected stakeholders in all key steps of the due diligence
process
Interests and views of stakeholders (SBM-2),
Processes for engaging with own workforce and workers
representatives about impacts (S1-2)
Identify and assess adverse impacts
Description of the process to identify and assess material
impacts, risks and opportunities (IRO-1),
Material impacts, risks and opportunities and their
interaction with strategy and business model (SBM-3)
Address these adverse impacts
Transition plan for climate change mitigation (E1-1),
Processes to remediate negative impacts and channels
for own workforce to raise concerns (S1-3),
Taking action on material impacts on own workforce, and
approaches to mitigating material risks and pursuing
material opportunities related to own workforce, and
effectiveness of those actions (S1-4),
Processes to remediate negative impacts and channels
for consumers and end-users to raise concerns (S4-3),
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Prevention and detection of corruption and bribery (G1-
3)
Track the effectiveness of these efforts and communicate
The role of the administrative, management and
supervisory bodies (GOV-1, GOV-2),
Strategy, business model and value chain (SBM-1)
The activities of the Group’s Customers may have a negative impact on certain sustainability issues and give rise to
material risks. Therefore, in response to the requirements of the EBA/GL/2020/06 Guidelines of 29 May 2020 on loan
origination and monitoring, we developed ESG assessment questionnaires for all our Customers in the corporate, SME and
micro-enterprise segments. The purpose of the assessment is to identify any risks related to ESG factors affecting the
financial situation of the Customers, as well as the impact of the Customers’ economic activities on ESG factors.
For large Customers in the corporate segment, we also use a comprehensive assessment of the level of sophistication of
sustainability practices (ESG Assessment). The analysis is carried out on the basis of extensive questionnaires that
correspond to EU sustainability regulations and focus on ESG factors relevant to the industry. Thanks to the
comprehensiveness of the issues analysed, the Group:
• assesses the scale of Customers’ engagement in their key areas of social and environmental impact,
• determines whether Customers are aware of sustainability challenges and what commitments and actions they are
taking,
• monitors progress in the implementation of ESG practices.
In 2025, the Bank carried out work to align with the EBA Guidelines EBA/GL/2025/01 on the management of environmental,
social and governance risks. This included the implementation of questionnaires for collecting the data required by the
guidelines for various categories of entities, which have been in use at the Bank since 2026.
Risk management and internal controls over sustainability reporting (GOV-5)
Information on the main features of the Group’s internal controls is detailed in the chapter Corporate governance, section
Internal control system (including control and risk management system for the preparation of financial reports).
The internal control system for sustainability reporting, aligned with the Group’s overall internal control framework, is
based primarily on:
• defining the roles and responsibilities of individual units and persons responsible for specific parts of the Sustainability
Statement, as set out in the Sustainability Statement Rules, which form part of the Policy on fulfilling disclosure
obligations related to the listing of the Bank’s shares on the Warsaw Stock Exchange.
• establishing a dedicated internal control plan for the units involved in preparing the Sustainability Statement.
• approving individual sections of the Sustainability Statement by designated responsible persons.
The Investor Relations and ESG Reporting Office, which coordinates the preparation of the Sustainability Statement,
constitutes the second line of defence in this process.
First line controls focus on ensuring:
• compliance of sustainability reporting with ESRS and national and EU regulations;
• quality of the reported sustainability data.
The risk management system related to the sustainability reporting process follows the same framework as the Group’s
overall risk management system, described in the section Managing impacts, risks and opportunities.
As part of its oversight of the sustainability reporting process, the Audit Committee reviewed matters related to
sustainability statements, including the double materiality assessment, key performance indicators, and observations
arising from the assurance process.
Strategy
Strategy, business model and value chain (SBM-1)
The Group’s diversified business model
The BNP Paribas Bank Polska S.A. Capital Group is based on a diversified business model in order to respond to the needs of
Customers in a coordinated manner and create value for them. The Group’s parent company - BNP Paribas Bank Polska S.A.
– is a universal Bank with a full product offering for Polish and international corporations, the SME segment, farmers and
retail Customers, with a local presence but with a global reach. The Bank holds a leading position in the agri-food and
consumer segments, as well as in the sector of large companies and multinational corporations.
Foundations of our business:
• Completeness of the offer – We offer Customers a variety of financial products and services provided by the Bank and
Group companies. We are close to our Customers. We provide services in a network of banking Customer Centres and we
are constantly developing and adapting our outlets to their needs. Our credit products are also available at partner shops
and selected car dealer networks. To meet the technological challenges, we are constantly developing our products and
digital service channels: mobile and online banking, and new forms of communication.
• Availability of the offer – We aim to provide every Customer with equal access to banking. To this end, we are improving
our products and introducing facilities at Customer Centres. Through these facilities, we provide access to banking for
people with disabilities, seniors and those from groups at risk of exclusion.
• Responsible risk management – Our aim is to provide the highest quality service to Customers. Prudent risk management
and a culture of compliance are the pillars of the Group’s business operations. We have implemented and apply
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procedures through which we manage risk. One of the key elements of this system is the management of ESG risks,
including climate risk.
• Supporting Customers in sustainable transition – The long-term promotion of sustainable economic development and the
building of lasting relationships with Customers and other Group stakeholders is a key dimension of our responsibility. We
offer products and services tailored to the changing needs of Customers, such as: Sustainability-Linked Loans, ESG Rating-
Linked Loans and products with a positive environmental impact for green investments and projects. We strive to respond
to global challenges and the conditions of the Polish market.
The Group conducts its business based on the following operating segments:
• Retail and Business Banking - serves retail Customers – including private banking Customers (Wealth Management) and
business Customers – as well as micro-enterprises,
• Corporate Banking– offers a wide range of financial services to large and medium-sized enterprises, local government
units and entities that belong to international capital groups,
• Small and Medium-sized Enterprise Banking– serves Agro and non-Agro Customers,
• Corporate and Institutional Banking (CIB) – supports the sale of the Group’s products to Polish companies and serves
strategic Customers,
• Other banking activities include the Asset and Liability Management Division and the Corporate Centre.
Business model
How the Bank creates value
The Bank operates a business model aimed at value creation for all stakeholders in the changing world. The Bank pursues
this objective through its business units.
The figure below presents the Group’s key intangible resources and explains how the Group’s business model depends on
them. The key capitals built and consumed in the Group’s operations generate effects for the stakeholders, as measured
with the key indicators set for the resources.
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• Funds raised from Customers and shareholders,
and profits we generate
KEY RESOURCES
INPUTS
IMPACT FOR STAKEHOLDERS
SELECTED 2025 ACHIEVEMENTS
FINANCIAL CAPITAL
HUMAN AND
INTELLECTUAL CAPITAL
OPERATING CAPITAL
SOCIAL CAPITAL
ENVIRONMENTAL
CAPITAL
Increasing value for shareholders while respecting the
principles of sustainable development. Offering
responsible financial products and services.
A responsible workplace that enables implementation
of the Group’s strategy and supports an inclusive
organisational culture, offering broad opportunities for
development and social engagement
Top-quality financial products and services delivered
through secure channels tailored to Customers’ needs
Professional Customer service based on stable relations
Impact of social initiatives that address the challenges
of our environment. Equalising opportunities and
preventing social exclusion
Products and services that support environmental and
climate protection. Promoting responsible behaviour
among employees, suppliers, and Customers
•
Return on equity (ROE): 18.7%
•
Share of sustainable finance: 14.6%
•
Reduced adjusted gender pay gap: 3.7%
•
eNPS at 20 points
•
NPS – Retail Banking and Personal
Finance: 6th position
•
% of key processes available in remote
channels (for retail Customers): 87%
•
Customer Centres with ‘Barrier-Free
Facility’ certification: 41.5%
•
Social engagement (annual average per
employee): 2h 40 min
•
Reduction of CO
2
emissions from
operations vs 2019: -61%
•
Reduction of energy consumption
vs 2019: -50%
• Skills, experience and engagement of employees
• Intellectual property, global brand
• Effective use of new technology
• Prudent risk management
• Traditional and digital communication channels
•
Relations with stakeholders that build mutual trust
•
Engagement through many partnerships and social
programmes
• Integration of climate factors into business
decisions
• Promoting sustainable finance and supporting
Customers in energy transition
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The Group uses its human, financial, and technical resources to create and distribute financial products and services, as
presented in the table below.
Table 75. Presentation of core products and services of the Group’s business segments
Retail and Business Banking
Corporate and SME Banking
Corporate and Institutional Banking
(CIB)
Deposits and savings (maintaining
current accounts and deposit accounts,
accepting term deposits)
Deposits (current accounts, term
deposits), cash management
Managing cash flows and liquidity,
optimising working capital
Distributing banking services (daily
banking, payments, currency exchange,
debit and credit cards)
Distributing financial solutions (overdraft,
revolving loans, investment loans, leases,
factoring, arranging bond issues)
Financing services (financing current
business, financing M&As and investment
projects)
Distributing financial solutions (house
loans, cash loans, consumer loans,
overdraft, micro-business loans)
Financial market products (currency
exchange and derivative transactions for
Customers)
Transactions in currency and money
markets (including derivatives), sale of
financial market products hedging
currency risk, interest rate risk and
commodity price risk
Distributing insurance and investment
products (brokerage, investment
advisory, distributing investment fund
shares)
Global trade finance (full service for
import and export LCs, bank guarantees,
documentary collection)
Advisory on M&As and restructuring,
advisory and arranging capital market
transactions
Specialised services: real estate finance,
structured finance for mid-caps,
investment banking, services for local
governments and agro-business
Value chain
The Group’s products and services are distributed in the downstream part of the value chain by specific business segments
(e.g., retail banking), forming the commercial activity of the Group’s integrated business model. The main participants in
this part of the value chain are Customers served within the Group’s operational segments.
The upstream part of the Group’s value chain, together with its own operations, constitutes the operational scope
necessary to conduct business activities. The upstream segment is associated with all providers of services and products to
the Group (e.g., suppliers of energy, electronic equipment, office supplies, and various services, including advisory services).
The main participants in this part of the value chain are suppliers and business partners, as well as investors providing the
Bank’s financial capital.
The Group’s internal functioning, i.e. its own operations, include the activities required to support business operations,
including the management of business processes, administration of buildings, equipment and services used in day-to-day
operations, and the consumption of resources such as energy and water by the Group’s own workforce, including the Bank’s
subsidiaries. Participants in this part of the value chain include employees under employment contracts and contractors.
For the purposes of this statement, the Group conducted a double materiality assessment of the value chain of its business
model, where BNP Paribas, through its operational activities and core business, maintains a direct business relationship,
particularly with Customers.
The value chain diagram is simplified but it reflects the diversity of services offered to our Customers and covers the Bank
and the subsidiaries: TFI, GSC and Leasing Services.
Business strategy
In 2025, the Bank continued to implement the GObeyond strategy. The main objective of this strategy, adopted by the
Management Board and the Supervisory Board in March 2022 for the years 2022–2025, was the further dynamic
development of the Bank as an institution operating efficiently, with engaged employees and satisfied Customers, while
positioning itself as a sustainability leader. Following several years of multi-stage scale building through acquisitions, the
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GObeyond strategy focused on organic growth while maintaining a responsible approach to risk management. It is the
Bank’s first business strategy fully integrated with the ESG strategy.
Changes in strategy and/or business model
Since 2022, the strategy has been implemented unchanged. In 2024, we started work on preparing the business strategy for
the next period. Taking stakeholders’ interests and viewpoints into account when defining the Group’s strategy strengthens
the relationship of trust. This approach continued. when defining the next strategic plans. In December 2025, we
announced the Accelerate 2030 strategy for 2026-2030 described in the chapter Strategy and prospects.
Sustainability targets
The quantitative targets of the GObeyond sustainability strategy are included in the table below. They allow the Group to
monitor and evaluate the effectiveness of the products and services offered in relation to the sustainability targets.
These targets were adopted on the basis of internal estimates and analyses. They have been mapped to individual ESRS
standards for the purposes of this report.
The main area of impact of the Group’s sustainability action is to support the ecological transition of economic entities. To
this end, we develop and offer products with a positive environmental impact, such as financing for renewable energy,
energy efficiency and electromobility, as well as Green Loans. We also offer products linked to ESG assessment and
performance, including Sustainability Linked Loans
The Group supports businesses across industries and sectors in their transition towards zero carbon. We also take
measures to reduce our direct environmental impact (reduction of our own CO₂ emissions). The Group initiates
sustainability projects in Poland through partnerships.
During the time horizon of the strategy, from 2022 to the end of 2025, we implemented the sustainability strategic targets
presented in the chapter GObeyond strategy implementation – Pillar POSITIVE focusing on environmental responsibility.
The Group is building social capital among employees through training programmes, the ESG Academy and employee
volunteering. These activities are described in more detail in the section Own workforce (ESRS S1) and the presentation of
Pillar TOGETHER, the employee pillar of the strategy.
Information on actions taken in pursuit of the strategic targets is further presented under the individual strategic pillars
(chapter Strategy and prospects).
Table 76. Targets defined in GObeyond sustainability strategy
Strategic target
ESRS
Strategy Pillar
Implementation
2024
Implementation
2025
Strategic target
2025
Share of sustainable funding
1
[vs. 2021]
E1
Positive
11.6%
14.6%
4.5% » 10%
Strategic target
ESRS
Strategy Pillar
Implementation
2024
Implementation
2025
Strategic target
2025
Share of sustainable assets under
management [vs. 2021]
1
E1
Positive
27.3%
32.1%
5% » 30%
Social engagement of employees
2
S1
Positive
2h 03”
2h 40”
4h
Branches certified as ‘Barrier-free facilities’
[vs. 2021]
S4
Positive
41.5%
41%
18% » 50%
Reduction of CO
2
emissions from operations
[vs. 2019]
E1
Positive
59%
61%
55%
Participation of women on the Bank’s
Management Board [vs. 2021]
ESRS2/G
1
Together
37.5%
37.5%
22% » 30%
Reducing the adjusted pay gap [vs. 2021]
S1
3
Together
3.8%
3.7%
7.3% » <4.0%
Net Promoter Score of employees eNPS [vs.
2021]
S1
Together
27
20
-9 » 20
NPS Retail Banking and Personal Finance
S4
Up
#6
#6
TOP3
4
1 - total sustainable loans and advances/total loans and advances (portfolio measured at amortised cost)
2 - average annual engagement in hours per employee
3 - in ESRS S1, the Bank presented the unadjusted pay gap, in compliance with the ESRS definition
4- NPS benchmark among individual customers of banks in Poland
Under the GObeyond strategy, the Bank delivered on its ambitions related to the share of sustainable financing,
significantly exceeding the strategic target of 10%. At the end of 2025, the share reached 14.6% (up from 4.5% at the end of
2021). The Bank achieved its target for the share of sustainable assets under management, reaching 32.1% compared with
an initial level of 5%. These results reflect the consistent execution of the business strategy, close cooperation with
Customers and a product offering tailored to their needs. In terms of Customer satisfaction (NPS), the Bank ranked 6th at
the end of 2025, placing it in the middle of the market.
BNP Paribas Bank’s sustainability strategy incorporates the Group’s key impacts, risks and opportunities. Its
implementation is embedded in the strategic plan through a dedicated sustainability pillar (POSITIVE). The strategy is built
on strategic pillars designed to accelerate the delivery of the Group’s commitments, including in its own operations:
• The target for reducing greenhouse gas emissions from own operations was achieved: emissions were reduced by 59% in
2024, exceeding the 55% reduction target versus 2019, and reached 61% in 2025.
• The proportion of women on the Bank’s Management Board stood at 37.5% at the end of 2025.
• The adjusted gender pay gap was reduced almost by half, from 7.3% in 2021 to 3.7% in 2025.
• The employee Net Promoter Score (eNPS) reached the target of 20 points (the decline versus 2024 was partly due to the
announcement of changes to the hybrid work model shortly before the survey).
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• The indicator related to social engagement was achieved at 67% of the target, with year-on-year improvement (2h
40min in 2025 vs. 2h 3min in 2024).
• The target for Customer Centres certified as “Barrier-Free Facilities” was achieved at 41.5%, indicating progress,
although below the planned 50%.
Operational processes on sustainability issues require continuous improvement. Key challenges include:
• Obtaining information on the ESG risks to which the Group’s Customers are exposed. In order to understand these risks,
the Bank uses, among others, the ESG Assessment process and the ESG Risk Assessment. The Bank is seeing a gradual
improvement in awareness among Customers of the identified risks.
• Availability and reliability of ESG data – determining ESG targets and calculating ESG indicators is hampered by the
limited availability of ESG data and the variability of calculation methodologies used by Customers. This necessitates the
use of sectoral estimates and indicators, which raises the issue of data representativeness. It limits the accuracy of
measurement and hinders the setting of specific targets including reduction targets. Furthermore, the Omnibus
regulatory package significantly reduced the number of entities required to report under the CSRD, which is likely to
slow down the improvement in available data quality.
Interests and views of stakeholders (SBM-2)
Engagement with stakeholders we have an impact on and who impact our organisation plays a key role in the due diligence
process and in assessing the relevance of our sustainability efforts. We rely on constant and open dialogue with our
stakeholders. This applies both to our day-to-day operations and to the processes involved in identifying and assessing
impacts, opportunities and actual or potential risks. These interactions provide an opportunity to identify stakeholder
expectations and incorporate them into the Group’s operations. This dialogue is also crucial for informing and explaining
our decisions and actions. The Group constantly strives to improve the transparency of its communications with key
stakeholders.
In summary, conducting a constructive dialogue with key stakeholders aims to achieve the following:
• Anticipate business changes and improve our products and services.
• Optimise risk management by listening to internal and external stakeholders and developing a positive dialogue with
them to implement proactive risk management.
• Innovative solutions that have a positive impact on society. We listen to our stakeholders and fulfil our economic, social,
and environmental responsibilities.
Key stakeholders of the Group
In 2025, the Group updated its map of key stakeholders in accordance with the AA1000 SES standard. The process was
carried out during internal workshops involving Bank employees and representatives of subsidiaries who maintain
relationships with specific stakeholder groups as part of business processes.
As part of the assessment, the Bank’s impact on each stakeholder group and the impact of each group on the Bank’s
activities were evaluated on a scale from 1 to 5. Stakeholders for whom both values were equal to or higher than 2.5 were
classified as key stakeholders.
In addition, stakeholders were divided into two categories: stakeholders influenced by the Bank and stakeholders who are
users of sustainability statements. As a result of the mapping exercise, stakeholder groups were identified, as presented in
the diagram above.
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As shown on the stakeholder map, the Group identifies a wide range of stakeholders representing different types and
varying levels of engagement. These include Customers (retail, business and corporate), employees and employee
representatives, shareholders (including the strategic investor), suppliers, rating agencies, regulatory authorities and public
institutions, as well as civil society and its organisations. Some of these stakeholders, with whom the Bank maintains direct
and regular communication, were included in the double materiality assessment described below.
Methods for organising dialogue with stakeholders
The Bank has an organisational structure that enables effective cooperation with stakeholders where actions are based s on
a number of internal policies governing relations with them. For example:
• in relation to Customers – the Policy for protection of Customer interests defines the organisational rules and conduct
standards that the Group must apply at every stage of the Customer relationship and throughout the entire product and
service lifecycle (see the section Consumers and end-users (ESRS S4));
• in relation to suppliers – the sustainable supplier charter sets out the Group’s ethical principles and commitments
towards suppliers, as well as the expectations placed on suppliers.
In addition, each stakeholder group has designated contact persons at the level of specific functions or business segments.
This enables the Group to tailor and develop a variety of channels of dialogue with its stakeholders, the most important of
which are presented below.
Main channels of dialogue by type of stakeholder
Stakeholder group
Contact persons
Channels of dialogue
Customers
Dedicated sales teams
tailored to the profile and
needs of Customers. Experts
provide support to
Customers or specific sectors
(large companies, financial
institutions, SMEs and
mid-caps, entrepreneurs,
associations,
micro-enterprises, etc.).
• Network Promoter System which integrates the Net
Promoter Score, relationship surveys, transaction
surveys
• Handling complaints in each unit of the Group and
through the Customer Ombudsman
Employees
and co-workers
Human Resources
Management Area and
Communication, Marketing
and Social Engagement
Division
• Pulse check
• MiSie
• Intranet
• Mailing
• Regular meetings with the Management Board
Stakeholder group
Contact persons
Channels of dialogue
• Whistleblowing channels
Investors,
rating agencies, analysts
Investor Relations Team
• Quarterly performance presentations
• Investor meetings
• Investor chats
Suppliers and
subcontractors
Procurement Management
Department
• Events dedicated to the Group’s key suppliers covering
sustainable supply chains
• Manuals for suppliers including ESG content
• Satisfaction surveys
Supervisors
and regulators
Management Board and
Organisation Office
• Regular knowledge exchange and compliance with
corporate governance practice
• In addition, each area contacts the relevant authorities
directly
Civic society
and its organisations
Corporate Communication
Department
BNP Paribas Foundation
ESG Strategy and
Stakeholder Relations Office
• Participation in partnerships and associations
• Meetings, discussion platforms, conferences
• DMA dialogue sessions
• Surveys examining the Group’s impacts
Consideration of the effects of stakeholder engagement
Dialogue with stakeholders is at the heart of the Group’s social and environmental responsibility. The interests and
opinions expressed by employees and external stakeholders (investors, non-governmental organisations) make an
important contribution to the process of shaping the Group’s strategy and making management decisions. Employees of the
Group are involved in the strategy development process and co-created the assumptions for the current Accelerate_2030
strategy.
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The Group consistently implements tools that enable regular listening to employees’ voice. The insights gathered are used
to define strategic directions and to improve operational plans. Procedures for dialogue with employees or employee
representatives are described under Own workforce (ESRS S1), section Processes to remediate negative impacts and
channels for own workforce to raise concerns (S1-3). Employees and third parties can use the Bank’s whistleblowing
system (see also ESRS G1, Whistleblowing system).
The Bank engages in dialogue with retail Customers on an ongoing basis. The channels of communication and its frequency
are described in section Processes for engaging with consumers and end-users about impacts (S4-2).
The Bank and its subsidiaries work with their suppliers. Regular business reviews of major suppliers are conducted. In 2025,
we held a meeting as part of the “Procurement Academy” dedicated to key suppliers. The Group also offers them recourse
in case of difficulties [see Business conduct (ESRS G1)].
The opinions and interests of the key stakeholder groups were included in the Group’s double materiality assessment. For
more information, see below: Methodology of impact materiality assessment
Stakeholder interests and opinions – own workforce
Employees are a special category of stakeholders for us, and it is with them that we maintain an ongoing dialogue. The
tools the Group uses to listen to employees include targeted surveys, social dialogue, employee networks and an alert
platform.
We build an attractive and engaging workplace through an open dialogue with employees: Employee Voice. It is based on a
collection of tools and processes that give employees the opportunity to express their opinions and ideas in the workplace
and thus allow them to influence their work environment. The Employee Voice survey serves to increase employee
engagement, improve internal communication, and provide a better understanding of employees’ needs and expectations.
The unit responsible for the Employee Voice survey at the Bank is the Organisational Culture Team, which works closely
with the Internal Communications Team and the Customer Research and Knowledge Team in this regard. The role of the
Team is to listen, analyse and draw conclusions and prepare recommendations from the feedback of employees given,
among others, through surveys, and to take care of the selection and standard of surveys carried out in the organisation.
Pulse Check – periodic engagement survey
For many years, the main tool for gathering employee feedback has been the Pulse Check survey. This year, recognising the
specific situation of persons cooperating with the Bank under B2C contracts, we conducted for the first time a separate
survey tailored to this group, the Contractor Voice survey. Both surveys were carried out in October 2025, and their results
are analysed by managers, the HR Area and the Management Board.
This year’s Pulse Check was the final survey conducted during the implementation of the Bank’s GObeyond strategy. We
can report that the targeted indicators were achieved: the engagement index reached 77% (the strategic target for 2025
was 70%), and the employee Net Promoter Score (eNPS) reached 20 points (the 2025 target was 20).
Table 77. Pulse Check eNPS
eNPS
2025
2024
Question: how likely are you to recommend BNP Paribas Bank S.A. as an
employer to your friends and family?
20
27
Compared to the previous edition of the survey, there were no significant changes in the Bank’s overall results. The highest
rate of positive responses given by employees (96%) remains unchanged as was for the statement about commitment to
work: I fully engage in my work to contribute to the success of the company. Very well rated statements are those about
supervisors: My direct supervisor supports me when I need it (91% of positive responses) and My direct supervisor gives
me enough autonomy so that I can do my job well (94%). The eNPS for the Bank decreased by 7 points from the last edition
to reach a score of 20. This year’s survey coincided with communications announcing an increase in office days to 30% and
a reduction of remote work from home, which caused a drop in eNPS year on year.
The factors contributing most strongly to the overall high level of the indicators are the working atmosphere, development
opportunities, and the culture of collaboration.
The engagement index is the arithmetic mean of two values representing the percentage of respondents who, in the Pulse
Check survey, selected option 4 or 5 (on a scale from 1 to 5) in response to the statements: “Overall, I am satisfied with
working at the Bank” and “I see my future in BNP Paribas Bank.”
We calculate the eNPS based on the answers to the question: How likely are you to recommend BNP Paribas Bank Polska
S.A. as an employer to your friends and family? Everyone answers using an eleven-point scale from 0 to 10. When
answering, it is important to keep in mind how the various choices are interpreted:
• choice of ratings from 0 to 6 – means “I am not satisfied with the pro-employee actions taken by the Bank” (critics
group),
• choice of ratings 7 or 8 – means “I do not have an opinion on this topic and pro-employee actions in the Bank are
neutral to me” (indifferent group),
• choice of ratings from 9 to 10 – means “I rate positively the actions taken for employees in the Bank” (promoters group).
Based on these results, the eNPS is calculated according to the formula: eNPS = % of promoters – % of detractors.
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MiSie platform – feedback exchange
The MiSie feedback platform, launched in 2023, had around 7.5 thousand users at the end of 2025, of whom 97% were
active on the platform.
Nearly half of employees provide feedback and take part in the weekly Friday 6 surveys, in which teams share their views
on engagement and satisfaction. This creates a strong foundation for leaders and teams to jointly improve the working
environment, using indicators such as climate, eNPS, managerial index, equal treatment and inclusion, collaboration, stress
management, well-being, psychological safety and Customer focus. We continue to strengthen a culture of ongoing
feedback through communication and educational initiatives. This year’s activities included training sessions delivered by
Feedback Ambassadors entitled “Feedback – discover the path to meaningful relationships!”, Appreciation Day, the
publication of inspiring interviews with leaders sharing good practices in working with feedback, and the promotion of using
the platform to gather feedback when preparing for the annual performance review process.
Social dialogue
Social dialogue is essential in order to develop open and transparent communication between managers, employees, and
employee representatives. There are trade unions at the Bank, representing and defending the professional and social
rights and interests of all employees, both under collective and individual labour law. Trade union organisations bring
together employees, persons in non-employee employment relationships (contractors, self-employed) and retirees of the
Bank.
All employees of the Bank, excluding members of the Management Board, employees seconded to work abroad, persons
working at the Bank on the basis of secondment from other entities of the BNP Paribas Group, persons employed at the
Bank under managerial contracts are covered by the provisions of the Company Collective Bargaining Agreement, which is
an agreement concluded between the employer and trade unions representing employees. Its content defines the
conditions of employment and remuneration. The provisions of the Company Collective Bargaining Agreement, being the
result of joint arrangements with the social partners, contain more favourable provisions than those adopted by the
generally applicable labour laws.
Trade union organisations cooperate with the employer in the field of employment policy and wage formation. The basic
principle of cooperation with trade unions is partnership. The cooperation between the Bank as an employer and the trade
unions is carried out through dialogue, acting in good faith, respecting the competence and legitimate interests of the
parties to the dialogue.
Employee networks
In order to strengthen an inclusive organisational culture, the Bank fosters the creation and supports the activities of
grassroots employee networks that support groups at risk of discrimination and exclusion in various thematic areas such as
gender equality, disability, neurodiversity, LGBT+, multiculturalism, age, parenting, etc. The activities of employee networks
aim to promote respect, equal opportunities and strengthen a culture of openness and inclusion. The networks’ activities
focus on building awareness, education, breaking down stereotypes and prejudices. Employee networks are a source of
support, personal and professional development, strengthening commitment and a sense of belonging. For the Bank, they
are a partner, a consultant, a co-creator of solutions that build an inclusive organisation, as well as the availability of
products and services. In 2025, six employee networks were active: Dad, you’ve got it made, Agave Age, BNP Paribas Women
of Change, BNP Paribas Pride Poland, Means I Can, Neuronauts.
Alerts reported by employees
Group employees have the right to report in good faith threats to the general public interest or violations of standards,
laws, internal procedures, including the Group Code of Conduct. For more information, see Processes for engaging with own
workforce and workers representatives about impacts (S1-2)
Informing administrative, management and supervisory bodies
The management and supervisory bodies are regularly informed of stakeholder views and expectations on sustainability
matters through the Chief Sustainability Officer and other units maintaining relationships with stakeholders. Sustainability
matters raised by investors, the Group’s Customers and non-governmental organisations are analysed on an ongoing basis,
and the relevant units of the Group provide appropriate information in response to incoming enquiries.
Managing impacts, risks and opportunities
Activities of the Group’s Customers may generate both positive and negative ESG impacts, risks and opportunities. In order
to mitigate actual negative impacts and risks and monitor potential negative impacts and risks, the Group employs a
comprehensive system for identifying them in the Group’s operations, covering environmental, social and governance
aspects. This system makes it possible to combine the knowledge and assessment of each Customer’s ESG performance
through the existing Know Your Customer (KYC) and ESG Assessment (ESG Assessment) processes, and to identify material
impacts, risks and opportunities, in particular through the risk assessment processes in the Risk ID tool described in this
chapter under Financial materiality assessment methodology – the risk dimension, stakeholder consultation and
monitoring of strategic objectives and targets.
The system is integrated operationally, particularly through credit policies and sector policies that incorporate ESG criteria.
In this way, the overall system ensures that ESG factors are considered in credit and investment committee meetings. The
complete system is shown in the diagram below:
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ESG risk analysis system in Group operations in 2025
Description of the process to identify and assess material impacts, risks and opportunities (IRO-1)
The Group used the system outlined above to conduct a Double Materiality Assessment (DMA) and identify material
impacts, risks and opportunities (IRO) related to the Group’s operations and business. For this purpose, the Group used a
number of criteria and thresholds described below.
The DMA process was conducted in accordance with an internally developed methodology. We reviewed the activities,
business relationships and context resulting from a comparative analysis of the banking market in which we operate.
We mapped the GObeyond Strategy to the specific disclosure requirements identified in the ESRS. We also took into account
the current regulatory environment, industry analysis of the banking sector, and priorities of the European Securities and
Markets Authority (ESMA).
Structure of the double materiality assessment
We conducted a double materiality assessment by following four steps to cover ESRS topics defined in the regulations:
• Understand and define:
− the Group’s value chain, in particular by taking records of the Group’s key business processes, broken down into
those carrying out the Group’s core business activities and management and organisational processes, in order to
gain a structured understanding of the Group’s operations including its own operations and within its business
relationships with upstream and downstream entities, and
− ESRS sub-topics relevant to the Group, which led to the addition of two entity-specific topics to the Group’s
activities: “Cybersecurity” and „Market Integrity and Financial Security”, which were identified in the context of
risks.
• Identify on the two sub-perimeters of the value chain:
− actors within our value chain to define key stakeholder groups,
− definition of impacts, risks and opportunities by ESG/ESRS sub-topics.
• Assess the materiality of impacts, risks and opportunities for each sub-topic on a scale of one to five (from “1-minimal”
to “5-critical”) in the identified sub-perimeters of the value chain in the short, medium and long time horizon.
• Determine the materiality threshold for impacts, risks and opportunities; when the rating is 3-medium and above on at
least one of the three dimensions (of impacts, risks and opportunities), then the sub-topic is considered material.
The methodology for double materiality assessment is the same for all ESRS topics/ sub-topics, without distinction.
Methodology of impact materiality assessment
The methodology for identifying and assessing actual and potential impacts was based this year on information obtained
from an analysis of our documents and an analysis of answers from our key stakeholders, consolidated and classified
according to ESRS sub-topics, for all Group activities. The impact assessment was done in four steps:
• Development of an initial, broad list of impacts based on a banking sector benchmark, mapped to individual ESRS
sub-topics. Each impact was assessed in terms of whether it is positive or negative, actual or potential, and whether it is
relevant to the Group. We determined which part of the value chain it relates to, as well as its severity, scope and
likelihood of occurrence, and for negative impacts, the level of irreversibility of the Bank’s impact on the environment and
society.
• A multi-stage assessment of impacts depending on their type, carried out through:
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surveys: six different surveys tailored to Group employees, Customers, suppliers, social organisations, environmental
organisations, and a mixed group consisting of industry organisations, analysts, BNP Group companies operating in
Poland and the media;
external stakeholder panel: in August 2025, representatives of key stakeholder groups were invited to an online
dialogue session conducted in accordance with the stakeholder engagement standard AA1000 SES. Participants
represented the following stakeholder groups: rating agencies and sell-side analysts, suppliers and business partners,
experts, minority investors, Customers, consumer and industry organisations, supervisory and regulatory authorities,
society and environmental groups;
expert workshops: dedicated to specific disclosure requirements under individual ESRS;
document analysis: complaints, exit interviews and available internal studies.
At each stage, where possible, severity, scope, likelihood and irreversibility of impacts were assessed. Each assessment was
carried out on a scale from 1 to 5.
• Determination of impact materiality by calculating weighted averages of the individual assessment stages on a scale of
1–5, where 3–5 indicated a material impact. We adopted the assumption that if at least one impact assigned to a
sustainability sub-topic was assessed as material, the entire topic to which the sub-topic belongs is considered material
from an impact perspective.
• The analysis conducted by internal experts was based on an expert review of the results of previous assessments and
verification of the outcomes from the perspective of the entire organisation. Experts made the final determination of
whether the identified impacts were not, in fact, mitigation measures for other negative impacts or the result of
regulatory obligations and confirmed that the impacts presented were gross impacts (before the Group’s remediation
actions, in line with EBA recommendations).
It should be noted that during the assessment of impacts, it was not possible to determine their time horizons with a
sufficient level of certainty. In most cases, a conservative approach was applied, classifying the majority of identified
impacts as actual and current, falling within the short- or medium-term horizon. This year, a methodological change was
made in the impact materiality assessment: positive impacts were considered where the Group could differentiate them
from financial opportunities and where they reflect positive external impact on society and/or the environment.
As a result of in-depth expert discussions and verification of whether all analysed impacts represent actual impacts of the
Group rather than, for example, mitigation measures or compliance with legal requirements, the impact scores for the
following sub-topics were lowered:
• climate-change adaptation;
• relationships with end-users (customer satisfaction, transparent and relevant information, complaints management,
human rights, social inclusion) – this did not affect the materiality of the topic from an impact perspective;
• cybersecurity, market transparency and financial security, which were assessed as more relevant in the context of risks
(i.e., the external environment’s impact on the organisation) rather than the organisation’s impact on society.
Financial materiality assessment methodology – the risk dimension
The materiality assessment methodology we use is based on the results of annual risk identification process, which aims to
identify and assess all risks in the Group’s operations. This is done as part of a formalised, comprehensive and forward-
looking process, using the Risk ID tool. Representatives of the organisational units responsible for measuring a given risk
(e.g. operational risk, business risk, reputational risk) participate in the identification of risks. To the best of their
knowledge, they identify risks within their areas of responsibility that can be assessed as material and that could
jeopardise the achievement of the Group’s mission and goals. The goal of this process is to provide information on changes
in the internal and external environment and their impact on the activities of the Group. In conducting the analysis of the
external environment, the Group considers among others factors related to infrastructure, economic conditions, risks,
political changes, the legal environment, the natural environment, suppliers and service providers, Customers and
competitors. Risks are assessed conservatively but the prevention and mitigation techniques relevant to operations or
transactions, without which such operations or transactions could not exist, are considered in the risk assessment stage,
including materiality assessment in the risk identification process.
To identify risks related to ESG factors, risk owners use a set of documents and analyses concerning ESG issues, including:
• a review of major global risks – a panorama of global risks for financial institutions. The review is based on an analysis of
external studies and publications (both public and private) and aims to identify key economic, technological, commercial,
socio-political and environmental trends, material risks and major transitions that may pose short-, medium- or
long-term threats to financial institutions. A wide range of ESG issues is analysed as part of this review (climate change,
natural environment, social issues);
• a set of ESG studies, analyses and tools prepared by Group experts:
quarterly ESG risk analysis and assessment;
assessment of the potential impact of physical risk on Customers and on residential and commercial real estate;
a sensitivity map of industrial sectors to transition risk and the effects of climate change (with or without considering
insurance and public support schemes);
a sector classification map based on direct negative environmental impacts;
information on climate- and nature-related regulatory requirements.
The materials listed above support the identification and updating of the most likely scenarios triggered or exacerbated by
ESG risk factors. Based on this information and their own expertise, participants in the Risk ID process representing various
areas in the organisation, including ESG risk management experts, must assess the extent to which ESG risk factors may
lead to risk materialisation. For this purpose, process participants identify:
1. “risk events” based on the Group’s risk taxonomy, such as business risk, reputational risk, credit risk, market risk,
operational risk, etc., on which ESG factors may have a material impact;
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2. “risk factors” that contribute to, trigger or exacerbate the risk event, including ESG factors, must be selected in
accordance with the Group’s risk taxonomy;
3. “risk assessment” should include, among other elements, an evaluation of the severity and likelihood of the risk event in
order to assess its materiality (expected potential loss).
Based on these elements, for each ESG area:
• the expected potential losses associated with risk factors material to that area are identified;
• they are compared with the Group’s materiality threshold. The materiality threshold is set annually as part of the risk
identification. The following rule applies: if the materiality of a risk factor and its associated risk event exceeds the
threshold, the area is considered material;
• the area is classified on a scale from 1–Minimal to 5–Critical:
material levels: 3–Material, 4–Significant, 5–Critical;
non-material levels: 1–Minimal, 2–Informational.
Additionally:
• For short-, medium- and long-term horizons considered in the materiality assessment, Risk ID participants must
evaluate, for each ESG-related risk event:
the current materiality of the risk event, based on its severity and likelihood (likelihood results from the combination
of frequency and inevitability), as well as its expected evolution over the next three years (short-term horizon);
the relative likelihood and severity of the risk event if it were to materialise within 10 years (medium-term horizon);
the relative likelihood and severity of the risk event if it were to materialise within 30 years (long-term horizon).
• In the assessment of climate risk, participants in the Risk ID process may rely on the results of climate stress tests;
details of the approach are described in the section Scenario analysis at the Bank.
To assess the impact of physical and transition risks in the risk identification (Risk ID) process, the Group uses, among other
things, the results of climate stress tests.
The materiality threshold is set annually as part of risk identification in ICAAP (Internal Capital Adequacy Assessment
Process).
The key climate assumptions used in the Group’s financial statements are consistent with climate scenarios over a 20-year
horizon presented in section Scenario analysis at the Bank.
The materiality assessment used in this statement is based on the methodology and results of risk identification for 2025.
The key climate assumptions applied in the Group’s financial statements (with respect to cost of risk) are based on the
same scenarios as used in the stress tests, which form the foundation of the Risk ID for credit risk.
Opportunities assessment
The GObeyond strategy, running until the end of 2025, identified development opportunities for our Group. To be consistent
with operational processes, the methodology for identifying opportunities in the double materiality process was based on
defined strategic targets, as in 2024, including sustainability targets.
The opportunities assessment methodology was based on the following:
• Step 1: Identify a strategic commitment monitored through a performance indicator (strategic KPIs) linked to an ESG sub-
topics;
• Step 2: Analyse nominal expected additional business income and cost savings associated with the Group’s own
operations.
According to the methodology, the quantification of opportunities corresponded to the horizon of the GOBeyond strategy, i.e.
the materiality of opportunities was assessed in the short term in 2025.
The opportunity identification and assessment methodology applies to all ESRS topics and is not specific to climate change.
Governance and internal control
The individual parts of the impact, risk and opportunity assessment are carried out respectively by the ESG Strategy and
External Stakeholder Relations Office, the Risk Processes and Reporting Department, and the Investor Relations and ESG
Reporting Office. The results are then consolidated and presented for approval to the Bank’s Management Board and for
information to the Audit Committee.
The assessment of impacts, risks and opportunities is based on existing operational processes within the integrated
governance and internal control system:
• The risk inventory is subject to three levels of validation and controls by the second line of defence.
• The targets related to the implementation of the strategic plan are covered by the same control system as other
information reported by the Group, including the three lines of defence described in the chapter: Corporate Governance,
section Internal control system (including control and risk management system for the preparation of financial reports),
and earlier in the section General Disclosures (ESRS 2), under Risk management and internal controls over sustainability
reporting (GOV-5).
• These mechanisms ensure that the DMA process complies with ESRS requirements, particularly with respect to reliability,
completeness and appropriate documentation of the processes for identifying and assessing material impacts, risks and
opportunities.
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Summary of the double materiality assessment (DMA)
The Group’s approach to assessing materiality includes all identified areas of impact on sustainability. We consider a given
topic/sub-topic to be material when:
• the Group’s impact on the topic is considered material by key stakeholders (at least 3-medium);
• risks generated by the topic (i) directly to the Group or (ii) indirectly through its financial activities, are above a certain
annualised expected loss threshold;
• opportunities related to the topic are linked to the Group’s strategic targets, for which financial quantification was
possible of the opportunity or cost reduction, exceeding the same materiality threshold as applied to risks.
In 2025, the Group carried out a review and update of the DMA process in accordance with ESRS requirements. As part of
the review, an analysis was conducted of the Group’s business model and strategy, external factors, as well as a market
benchmark. The analyses did not identify any changes in the material topics in terms of impact or financial materiality
compared with the previous year. The list of ESRS-aligned material topics remained unchanged year on year. The double
materiality assessment process, including the identification, evaluation and validation of material impacts, risks and
opportunities (IRO), is subject to annual review. Its results may change in subsequent reporting periods, particularly due to
updates to the Bank’s strategy, changes in the regulatory environment, or developments in market practice. The
sustainability topics/sub-topics and their corresponding impacts, risks and opportunities assessed as material are
presented in the following section (see also Table 78).
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Material impacts, risks and opportunities and their interaction with strategy and business model (SBM-3)
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Table 78. Detailed list of impacts, potential risks and material opportunities (IROs) for the Group by ESRS sub-topic
Topic
Sub-topic
Value chain
Category
IRO
IRO description
Potential /
actual
Time horizon
Climate change
(ESRS E1)
1
Climate change
adaptation
Business activities
Risks
Credit risk arising from physical risk
Credit risk arising from the physical risks associated with the intensification of extreme
weather events (droughts, heat waves, floods, etc.) and the resulting transition risks.
Potential/actual
Medium/long
N Operational risk arising from
environmental risk
Refers to environmental risks (caused by acts of nature or human activity) directly affecting the
security of the Group, employees and Customers.
Potential/actual
Short/medium
Climate change
mitigation and energy
consumption
Business activities
Negative
impacts
Customers greenhouse gas emissions
The Group has an indirect impact on the climate by financing Customers that emit greenhouse
gases.
Potential/actual
Short
Positive
impacts
Financing low-carbon investments
Positive impact on carbon dioxide emissions through low-carbon investments financed by the
Group.
Actual
Short
Risks
Business risk, credit risk, liquidity and
financing risk arising from transition risks
Credit risk arising from stranded assets or decline in activity in certain sectors exposed to
transition risk.
Potential/actual
Short/medium/long
Reputational risk
Reputational risks associated with accusations of greenwashing and funding of sectors with high
greenhouse gas emissions.
Potential
Short/medium/long
Opportunities
Financing the low-carbon transition
Opportunity related to offering sustainable products and services that promote Customers’
transition to a low-carbon economy.
Actual
Short
Own operations
Opportunities
Reduction of direct greenhouse gas
emissions
Reducing the carbon footprint of the Group’s own operations can lead to lowering the costs,
improving the Group’s image and increasing employee awareness.
Actual
Short
Own workforce
(ESRS S1)
2
Employment in the
Group
Own operations
Positive
impacts
N Creating a friendly work environment,
inclusion and diversity
Promoting an environment based on respect and equity, steady improvement of working
conditions and enhancement of employee welfare.
Actual
Short/medium
N Ensuring employee development through
access to training and upskilling
programmes
Increasing social capital, employee competences and position in the job market through a broad
range of training and professional development opportunities for employees.
Actual
Short/medium
Negative
impacts
Discrimination, violence and mobbing in
the workplace
Sporadic incidents of discrimination, violence and harassment at work.
Potential
Short/medium
Risks
Psychosocial risks
Operational risks related to business continuity: psychosocial risks (burnout and job abandonment)
for employees related to recent changes in working methods and environment.
Potential
Short
HR legal risks
Legal risks: disputes related to discrimination (including mobbing), employment contracts (breach
of contract, resignation) and employer’s obligations towards employees (e.g. unequal treatment).
Potential
Medium/long
Protection of
Customers’ interests,
Business activities
Negative
impacts
Financial difficulties due to lack of
information
Impact on retail Customers at risk of financial difficulties, particularly where information about
financial products or services is not clear, transparent and may be misleading.
Potential
Short/medium/long
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Topic
Sub-topic
Value chain
Category
IRO
IRO description
Potential /
actual
Time horizon
Consumers and
end-users (ESRS
S4)
3
clear, transparent
and not misleading
information
Risks
Legal and reputational risks relating to lack
of information and complaints from
Customers
Risks related to the protection of retail Customers’ interests, such as the risk of sanctions, fines
from regulators and legal proceedings initiated by Customers; reputational risks related to the
actions of third parties (Customers, NGOs, etc.).
Potential
Medium/long
Social inclusion
Business activities
Positive
impacts
Social inclusion
Non-discrimination in access to products and services by introducing facilities for, among others,
seniors and people with disabilities and by adjusting and developing applications and digital tools
for Customers experiencing any kind of difficulty.
Actual
Short
Customer satisfaction
Business activities
Negative
impacts
Customer dissatisfaction
Dissatisfaction of retail Customers due to lack of or limited access to a product or service affecting
their personal projects and plans.
Potential/actual
Short/medium/long
Risks
Legal risks associated with Swiss franc
(CHF) mortgage loans
Legal risks related to pending litigation involving CHF denominated or foreign currency mortgage
loans, taking into account the current status of judgments in cases against the Bank and the line of
case law.
Potential/actual
Short/medium/long
Data protection
Business activities
Negative
impacts
Impact related to legal and reputational
risks resulting from loss or theft of
confidential data
Avoiding data leakage
Legal and reputational risks arising from breaches of data protection legislation (e.g. breach of the
GDPR) and/or loss or theft of confidential Customer information.
Potential/actual
Short/medium/long
Business conduct
(ESRS G1)
Business conduct
(including
whistleblower
protection)
Business activities
Negative
impacts
Impact related to legal and reputational
risks associated with corruption or
influence peddling
Reputational, legal or financial risk for the Group if it is involved in acts of corruption or influence
peddling, directly or indirectly, actively or passively.
Potential/actual
Short/medium/long
Corporate culture
Own operations
Positive
impacts
Impact related to employees’ adherence to
values and ethical principles
Declared values of the organisation, mission statement, Code of Conduct.
Actual
Short
Group specific
topics
Market integrity
and financial security
Business activities
Risks
Legal risk of not identifying suspicious
Customer activity
Legal risk if the Group fails to identify, monitor and report suspicious Customer activity. The Group
may be held criminally and administratively liable, as well as exposed to incurring significant
remedial costs, if it fails to detect and report criminal activities such as money laundering.
Potential/actual
Short/medium/long
Cybersecurity
Own operations
Risks
Operational risks generated by cyber
attacks
Operational threats to continuity and resilience: system disruption due to cyber attacks.
Potential
Short/medium/long
Legal risks arising from cyber attacks
Legal risks caused by loss or theft of confidential data as a result of cyber attacks
Potential
Short/medium/long
Reputational risks generated by cyber
attacks
Reputational risk related to the Group’s ability to counter cyber attacks.
Potential
Short/medium/long
1. Employment in the Group is understood as employees hired under employment contracts, as well as those in a relationship with the Group under other forms of cooperation (contracts for services or civil law agreements). N new IRO in relation to 2024.
Reducing negative impacts in terms of ESG factors is possible through, among others, the following described above:
assessment of ESG risks in the process of selecting counterparties, sector policies, a list of monitored and excluded
companies, and KYC tools.
In the process of identifying risks, the impact of ESG factors on credit risk, operational risk, business risk, liquidity and
financing risk was recognised. Since ESG factors are not yet comprehensively included in the quantitative measurement
framework for credit risk, a decision was made to separate ESG risk as a hard-to-measure risk category until ESG factors
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are included in credit parameters. As a result of the above, the Bank has incorporated ESG risk into its internal risk
management framework by including ESG risk as a subtype of credit risk in its Risk Management Strategy and risk appetite.
In order to mitigate and control the risk, the principles for measuring ESG risk in the Bank’s internal capital adequacy
assessment process (ICAAP) were also developed. The capital plan for 2022-2025 was supplemented with limits for ESG
risk determined based on the risk measurement made. ESG Risk Management Principles were also developed, which
include, among others, provisions for risk monitoring and reporting, and stress testing.
ESG risk emphasises traditional risks, which may impact the Group’s financial performance. The Group’s ESG risk
management and stress testing system is integrated into the overall risk management system, which is described in detail
in the chapter Risk and opportunities, section: Risk management system.
In order to mitigate negative impacts and potential and actual risks and to develop its opportunities, the Bank has
implemented policies, broken down into specific actions, outlined in individual topical standards (ESRS): Climate Change
(ESRS E1), Own Workforce (ESRS S1) Consumers and End-Users (ESRS S4), Business Conduct (ESRS G1).
Current financial effect
Thanks to the financial quantification of risks and opportunities, we assessed which risks and opportunities impacted the
Group’s situation in the current reporting period. For risks, taking into account the estimated severity and the likelihood of
materialisation allowed us to identify key events that may have a material impact on the Group’s financial position in the
next and subsequent reporting periods.
In 2025, the Group carried out climate stress tests, which are a key tool in financial risk management, enabling the
assessment of the Group’s resilience to potential shocks resulting from climate change. A broader description is provided in
ESRS E1 under Description of the resilience of the strategy and business model.
Disclosures in relation to specific circumstances (BP-2)
The existence of specific circumstances can change the content of sustainability information. This could be a deviation from
the time horizons originally specified in the regulation, but also the use of value chain estimates or sources of uncertainty
related to these estimates. The following table provides information on those parts of the statement that help understand
these specific circumstances.
Table 79. Parts of the Sustainability Statement affected by specific circumstances: time horizons, estimates and sources
of uncertainty
Paragraph
Disclosure requirement BP-
2
Related information
Sustainability
Statement
sections
Time horizons
9 a
Definitions of medium- or
long-term time horizons
Climate stress tests
Material
impacts, risks
and
opportunities
and their
interaction with
strategy and
business model
(ESRS 2 SBM-3)
9 b
Disclosures of the reasons
why the application of
these definitions of the
time horizon is different
Financial materiality assessment: the risk dimension
Financial
materiality
assessment
methodology –
the risk
dimension
Value chain
estimates
10 a
Disclosure of the indicators
used, which include
upstream and downstream
value chain data that are
estimated using indirect
sources such as sector
averages or other proxies
Scope 3 category 15
(financed greenhouse gas emissions)
Scope 3 category 6
(business travel)
In line with the PCAF guidelines Part A, the Bank
used activity and economic data to estimate
greenhouse gas emissions associated with its
lending and investment activities, relying as far as
Gross Scopes 1,
2, 3 and Total
GHG emissions
(E1-6)
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Paragraph
Disclosure requirement BP-
2
Related information
Sustainability
Statement
sections
10 b
Description of the basis for
the preparation of value
chain metrics estimated
using indirect sources
possible on data from primary sources and
recognised secondary sources.
When Customer data reported by the company
(primary data) are not available on the reporting
date, data from the previous year are used as the
basis for estimates. The use of secondary data
sources, such as emission factors and industry
averages, results in less accurate information than
relying solely on primary sources. The accuracy of
the resulting financed emissions calculations is
reflected in the average PCAF data quality score,
which is calculated and disclosed for each sector.
The Bank invests in data collection systems,
cooperates with Customers to obtain more actual
data, and participates in industry initiatives aimed at
improving financed emissions calculation
methodologies, which may enhance the quality of
emissions reporting in the future.
10 c
Description of the level of
accuracy resulting from
indicators including value
chain data estimated using
indirect sources
10 d
If applicable, a description
of planned actions to
improve the accuracy of
indicators, which include
value chain data estimated
using indirect sources
Sources of
uncertainty in
estimates and
results
from 11a
Publication of quantitative
indicators and monetary
amounts that are subject to
a high level of
measurement uncertainty
Description of the resilience of the strategy and
business model
Scope 3 category 15
(financed greenhouse gas emissions)
- the estimation methods are consistent with
common industry practice. It is recognised that
reliance on external data sources, in particular the
availability of high-quality emissions data for
Description of
the resilience of
the strategy and
business model
Gross Scopes 1,
2, 3 and Total
GHG emissions
(E1-6)
Paragraph
Disclosure requirement BP-
2
Related information
Sustainability
Statement
sections
11 b (i)
Disclosure of information
on sources of measurement
uncertainty
counterparties and the resulting indicators, is
inherently subject to measurement uncertainty as
most counterparty emissions data are reported with
a one-year delay or are generalised estimates rather
than precise, counterparty specific values.
Scope 3 category 6
(business travel)
11 b (ii)
Publication of assumptions,
approximations and
evaluations used for
measurement
Information on value chain estimates and sources of uncertainty in estimates and results is disclosed with each ESRS topic
area. Where data were not available, an estimation method was used, in each case described with the specific disclosure.
The GHG emissions data presented in the Sustainability Statement relate to the Group and the upstream and downstream
value chain. The process for calculating the organisation’s carbon footprint is described in section ESRS E1-6. The method
for estimating Scope 3 category 15 emissions (investments) and calculating Scope 3 category 6 emissions (business travel)
is described in Table 88. Reported Scope 3 category 15 emissions exclude, among others, emissions from government bonds
and Scope 3 customers.
The taxonomic disclosure process used data from third-party providers.
Given the broad loan portfolio and the difficulty in obtaining data from the Group’s Customers and other business partners,
quantitative data may involve a risk of measurement uncertainty. Documentation of data sources and estimation
methodologies, as well as any disclaimers regarding the uncertainty of the results presented, are presented with due
diligence. We have attempted to describe as accurately as possible the facts of the Group’s sustainability activities to date.
For the purpose of the risk analysis presented in this Sustainability Statement, including climate risks, the following time
horizons were used:
• short-term – less than a year,
• medium-term – from one to three years,
• long-term – from three to 30 years.
According to the time horizons used in the risk identification process, the Group identifies opportunities only in the short
term.
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As in 2024, the topics covered by ESRS E1, S1, S4, G1 have been identified as material as a result of materiality assessment
and are reported herein. In addition, the Group has identified two specific topics: financial integrity and security and
cybersecurity. These are material in view of the analysis of risks for the previous year and may impact the Group’s financial
results.
This report is the second Sustainability Statement of the BNP Paribas Bank Polska S.A. Group fully prepared on the basis of
the ESRS. Due to the evolving reporting practice, we updated parts of our methodologies, for example by expanding the
analysis of our Group’s impacts. We also took into account proposed regulatory changes and recommendations issued by
supervisory authorities. We did not identify any errors in the presentation of last year’s data. All changes in data
presentation compared with 2024 have been described within the respective disclosures to which they relate.
The Sustainability Statement includes:
• the disclosures required by Article 8 of the Taxonomy Regulation (2020/852) and its implementing acts. The disclosures
are part of ESRS E1: this year, the detailed taxonomy tables are presented in Annex 2 for better transparency;
• calculations of greenhouse gas emissions in Scope 3 category 15 presented on the basis of the PCAF (Partnership Carbon
Accounting Financials) Part A guidelines (information included in the section Gross Scopes 1, 2, 3 and Total GHG
emissions (E1-6)).
To improve the transparency of the sustainability statement, the Bank has incorporated certain information by referring to
other sections of the Management Board Activity Report or to other documents. The table below lists the disclosure
requirements that are incorporated by reference:
Table 80. Disclosures incorporated by reference
ESRS
Disclosure requirement (DR)
Data point
Related information
Sustainability
Statement section
2
GOV-1
21
Information on the composition and diversity of the
administrative, management and supervisory bodies
Statutory bodies
of the Bank
Diversity of the
administrative
management and
supervisory
bodies
2
IRO-2
56
List of disclosure requirements complied with in the
preparation of the sustainability statement and a table
of all data points originating from other EU regulations
Appendix 1
ESRS
Disclosure requirement (DR)
Data point
Related information
Sustainability
Statement section
G1
GOV-1
40 b
Expertise of
the administrative, management and supervisory
bodies on business conduct matters
Statutory bodies
of the Bank
E1
E1-6
53-55
Gross GHG emissions intensity
Financial results
of the Group
Table 24, 25,
26, 27
E1
Disclosure under Article 8 of
Regulation 2020/852
(Commission Delegated
Regulation (EU) 2026/73
Appendix 2
Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement (IRO-2)
See Annex 1
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Climate change (ESRS E1)
Corporate governance
Integration of sustainability-related performance in incentive schemes (ESRS 2 GOV-3)
Climate issues are not directly included in the remuneration of members of the management and supervisory bodies.
Information on the integration of sustainability topics in the remuneration of members of these bodies is further described
in General Disclosures (ESRS 2),Integration of sustainability-related performance in incentive schemes (GOV-3)
Strategy
Transition plan for climate change mitigation (E1-1)
Transition plan in the Bank
In 2026, the Bank developed a Prudential Transition Plan based on the requirements of the EBA Guidelines EBA/GL/2025/01
on ESG risk management. In the context of the ESRS E1 requirements, the Bank did not prepare its own transformation
plan, however the Bank is fully committed to achieving the BNP Paribas Group’s objectives, by taking specific actions within
its scope of impact. Therefore, it will among other things aim to achieve the targets related to the highest-emission sectors
under the commitments aligned with the Paris Agreement, which the BNP Paribas Group has set for 2030. In addition, the
Bank, like all entities operating within the BNP Paribas Group, is taking a number of measures to support its own Customers
in their transition and to reduce its carbon footprint.
The elements of the BNP Paribas Group’s transition plan related to climate change mitigation apply exclusively to the
financial assets on the Group’s banking balance sheet. While the strategy, identified risks and policies cover all areas of the
Group’s activities, certain actions, targets and metrics are specific to financial operations. The indirect transition targets
relate in particular to financing provided to non-financial corporates. The BNP Paribas Group does not set an absolute
greenhouse gas reduction target. Instead, it has established interim targets for reducing emission intensity in its credit
portfolio in the sectors with the highest greenhouse gas emissions, with milestones set for 2030. The Group currently
considers that its approach based on medium-term, sector-specific portfolio decarbonisation targets is consistent with its
previous commitments and represents the most effective response to the challenges of decarbonisation. The Group has
also set targets for reducing greenhouse-gas emissions from its own operations (Scopes 1, 2 and Scope 3 business-travel
emissions), which can be achieved through improvements in building energy efficiency and sustainable mobility.
The Bank’s efforts to mitigate climate change
The Bank’s main lever as a financial institution is to use its position to support the sustainable transition of businesses. This
is its key environmental commitment. To this end, the Bank consistently expands its range of products, services and other
solutions that help Customers carry out their own transition and develop their sustainable investments.
These actions at the Bank consist of:
• Integrating climate considerations into its own operations and, in particular, into its analysis of Customers in the credit
process, investment decision-making, reporting and risk management;
• Limiting support for activities with the greatest negative impact on the climate and credit exposure to greenhouse gas-
intensive activities, primarily through dedicated financing and investment policies;
• Increasing support for low-carbon energy. The Bank participates in the financing of energy transition projects and
companies particularly involved in this field, and also offers its Customers appropriate financial products and services:
sustainability-linked loans (SLL), reduced-interest mortgages for more energy-efficient properties or the purchase of less
polluting vehicles, etc.;
• Conducting a systematic ESG assessment of its Customers with a turnover exceeding 50 million euros. With corporate
Customers and financial institutions in mind, the Bank has developed the ESG Assessment process. It provides a more
harmonised, systematic, comprehensive and formalised review of ESG factors across the Customer’s entire activity,
including within the credit process, from loan origination to monitoring and reporting. Initially, the ESG Assessment
applied only to large companies, but in 2024 it was extended to medium-sized companies with turnover above EUR 50
million as well as to financial institutions. The ESG Assessment covers five ESG dimensions, including climate and
environment, and provides an overview of the Customer’s ESG profile, complemented by a controversy analysis to ensure
a comprehensive evaluation. Qualitative data for the ESG Assessment (including information for the controversy analysis)
are provided by Business and verified by the Risk Department as part of the credit risk control function, enabling a
balanced assessment of performance. The ESG Assessment supports decision-making in credit processes by
strengthening and documenting due diligence regarding Customer’s sustainability commitments. The Bank also conducts
an ESG risk assessment process.
The goal at the level of the BNP Paribas Group is that by 2030, low-carbon energies, primarily renewables, represent at
least 90% of the Group’s financed energy mix. In addition to exiting the thermal coal sector, almost completed by the end of
2025, the BNP Paribas Group no longer provides any financing since 2023 to new oil or gas field development The Group
will reduce its outstanding loans for oil exploration and production by 80% and 30% respectively by 2030 compared to
September 2022.
The Bank continues to advance its systemic approach to decarbonisation, including the development of solutions that
support this process. The sectors listed below have the greatest impact on emissions in the credit portfolio and require
targeted investment support:
• energy,
• food processing and agriculture,
• transport, shipping and logistics,
• manufacturing (wood processing, chemicals, rubber and plastics, non-metallic products, metal production, metal
products).
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Customers generating the highest greenhouse gas emissions were identified in the portfolio, along with the key
decarbonisation levers relevant to these Customers. Tools and systemic solutions have been developed to support effective
transition in the identified sectors.
Based on these analyses, the Bank has initiated commercial activities and is preparing a comprehensive product offering
that covers not only Customers but also their suppliers. In the area of cooperation with corporate Customers, the Bank
promotes climate mitigation initiatives in several variants, depending on the segment and profile of the enterprise. Large
entities can benefit from Sustainability-Linked Loans, which allow Customers to set a CO₂ reduction pathway as one of
several ESG targets in exchange for a reduced margin. A similar solution is the Decarbonisation Loan (currently in pilot
phase), where the loan margin is partially linked to the borrower’s CO₂ reduction trajectory. Smaller enterprises may use
the Green Loan, supported by non-repayable EU grants. To obtain financing under this scheme, Customers must present
energy efficiency investment plans that meet the grant eligibility criteria. Within this offering, a project in the agro-food
sector has been launched in partnership with Klim GmbH: nine of the Bank’s corporate Customers have begun Scope 3
decarbonisation projects by implementing regenerative agriculture practices among their suppliers. In addition to financing,
the Bank provides access to national and EU support instruments. Combining banking products with these instruments
helps Customers implement decarbonisation measures, reduce costs, lower energy consumption, cut emissions and
strengthen their competitive advantage.
In supporting the transition of the national energy sector towards renewable energy sources, the Bank relies on the
development of highly specialised teams and competences. In addition to dedicated experts in structured financing of
long-term energy projects, the Bank has developed strong sector expertise. This enables continuous monitoring of
developments in the energy sector, new projects and investors, and allows the Bank to respond to Customers’ specific
needs. At the same time, the Bank leverages the experience and expertise of the BNP Paribas Group’s investment banking
division in financing large-scale energy projects. These efforts translate into a growing share of the Bank’s financing of
large-scale photovoltaic, wind and biogas projects.
Material impacts, risks and opportunities and their interaction with strategy and business model
(ESRS 2 SBM-3)
Material climate-related impacts, risks and opportunities for the Group
As part of its double materiality assessment, as described in section Description of the process to identify and assess
material impacts, risks and opportunities (IRO-1) under General Disclosures (ESRS 2) part, the Bank identified a number of
climate-related material impacts, risks and opportunities (IROs).
Material impacts related to climate change mitigation and linked to the Bank’s business activities:
• Positive impact on CO2 emission reductions through financing low-carbon investments by the Group.
• Indirect negative climate impacts through the financing of Customers that emit greenhouse gases.
Material risks related to adaptation to climate change and linked to the Bank’s business activities:
• Credit risk and operational risk arising from an increase in extreme, acute and chronic weather events (droughts, heat
waves, floods, etc.).
Material climate change mitigation risks linked to the Bank’s business activities:
• Credit risk, business risk, liquidity and financing risk arising from stranded assets and/or the Group’s climate
commitments which may lead to exit from or declining activity in certain sectors exposed to transition risks.
• Reputational risks related among others to accusations of greenwashing and financing of sectors with high GHG
emissions.
Material opportunities related to climate change mitigation and linked to the Bank’s commercial activities:
• Opportunity related to providing sustainable products and services that promote Customers’ transition to a low-carbon
economy.
Material opportunities related to climate change mitigation and linked to the Bank’s own operations:
• A reduction in the carbon footprint of the Group’s own operations can lead to cost reductions, an improvement of the
Group’s image and increased employee awareness.
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Summary of links between material IROs, policies, actions, metrics and targets
Table 81. Links between IROs, policies, actions, metrics and targets in the Group
Category
Material IROs
Policy
Actions
Metrics and targets
Positive impact
Financing low-carbon investments
• GObeyond Strategy
• Accelerate 2030 Strategy (from 2026)
• Credit policy
• ESG policy towards the oil and gas
• ESG policy towards the mining sector
• ESG policy towards the coal power sector
• ESG policy towards the nuclear energy sector
• ESG policy towards the agro-food sector
• ESG policy towards the forestry sector – palm oil
• ESG policy towards the forestry sector – wood pulp
• Supporting Customers in the transition to a
low-carbon economy
• Share of sustainable financing amounting
to 10%
Opportunity
Financing the low-carbon transition
Negative impact
Greenhouse gas emissions of Customers
• Implementation of ESG risk assessment and
its use in the KYC / credit process
• Managing operational risk and reputational
risk
Risks
Credit risk arising from physical risk
Credit risks arising from transition risks
Reputational risk
Operational risks arising from environmental risks
Liquidity and financing risks arising from transition risks
Business risks arising from transition risks
Opportunity
Reduction of direct greenhouse gas emissions
• Energy management of buildings
• Business Travel Policy
• Initiatives to decarbonise own operations
• Direct greenhouse gas emissions in the
Group Target for 2025: reduction in CO2
emissions from operations – 55% and
reduction in energy consumption – 35%
The Bank recognises that environmental risks can materialise through:
• physical risks related to environmental degradation, e.g. air, water and soil pollution, deforestation (these phenomena
can lead, for example, to damage to infrastructure, destruction of crops, reduced productivity or indirectly lead to
consequences such as disruptions in the supply chain), as well as climate change, including the occurrence of:
extreme weather events such as storms, floods, fires and heatwaves, which can damage production facilities and
disrupt supply chains,
long-term climate change, which can lead to, among other things, rising temperatures, changing rainfall patterns and
types of precipitation, rising sea levels, limited water availability, loss of biodiversity and changes in soil productivity,
• transition risk arising from the need to adapt the economy to gradual climate change, in particular the use of low-carbon
and more environmentally sustainable solutions. This risk may materialise, among other things, through:
regulatory risk (changes in climate and environmental policy, e.g. as a result of energy efficiency requirements, carbon
pricing mechanisms that increase the price of fossil fuels, or policies that encourage the sustainable use of
environmental resources),
technological risk (a less harmful technology for the climate or the environment replaces a more harmful one, making
it obsolete),
changes in market sentiment and social norms (changes in consumer and investor choices, difficulties in maintaining
relationships with Customers, employees, business partners and investors due to the reputation of a company that has
a negative impact on the climate and the environment).
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Description of the resilience of the strategy and business model
The Bank’s Internal Capital Adequacy Assessment Process (ICAAP)
Within the framework of the principles of risk identification and assessment developed by the Bank, a separate group of
risks related to environmental, social and governance factors was defined. In the risk identification process, the material
impact of ESG factors was recognised. As a result of the above, the Bank has incorporated ESG risks into its internal risk
management framework. In order to mitigate and control the risks, principles for measuring ESG risks in the Bank’s Internal
Capital Adequacy Assessment Process (ICAAP) have been developed. The capital plan for 2026-2028 was supplemented with
limits for ESG risk set based on the risk measurement performed. ESG Risk Management Principles have also been
developed, which include among others provisions for risk monitoring and reporting and stress testing.
Scenario analysis at the Bank
The Bank conducts climate stress tests. The most recent tests were conducted in 2025. The test methodology is based on
the stress test approach proposed by the European Central Bank. The analysis takes into account those physical and
transition risks that are material from the perspective of the Bank’s current situation. The Bank assumes that the short-
term perspective is a period of up to 1 year, the medium-term perspective is 1–5 years, and the long-term perspective is
longer than 5 years.
The Bank’s approach to the tests is presented below:
Type of risk
Scenario
Horizon
Risk factors
Risk transmission
channel
Physical risk
Droughts and
heatwaves
1 year
• Temperature
increase by 2
o
C
• Impact on financial
metrics, a change in
which leads to a
reassessment of the
Customer’s rating
1 year
• Temperature
increase by 3
o
C
Floods
1 year
• River flood
• Coastal flood
• Impact on financial
metrics, a change in
which leads to a
reassessment of the
Customer’s rating
• Change in the value
of collateral
Transition risk
Orderly transition
Long-term
i.e. 20 years (in five-
year intervals)
• Changes in CO
2
emission allowance
prices
• Impact on financial
metrics, changes in
which lead to a
Disorderly transition
Hot house world
• GDP
• Paths of CO
2
emission reduction
according to
scenarios
reassessment of the
Customer’s rating
• Stimulation of the
balance sheet
structure in the long
term
Short-term
3 years
The purpose of the tests is to assess the Bank’s resilience to various climate change scenarios – both transition risks (e.g.,
more restrictive climate policies) and physical risks (such as increased frequency of floods and droughts). The results
indicate which portfolios are most exposed to losses arising from economic transition or climate change. The assessment of
the reliability and availability of data for conducting the tests was also crucial for the Bank. The test results indicate that a
lack of action on the part of Customers in terms of transition risk management can have a material impact on the level of
risk, including the occurrence of credit losses. In terms of physical risk, flooding is a key risk factor for the Bank.
The Bank carries out an analysis of individual economic sectors in terms of their transition potential. The table below
presents the credit exposure under the Polish Classification of Activities (PKD) section, together with a breakdown of the
likelihood of energy transition failure/delay. The result is presented on a colour scale from green to red, where green
represents the lowest probability and red the highest probability of energy transition failure/delay.
The probability of a delayed/unsuccessful transition is estimated on the basis of:
• the emission intensity of a given economic sector (according to PKD codes),
• the rate of energy transition adopted in the climate scenarios,
• the impact of individual scenarios on the financial performance of companies, obtained from the Bank’s climate stress
tests.
The calculations are carried out at the level of PKD classes and then aggregated to the section level as a weighted average,
where the credit exposure in each class is used as weights.
The Network for Greening the Financial System (NGFS) climate scenarios were used in the analysis, i.e.:
• Orderly transition scenario (‘net zero 2050’) – the scenario assumes that climate neutrality is achieved by 2050 and
global warming is limited to less than 2°C. This is possible through the implementation of appropriate climate policies as
early as 2020 and their consistent implementation in the following years. Early action on decarbonisation leads to a
reduction of both physical and transition risks;
• Disorderly transition scenario (‘delayed transition’) – the implementation of relevant climate policies only takes place
after 2030. Achieving climate neutrality by mid-century is still possible, but requires intensified decarbonisation efforts,
faster action and thus higher transition costs;
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• Current policies scenario – assumes that no climate policies are implemented beyond those already in place. Global
emissions continue to rise, leading to a warming of more than 3°C by the end of this century. The risk of transition in this
scenario is low, but it leads to the materialisation of physical risks.
In the context of the analysis below, the scenarios presented are considered over a 20-year horizon.
Table 82. Analysis of selected economic sectors in terms of their transition potential
PKD section
Balance
sheet
exposure of
the Group as
of
31.12.2025
(PLN million)
Likelihood of failure/delay of energy transition
Net zero 2050
Disorderly
transition
Current
policies
Agriculture, forestry and fishing
9,171.5
Mining and quarrying
49.0
Manufacturing
12,786.7
Electricity, gas, steam, hot water and air
conditioning manufacturing and supply
1,395.0
Water supply; sewerage, waste management and
remediation activities
123.2
Construction
2,403.4
Wholesale and retail trade
7,660.2
Transportation and storage
2,704.1
Accommodation and food service activities
316.4
Publishing, broadcasting and content production and
distribution activities
3,079.8
Telecommunication, computer programming,
consulting, computing infrastructure and other
information service activities
6,934.9
Financial and insurance activities
6,250.2
Real estate activities
2,630.9
Professional, scientific and technical activities
2,514.3
Public administration and defence; compulsory social
security
304.6
Education
1,119.0
PKD section
Balance
sheet
exposure of
the Group as
of
31.12.2025
(PLN million)
Likelihood of failure/delay of energy transition
Net zero 2050
Disorderly
transition
Current
policies
Human health and social work activities
31.4
Arts, entertainment and recreation activities
96.7
Other service activities
0.0
Activities of households as employers and
undifferentiated goods- and service-producing
activities of households for own use
0.0
Resilience of the Bank’s business model
The Bank conducts an analysis of the resilience of its business model, recognising that it is essential to demonstrate how
the strategy and business model can withstand and adapt to the materialisation of climate risks: both physical risks (e.g.,
extreme weather events) and transition risks (e.g., regulatory, technological and market changes linked to the energy
transition). The Bank applies a comprehensive approach that integrates risk assessment with strategic and financial
planning. Resilience is tested in the context of the Bank’s ability to deliver its financial plan under various, potentially
adverse, climate scenarios.
Climate stress tests are the key tool used by the Bank to assess and demonstrate the resilience of its business model.
These tests make it possible to quantify potential financial losses over the short-, medium- and long-term horizon. The
purpose of the process is to understand how shocks arising from physical and transition risks may impact the Bank’s
portfolio, revenue generation and ability to execute its long-term strategy.
A detailed description of the scenarios applied by the Bank is provided above in the section Scenario analysis at the Bank.
The tests include an assessment of the impact of climate risks on the Bank’s main financial risk categories, i.e. credit risk,
operational risk, and liquidity and funding risk. Integrating the test results into the budgeting process and strategic capital
planning (ICAAP/ILAAP) is a key demonstration that the Bank actively manages climate risk and verifies the resilience of its
business model. The results are directly used in the Bank’s budgeting process, including by:
• providing quantitative estimates of additional credit losses under climate scenarios, which may be reflected in the risk
appetite and key risk indicators;
• alerting to the need to maintain additional capital buffers to cover identified climate risks, influencing strategic decisions
on capital allocation;
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• identifying resilience gaps, leading to budgeting for adaptation investments (e.g., IT infrastructure upgrades, branch
protection) and transition investments (e.g., development of sustainable finance products).
In 2025, the Bank continued scenario analysis to stress-test the resilience of its business model under different
temperature rise pathways and economic transition trajectories. The analysis focuses primarily on credit risk, where the
most material risks have been identified (physical and transition risks). For physical risks, the Bank considers flood risk
(affecting property-secured loans) and drought risk, which significantly impacts the Agro sector. All other types of physical
risk are currently assessed as immaterial for the Bank’s credit portfolio. For transition risk, the Bank applies a
comprehensive approach, meaning that no material risks are excluded from the analysis. Immaterial risks are monitored
but not included in sensitivity analysis. Simulation results indicate that the materialisation of physical and transition risks
may affect selected products and portfolio segments. However, the overall expected impact on the Bank’s risk profile and
financial stability remains limited. This is due to the Bank’s balance-sheet structure: maintaining high sectoral
diversification and avoiding excessive concentration in high-emission industries, which naturally mitigates potential shocks.
The projected financial effects remain within the risk appetite approved by the Supervisory Board, ensuring the Group’s
financial stability. The sector diversified portfolio and proactive risk management practices, including sector policies
restricting financing, effectively mitigate potential negative impacts of the transition.
Within the Internal Capital Adequacy Assessment Process (ICAAP), these tests serve as a tool for:
• verifying the strategy: confirming that the business strategy is resilient to the materialisation of climate risks over the
strategic horizon;
• quantifying risk: translating qualitative climate risks into measurable capital impacts;
• setting targets: defining key risk indicators and capital targets that account for potential climate shocks.
The long-term resilience of the Bank’s business model is built on two pillars:
• risk mitigation: including consistent application of sector policies (such as exclusion of financing for certain industries),
monitoring of key risk indicators and ESG risk assessment in the credit process;
• active financing of Customers’ energy transition, which systematically reduces the portfolio’s sensitivity to transition
risks; assets identified as exposed to material physical risk are subject to enhanced monitoring and dialogue with
Customers on climate mitigation actions.
Through risk identification, measurement, limits and capital allocation, the Bank safeguards its position to cover potential
losses arising from potential materialisation of climate risks. The Bank assesses Customer risk in the credit process and,
through sector policies and controversy analysis, introduces restrictions in its core business to avoid material exposures to
sectors and companies most affected by climate change. It also promotes sustainable practices among Customers (e.g.,
through the Agronomist platform and cooperation with Klim GmbH). By combining risk-mitigation actions with strategic
financing of climate mitigation initiatives, the Bank protects its financial performance while strengthening the long-term
resilience of its business model.
The resilience of the Bank’s business model to climate risks is demonstrated through the systematic integration of climate
scenario analysis into strategic risk management and the budgeting process. The Bank uses stress tests to quantify the
potential financial impacts of physical and transition risks and then integrates these results into planning, capital
allocation and investment decisions. This approach ensures that the Bank is prepared for the transition to a low-carbon
economy while maintaining financial and operational stability.
The Bank views responsibility for addressing climate change as one of the key business opportunities identified in the DMA
process. A material opportunity lies in offering sustainable products and services that support Customers in transitioning to
a low-carbon economy, directly delivered through the development of products such as Sustainability-Linked Loans and
financing for renewable energy and energy efficiency. The Bank’s approach assumes that Customer transition is a driver of
the Bank’s growth, enabling the alignment of business objectives with environmental responsibility. Additionally, the Bank
identifies an opportunity in reducing emissions from the Group’s own operations, which leads to lower operating costs.
Managing the Bank’s exposure to climate risks is integrated into its business model. The previous GObeyond strategy and
the Bank’s risk management framework directly addresses the material risks identified in the DMA: credit risk arising from
intensifying extreme weather events (physical risk) and transition risks, including stranded asset risk in high-carbon
sectors. Through the systematic withdrawal from coal financing and the implementation of ESG assessment in the credit
process, the Bank also mitigates material reputational risk that could arise from accusations of greenwashing or financing
emissions.
It should also be noted that resilience analysis is subject to uncertainty. Future climate developments (frequency and
severity of weather events), the pace of technological progress and the dynamics of legislative change may differ from
current model assumptions. The evolution of consumer behaviour and financial markets may accelerate or delay the
materialisation of risks in ways that are difficult to estimate precisely today.
Managing impacts, risks and opportunities
Description of the processes to identify and assess material impacts, risks and opportunities (ESRS2 IRO-1)
The Group has identified the sources of greenhouse gas emissions in its own activities and since 2019 measures and
publishes theme in its annual reports. Starting from 2024, it also measures the greenhouse gas emissions in its loan
portfolio. For more information, see: Targets related to climate change mitigation and adaptation (E1-4) and Gross Scopes
1, 2, 3 and Total GHG emissions (E1-6).
The climate stress tests conducted by the Bank in 2025 aimed to identify potential vulnerabilities to transition-related
climate risks, both in the short term in the event of a disorderly transition and in the long term.
Description of processes and assessment of climate-related risks
As part of the risk assessment to comply with the European Banking Authority (EBA) requirements for originating and
monitoring loans, the Bank developed ESG assessment questionnaires in 2021, which were implemented in the credit
process. Through these questionnaires, the Group verifies whether Customers are aware of the risks associated with the
materialisation of ESG risks and take precautionary measures. Among other things, this assessment aims to identify the
negative impact of physical and transition risks on activities of Customers in the Corporate and SME segments. In addition,
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as part of the ESG assessment, the Bank verifies whether Borrowers have implemented or plan to implement solutions to
protect their business from the negative effects of climate change, including:
• use of electricity from renewable energy sources, implementation of a plan to reduce greenhouse gas emissions,
• implementing a plan to reduce water and electricity consumption or diversify into renewable energy,
• taking measures to reduce the impact of climate change on business activities.
The Bank’s approach to ESG risk analysis focuses on assessing two perspectives:
• impact materiality, i.e. the impact of business activities on the environment,
• financial materiality, i.e. the impact of the environment on business activities.
Based on the data collected in the credit process, the level of ESG risk of the Bank’s Customers in the Corporate and SME
segments, including climate risk, is examined when new financing is granted, increased or the Customer is reviewed. After
aggregating the results, according to the data as at the end of 2025, the exposure-weighted average score of the loan
portfolio subject to analysis achieved a low level. Drought, heat waves and the impact of heavy precipitation (rain, snow,
hail, ice) dominate among the physical risk factors most frequently indicated by Customers. 38% of Customers declare
sensitivity to any type of physical risk. For the Micro-enterprise segment, the ESG analysis is carried out without the
involvement of Customers and is based on the Bank’s internal model. The model assesses sensitivity to ESG risk factors,
including transition risk and key physical risks (i.e., flooding, drought and rising temperatures). It also examines Customers’
dependence on the natural environment as well as the extent to which micro-entrepreneurs impact it.
Based on the aggregated model results, 38% of Micro segment Customers were identified as having a medium level of ESG
risk, and 18% a high level. A particularly significant risk factor is exposure to drought, which is linked to the substantial
share of agricultural loans in this segment (58% of credit exposure).
According to the Risk Management Strategy, ESG risk is the risk of losses resulting from the current or future negative
impact of environmental, social or governance factors on the Group’s counterparties or invested assets. This includes
environmental risk, which is the risk arising from exposure to counterparties that may be adversely affected by
environmental factors, including factors arising from climate-related changes and factors related to environmental
degradation.
The Group’s climate risk management process is set out in the ESG Risk Management Principles. The Principles synthesise
the actions taken in the area of ESG management, in the context of the impact on the Bank’s credit risk and internal
capital. By defining its risk appetite, the Bank limits its exposures to Customers with high ESG risk. The designated risk
appetite aims to determine the level of risk that the Bank is prepared to accept in pursuit of its strategic objectives and
financial plans. The level of ESG risk should be assessed as low.
In order to manage risks related to climate change, the Bank has incorporated into its loan origination and monitoring
process an assessment of the impact of long-term climate-related changes and extreme weather events on Borrowers’
activities, in line with a systematisation divided into:
1. Long-term climate-related changes:
• impact of higher temperatures (air, freshwater, seawater),
• impact of thermal shocks, impact of changing wind patterns,
• impact of changing precipitation patterns and types (rain, hail, snow),
• impact of sea level rise,
• impact of water stress (limited access to fresh water),
• impact of soil and coastal erosion/degradation.
2. Extreme weather events:
• impact of heat/cold waves, droughts/floods, fires, storms, tornadoes heavy precipitation, landslides, etc.
The above categories were ranked according to the materiality of these risks, estimated on the basis of Customers’
responses obtained in the ESG questionnaires. In addition, special attention was paid to the risks that are regionally most
specific to Poland, i.e. droughts, heat and floods. These categories were included in the climate stress tests conducted at
the Bank in 2025.
The breakdown of these risks was implemented on 30 June 2021, with the entry into force of the EBA/GL/2020/06
Guidelines of 29 May 2020 on loan origination and monitoring. In determining the types of risks, the Bank followed the
guidelines set out in the EBA Report on the Management and Supervision of ESG Risks for Credit Institutions and Investment
Firms (EBA/REP/2021/18), as well as the types of risks indicated in the Commission Implementing Regulation (EU)
2022/2453 of 30 November 2022 as regards the disclosure of environmental, social and governance risks.
As part of the risk assessment, the Bank’s Customers’ vulnerability to transition risks (transition towards a climate-neutral
economy) is also analysed. The Bank pays particular attention to the financing of sectors deemed sensitive in terms of ESG
risk (including climate risk) and limits its participation in industries widely regarded as particularly damaging and
unsustainable.
The Bank's exposure to high-emission sectors as of 31.12.2025 amounted to PLN 2.8 billion and increased year-on-year by
PLN 0.3 billion. The Bank defines high-emission sectors using the list of industries set out in Commission Implementing
Regulation (EU) 2024/3172 of 29 November 2024 laying down implementing technical standards for the application of
Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to public disclosures by
institutions of the information referred to in Part Eight, Titles II and III, of that Regulation, and repealing Commission
Implementing Regulation (EU) 2021/637. The list of high-emission sectors is presented in the table below, and exposures
are assigned to these sectors based on the companies’ primary PKD codes. In previous years, the Bank also included
agriculture among high-emission sectors. However, since the above Regulation does not cover this industry, the list has
been aligned with regulatory standards, which effectively resulted in the exclusion of agriculture.
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Table 83. Percentage of high-emission sectors in the Group’s loan portfolio as at 31 December 2025 (for non-financial
corporates)
Sector
2025
2024
car
0.6%
0.8%
aviation
0.0%
0.0%
cement
0.1%
0.2%
coal
0.0%
0.0%
oil and gas
0.1%
0.1%
energy
1.4%
0.9%
ships and water transport
0.1%
0.1%
steel manufacturing and processing
0.8%
0.9%
Total
3.2%
3.0%
Policies related to climate change mitigation and adaptation (E1-2)
Policies related to the Group’s financing and investment activities
The Group has established a range of principles which govern its activities and business relationships. The Bank’s financing
and investment activities are governed by sectoral policies in relation to sensitive sectors
(https://www.bnpparibas.pl/csr/strategia-csr/gospodarka). Seven of these are directly related to climate change:
• ESG policy towards the coal power sector,
• ESG policy towards the oil and gas sector,
• ESG policy towards the mining sector,
• ESG policy towards the nuclear sector,
• ESG policy towards the agro-food sector,
• ESG policy towards the forestry sector – palm oil,
• ESG policy towards the forestry sector – wood pulp.
By limiting the Bank’s exposure to high-carbon sectors, these policies also limit transition risks.
These policies, consistent with the BNP Paribas Group, are continuously inspired by its interaction with its stakeholders,
including investors, NGOs, etc., and through best practice of international or sectoral bodies.
Policies regarding the Group’s own activities
The Group’s approach with regard to its direct impact on climate is one of continuous improvement and includes:
• adjusting energy consumption to reduce demand for energy,
• energy efficiency (more efficient production, transport and use of energy),
• use of energy from renewable sources.
The Group has defined policies relating, among others, to energy management in buildings and business travel, which
contribute to reducing the carbon footprint of its operations.
At the Bank, two documents are in place which govern environmental and climate approaches:
• Integrated Environmental and Energy Management System,
• BNP Paribas Bank’s Environmental and Energy Declaration.
The Bank also has a business travel management policy, in which it recommends to apply best practice for reducing CO
2
emissions, which contributes to reducing the impact of its activities.
The Bank has adopted a CSR Declaration for Suppliers, which is available to all suppliers. It is intended to ensure that the
requirements and principles set out in it, in particular with regard to the environment, are observed by subcontractors.
Similar documents are also in place in the other companies of the Group.
Table 84. Summary of the Bank’s main policies for managing impacts, risks and opportunities related to climate change
Policies
Description of the content of the policy
Description of the scope of the policy or its
exclusions
Description of the highest
level of the organisation
responsible for
implementing the policy
Interaction with stakeholders
ESG policy towards and the oil
and gas sector
The document sets out the commitments made by the Group in its
business relationships with companies in the oil and gas sector. It
refers in particular to challenges of mitigating the effect of climate
This Policy applies to all BNP Paribas
entities and covers all financial products
and services provided by BNP Paribas
Management Board of the
Bank
Publication on the Bank’s website. A copy of the policy is regularly
distributed to actual and potential customers in the KYC process or when
discussing any financial service offered.
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Policies
Description of the content of the policy
Description of the scope of the policy or its
exclusions
Description of the highest
level of the organisation
responsible for
implementing the policy
Interaction with stakeholders
change and sets out the framework for financing arrangements, defines
the criteria for granting financing and identifies sector exclusions.
ESG policy towards the mining
sector
The document sets out the commitments made by the Group in its
business relationships with companies in the mining sector. It refers in
particular to challenges of mitigating the effect of climate change and
sets out the timeline for exiting the financing of thermal coal.
This Policy applies to all entities of the BNP
Paribas Group and covers all financial
products and services provided by the
Group
Management Board of the
Bank
Publication on the Bank’s website. A copy of the policy is regularly
distributed to actual and potential customers in the KYC process or when
discussing any financial service offered.
ESG policy towards the coal
power sector
The document sets out the commitments made by the Group in relation
to the financing of companies in the coal-fired power generation sector.
In particular, it sets out the timetable for a complete exit from thermal
coal financing.
This Policy applies to all entities of the BNP
Paribas Group and covers all financial
products and services provided by the
Group
Management Board of the
Bank
Publication on the Bank’s website. A copy of the policy is regularly
distributed to actual and potential customers in the KYC process or when
discussing any financial service offered.
ESG policy towards the nuclear
sector
The document sets out the commitments made by the Group in relation
to the financing of companies in the nuclear power generation sector. It
refers in particular to challenges of mitigating the effect of climate
change and sets out the principles and evaluation criteria relating to
the financing of nuclear power plant projects and in connection with
financial services for companies in this sector.
This Policy applies to all entities of the BNP
Paribas Group and covers all financial
products and services provided by the
Group
Management Board of the
Bank
Publication on the Bank’s website. A copy of the policy is regularly
distributed to actual and potential customers in the KYC process or when
discussing any financial service offered.
ESG policy towards the agro-food
sector
The document sets out the commitments made by the Group in relation
to the financing of companies in the agricultural sector. It refers in
particular to challenges of mitigating the effect of climate change and
It sets out the criteria for financing projects in the sector, but also the
requirements for companies in the sector with which the Group may
come into contact.
This Policy applies to all entities of the BNP
Paribas Group and covers all financial
products and services provided by the
Group
Management Board of the
Bank
Publication on the Bank’s website. A copy of the policy is regularly
distributed to actual and potential customers in the KYC process or when
discussing any financial service offered.
ESG policy towards the forestry
sector – palm oil
The document sets out the commitments made by the Group in relation
to financial services and asset management for the palm oil sector. It
refers in particular to challenges of mitigating the effect of climate
change and It sets out the criteria for financing projects in the sector,
but also the requirements for companies in the sector with which the
Group may come into contact.
This Policy applies to all entities of the BNP
Paribas Group and covers all financial
products and services provided by the
Group
Management Board of the
Bank
Publication on the Bank’s website. A copy of the policy is regularly
distributed to actual and potential customers in the KYC process or when
discussing any financial service offered.
ESG policy towards the forestry
sector –wood pulp
The document sets out the commitments made by the Group in relation
to the financing of companies in the wood pulp sector. It refers in
particular to challenges of mitigating the effect of climate change and
It sets out the criteria for financing projects in the sector, but also the
requirements for companies in the sector with which the Group may
come into contact.
This Policy applies to all entities of the BNP
Paribas Group and covers all financial
products and services provided by the
Group
Management Board of the
Bank
Publication on the Bank’s website. A copy of the policy is regularly
distributed to actual and potential customers in the KYC process or when
discussing any financial service offered.
CSR Declaration for Suppliers
The document describes the mutual ESG commitments made by the
Group and its suppliers.
The declaration applies to the activities of
the Bank. Appropriate regulations have
Vice-President of the Bank
The declaration is provided to each supplier during the supplier
assessment process. Publication on the Bank’s website
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Policies
Description of the content of the policy
Description of the scope of the policy or its
exclusions
Description of the highest
level of the organisation
responsible for
implementing the policy
Interaction with stakeholders
The declaration summarises the suppliers’ commitments, such as:
compliance with ethical principles, working and safety conditions,
regulations on the employment of young people, the fight against
forced labour, discrimination and environmental protection. It refers in
particular to challenges of mitigating the effect of climate change.
been implemented in the Bank’s companies
in accordance with the principle of
proportionality
ESG/CSR Declaration of Partners
(Agents, Contractors, Vendors) on
responsible cooperation
The declaration summarises the commitments of partners, such as:
compliance with ethical principles, working and safety conditions,
regulations on the employment of young people, the fight against
forced labour, principles of discrimination and environmental
protection. It refers in particular to challenges of mitigating the effect
of climate change.
The declaration concerns the activities of
the Bank
Executive Director of
Sustainability Area
The declaration is communicated to each partner before signing the
contract. Publication on the Bank’s website
Policy on integrated
environmental and energy
management at BNP Paribas
Bank Polska S.A.
The objective of the policy is to minimise the negative environmental
impact resulting from the Bank’s operations through responsible
environmental management and optimisation of energy consumption
(electricity, heat, gas, fuels) and water consumption. The Bank wants to
manage its environmental impact in a systematic way, implementing a
long-term strategy of continuous improvement and reduction of
negative environmental impacts.
The declaration concerns the activities of
the Bank
Managing Director of the
Bank’s Internal Services
Division
Internal document
BNP Paribas Environmental and
Energy Policy
The declaration describes the Bank’s activities in the environmental
area: managing the environment and energy, supporting Customers in
the transition to a low-carbon economy, reducing the negative impact
of operations on the environment and the energy consumed, raising
awareness for the environment. It also takes into account the Bank’s
environmental commitments. It refers in particular to challenges of
mitigating the effect of climate change, in particular by seeking energy
efficiency of buildings.
The declaration concerns the Bank’s
activities
Managing Director of the
Bank’s Internal Services
Division
Publication on the Bank’s website
BNP Paribas Polska – Business
Travel Policy
This document describes the principles to be followed by employees in
managing their business travel, in particular by encouraging them to
reduce their environmental impact. It refers in particular to challenges
of mitigating the effect of climate change related to business travel.
This policy is applicable to the activities of
the Bank
Managing Director of the
Bank’s Internal Services
Division
Internal document
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These policies limit the Bank’s physical or transition risks while minimising its impact on the most carbon-intensive
activities, projects and sectors. They indirectly allow financing and investments to be targeted towards opportunities that
arise from actions and projects aligned with the Paris Agreement.
Actions and resources in relation to climate change policies (E1-3)
The Bank measures the effectiveness of its activities in reducing the GHG emissions of its contractors and in its own
operations:
• Bank assesses ESG risks [see Material impacts, risks and opportunities and their interaction with strategy and business
model (SBM-3) under: General Disclosures (ESRS 2)], thereby improving knowledge of Customer and their impact on
climate change. It allows for a better understanding of the Bank’s risks and more effective support to Customers in their
transition.
• The Bank supports its Customers in the transition to a low-carbon economy through a range of sustainable products and
services, as outlined in section Implementation strategy GObeyond, Pillar POSITIVE.
• Since 2024, the Bank monitors the emission intensity of loan portfolios in high-carbon sectors.
• The Bank implements solutions to reduce greenhouse gas emissions from its own activities.
Actions related to the management of climate impacts and climate risk
The Group, through its activities for Customers and projects supporting a low-carbon economy, contributes to the energy
transition. The application of sectoral policies is complemented by lists of monitored and excluded companies, depending
on the degree of non-compliance with the policies. Companies on the list of monitored companies are subject to the Bank’s
actions to implement sustainable changes in their practices and to reduce the level of ESG risks, with a particular focus on
climate change issues. For excluded companies, the Group prohibits the Bank from entering into financial or investment
cooperation.
Assessing Customers’ climate effectiveness
The ESG risk assessment is used by the Bank to obtain a comprehensive view of a Customer’s activities. It provides insights
into how Customers approach ESG aspects, including their performance in climate transition and exposure to physical risks.
It supports the analysis that enables the Group to direct financing towards Customers and projects aligned with the
decarbonisation trajectory. The Bank carries out ESG risk assessments of Customers, taking into account climate risks. In
2025, 9,557 ESG risk assessments were carried out and 232 Customers operating in sensitive sectors were analysed on the
basis of sector policies.
In 2024, the ESG Assessment process was extended to include corporate Customers with an annual turnover of more than
EUR 50 million, operating in industries with high risks related to the transition to a low-carbon economy or high social
risks. In 2025, a total of 127 Customers were analysed under this process. The ESG Assessment process is also used to
better understand our Customers’ sustainability transition and their strategies in relation to climate change.
In 2025, the scope of the ESG assessment was further expanded to include corporate Customers with annual turnover
above EUR 50 million who are applying for financing for the first time or increasing their credit exposure by more than EUR
15 million.
Supporting Customers in decarbonisation
In 2025, the Bank continued its decarbonisation efforts. The focus was placed on action and implementation of the
identified decarbonisation levers for individual sectors, with particular emphasis on the agro-food sector. The Bank is
already supporting companies in decarbonisation through profiled tools. One of these is Envirly’s carbon footprint
estimation platform. In partnership with Envirly, the Bank enables companies to use a certified tool that allows them to
estimate the carbon footprint of their operations according to current standards. The Bank has also taken steps to expand
its support for Customers in financing sustainable transition including loans linked to decarbonisation targets.
To support the decarbonisation of Customers’ supply chains, primarily in the agro-food sector, the Bank has started
working with Klim GmbH. The company uses a unique methodology based on soil analysis and satellite imagery, ensuring
full transparency and regulatory compliance. Thanks to the regenerative agriculture practices implemented by Klim GmbH
in cooperation with the Bank, food producers and distributors can reduce greenhouse gas emissions in their supply chains
(Scope 3) by up to 20-30%. Regenerative practices help to reduce CO
2
emissions, which contributes to the achievement of
Scope 3 targets (indirect emissions) in sustainability strategies. Regenerative agriculture contributes to capturing carbon
dioxide from the atmosphere, improve soil fertility and protect biodiversity. This leads to more resilient ecosystems and
crops. It also increases soil water retention, which reduces erosion and the need for irrigation. In the long term,
regenerative agriculture reduces production costs, increases yields and opens up new sources of income for agricultural
producers.
Collaborating with Klim GmbH enables farmers to generate carbon credits in the value chain (insetting) by reducing
emissions and capturing carbon. The credits are purchased by the buyers of the raw materials produced by the farmers,
providing farmers with an additional source of income. Food producers who engage in sustainable regenerative agriculture
can promote their business. They contribute to the global fight against greenhouse gases emissions and can use this
advantage when talking to investors and business partners. Klim GmbH also offers tools to count, monitor and verify the
impact of regenerative agriculture practices on emissions.
The Bank is committed to developing its products and services for the transition of agricultural production towards
sustainability. Agriculture is key to addressing environmental challenges (e.g. carbon emissions, biodiversity loss, water
use, deforestation) and social challenges. It is highly vulnerable to climate change and a key lever for solutions (sustainable
agroecological practices, renewable energy, soil C0
2
capture). The Bank is committed to developing the skills of its teams,
as well as products and services to support the transition to sustainable agriculture. A centre of expertise for the agro-food
sector ‘BNP Paribas International Food & Agri’ has been created at the Bank to support the other entities in the BNP Paribas
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Group. This centre has developed and launched the Agronomist.pl platform, which offers, among other things, a toolkit to
facilitate the agroecological transition of agro-food producers and companies, best practices and an innovative solution
related to reducing the environmental impact of the agro-food sector. This knowledge is shared across the BNP Paribas
Group within the Sustainable Agriculture community, which brings together all the teams responsible for agriculture in
European markets.
The main decarbonisation levers prioritised in the Bank’s financing within this sector are:
• healthy soil as a key to the transition to a sustainable agricultural model,
• support for the development of the agro-photovoltaic and on-farm photovoltaic market,
• support for the development of the biogas/biomethane and fermentation chambers market.
Membership of industry organisations and sustainability partnerships
The Bank interacts with the business community and actively participates in environmental footprint mitigation initiatives.
For this purpose, the Bank enters into strategic partnerships:
• Partnership with the European Investment Bank (EIB) supporting energy efficiency projects,
• Membership of the Polish Sustainable Investment Forum (PSIK), which advocates for green initiatives and sustainable
financing,
• UN Global Compact, including the Climate Positive programme, which supports climate action and the UN Sustainable
Development Goals,
• The Responsible Business Forum, which promotes social responsibility and supports sustainable development,
• Partnership with the UNEP/GRID Centre Warsaw, supporting environmental action and the Sustainable Development
Goals. In partnership with leading organisations in the agro-food sector, the Bank carries out projects focused on
managing, protecting and restoring biodiversity,
• Partnership with POHiD – Modern Distribution Congress. As a partner of the Modern Distribution Congress, the Bank
actively contributes to discussions on the future of the retail and distribution sector and its supply chains, emphasising
the importance of sustainable development. The Bank uses this platform to promote solutions supporting environmental
and social transition and to share its experience in financing sustainable transition,
• Strategic partnership with Chapter Zero Poland. The Bank is a supporting partner and Patron of Chapter Zero Poland – a
programme aimed at developing the competences of management and supervisory boards in climate-risk management.
As part of this cooperation, the Bank supports climate education for senior executives, strengthens the integration of ESG
considerations into business decisions, and co-creates a platform for knowledge exchange among market leaders.
• Dairy Cooperative Forum and the Polish Chamber of Milk. In cooperation with the Dairy Cooperative Forum and the Polish
Chamber of Milk, the Bank engages in the sustainable transition of the dairy sector. The Bank supports dialogue on green
investments, environmental innovations and responsible agricultural production, acting as a financial partner for change
within the industry.
• Association for Sustainable Agriculture and Food in Poland (ASAP), which promotes sustainable agricultural practices.
The Group’s activities on climate-related opportunities
Introduction of activities related to business opportunities
According to the World Energy Outlook published by the International Energy Agency in 2025, global investments in the
energy sector are expected to reach USD 3.3 trillion in 2025. The share of global spending on low-emission technologies
has been steadily increasing since 2022. In 2025, such technologies were expected to account for two-thirds of total energy
investments (nearly USD 2 trillion). In the Net Zero Emissions scenario, clean-energy technologies and infrastructure have
represented almost 90% of power-sector investment since 2020, and according to the IEA’s projections, this share is
expected to approach 100% by 2035. To meet these challenges and make the changes, investments will be needed from
companies, institutional investors and the public sector. By helping its Customers in transition to a low-carbon economy,
the Bank is convinced that it can take action for the environment and a sustainable economy, while ensuring solid and
sustainable results in the long term.
These opportunities are reflected in the GObeyond Strategy for 2022-2025, and are particularly evident in the commitment
to supporting Customers in the transition to a low-carbon economy. The Bank has defined a strategic target for the share of
sustainable financing, as set out in the GObeyond strategy, which is 10%. In 2025, the value of the sustainable financing
portfolio amounted to PLN 13.6 billion, representing a 14.6% share of sustainable financing. Details and availability rules
are described in the chapter Implementation of the strategy, Filar POSITIVE., section Sustainable financing, pages 52-55.
BNP Paribas offers a range of banking and non-bank solutions to support its Customers in the energy and environmental
transition. These offerings cover a wide range of climate-related areas, including reducing energy consumption and
financing projects aimed at lowering greenhouse gas emissions.
• The Bank relies on specialised teams dedicated to financing and providing expert support to Customers in their transition
towards a low-carbon economy across all segments, from strategic and international Customers to mid-caps and SMEs,
as well as on the Decarbonisation and Biodiversity Office. In particular, the following areas offer significant opportunities:
• zero-emission energy production: financing that supports the development of new renewable energy generation capacity;
• decarbonisation of industrial production processes: support for Customers throughout their environmental and energy
transition strategies, including efforts to reduce energy consumption, decarbonise energy use and lower greenhouse gas
emissions;
• sustainable mobility: support and financing for companies and entities operating in the mobility sector, including public
transport operators and manufacturers;
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• food production sector (agriculture and food industry): a comprehensive offering that supports the transition of the food
system, decarbonisation and the development of regenerative agriculture practices as a lever for decarbonisation and
income resilience across the food value chain. The offering includes banking and non-bank products, such as cooperation
with the Klim platform.
To support individuals in purchasing property and undertaking energy renovation projects, the Group has developed
services and solutions that assist Customers in their projects. The My Sustainable Home initiative, introduced by BNP
Paribas Group and implemented in Poland as Mój Dobry Dom, structures the approach of operational units around four
main levers:
• education: raising awareness and advising Customers on creating and collecting energy performance certificates,
including the requirement to gather data when issuing a new dedicated mortgage loan;
• supporting the purchase of energy-efficient goods through favourable financing conditions;
• meeting the needs of building energy transition through preferential-rate loans or loans supported by public aid
programmes;
• developing non-financial services through partnerships that support comprehensive energy renovation pathways, from
defining the scope of work to verifying environmental impact after completion.
To address challenges related to sustainable mobility in everyday travel, the Group supports Customers by offering services
and solutions in the field of sustainable mobility:
• The BNP Paribas Group’s mobility offering includes products that enable Customers to finance new electric vehicles
through loans, leases and long-term rental, supporting the circular economy, as well as second-hand electric and
low-emission cars.
• Customers can access financial products in bank branches, at partner locations and via the mamGO platform. The
platform also provides key information on electromobility and features an educational blog.
• BNP Paribas Group products could also be used in conjunction with the government programme NaszEauto.
Activities related to emissions covered by the operational scope
The Bank is taking steps to reduce its direct environmental impact and to lead by example and raise awareness among its
employees. Since 2019, it has been measuring energy consumption and operational greenhouse gas (GHG) emissions
(Scope 1, Scope 2 and Scope 3 for business travel) and progressively reducing them, through the reduction of energy
consumption related to premises, IT equipment and business travel, as well as the use of low-carbon energy.
Use of low-carbon electricity
In order to further reduce its environmental impact, the Group has been increasing its share of low-carbon electricity for
several years. Starting in 2020, electricity from renewable sources accounted for 100% of total energy consumption. It
comes from the purchase of green electricity with guarantees of origin and from offsetting dirty energy with purchased
appropriate electricity certificates or direct consumption of renewable energy produced by the Group’s own photovoltaic
systems. The total energy consumption was 38,758 MWh in 2025 and 38,937 in 2024. The consumption of purchased
thermal and electrical energy alone in the Group amounted to 76,424 GJ in 2025 vs. 70,651 GJ in 2024. This increase was
due to the fact that 2024 was statistically the warmest year in Poland’s history, but one without a hot summer that would
have placed a heavy load on air-conditioning systems. As a consequence, energy and heat consumption in 2024 was lower
than in 2025.
Low-carbon energy measures allow to reduce the CO
2
emissions associated with the Group’s electricity consumption, which
is taken into account in the market-based approach. In 2025, GHG emissions from Scope 1, 2 and 3 (Category 6) amounted
to 7,860 tCO
2
e, a decrease of 61% compared to 2019. According to the target defined in GObeyond 2022-2025 strategy for
its own operations, GHG emissions in 2025 should fall to 9,067.05 tCO
2
e, meaning that this target has been achieved.
Actions taken at the Bank to reduce the carbon footprint of buildings
In addition to the use of green energy, the Bank is successively installing photovoltaic systems at its locations. At the end of
2025, 23 photovoltaic systems were in operation.
Along with the use of renewable energy sources, the Group is minimising energy consumption by introducing energy-
efficient initiatives. It is replacing lighting with LEDs (99% both in external signage and in the Bank’s locations), successively
replacing storage water heaters with instantaneous water heaters. Remotely controlled heat pumps, or miniBMS BMS
(Building Management System) controlling the schedule of the most energy-intensive installations in the network locations
have been launched at 20 locations. At the central locations, the Group is optimising operations for the HVAC system
(heating, ventilation, air conditioning) using the. The waste is segregated at 85% of locations.
The Group also raises awareness among employees on a daily basis on the efficient use of energy. These efforts are
supported by the ongoing work of the team responsible for ISO 50001 and 14001 standards within the integrated energy
management system. To this end, continuous education and internal communication are carried out to promote proper use
of equipment and building systems, contributing to the reduction of energy consumption and CO₂ emissions.
Environmental certification
In 2025, the Bank obtained ISO 14001 and ISO 50001 environmental certifications, covering the Bank’s headquarters and 10
additional locations. The certification confirms compliance with international standards for environmental and energy
management. In the next steps, the principles covered by these certifications will be gradually extended to the remaining
Bank branches. Following the certification, an energy review was carried out for the entire Bank, and a dedicated team was
appointed to develop and enhance a continuous improvement system that enables ongoing monitoring and optimisation of
how the Bank manages energy and environmental performance.
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Sustainable IT initiatives
The Sustainable Digital approach defines ten principles that apply to IT in the Bank. The New Technology and Cybersecurity
Area uses multiple decarbonisation levers:
• operating IT according to a ‘sustainable by design’ approach;
• raising awareness of environmental issues among all employees,
• making improvements to IT-managed equipment (Data Centre infrastructure, employee equipment) in order to increase
energy efficiency,
• creating, maintaining and developing IT systems with a view to reducing the harmful environmental impact of IT
infrastructure and operations, as well as IT systems.
• The Bank considers reduction of the carbon footprint associated with digital channels, marketing activities,
communications and IT processes. The Bank takes into account environmental objectives when conducting its
technological transition, in particular:
• moving part of IT ecosystem to the cloud and working with suppliers that have data centres with a zero carbon footprint
(certified by renewable energy certificates), which allows us to reduce our carbon footprint in the energy supply chain for
IT hardware,
• upgrading, consolidating and virtualising equipment in the Data Centre,
• shifting equipment management to a circular economy approach. The Bank manages the life cycle of equipment to reduce
the amount of waste generated during its life cycle (e.g. reuse of IT equipment). In 2025, employees repurchased 3,384 IT
devices (mobile phones, laptops, PCs, screens) under the implemented policy. 112 devices (screens, PCs, laptops,
printers) were donated to charitable organisations,
• defining environmental criteria for IT purchase: energy consumption assessments were introduced as qualitative
elements of the criteria in the tender proceedings in New Technologies and IT Support,
• raising awareness of the carbon footprint generated by applications when developing banking systems,
• equipment that is unusable is handed over to a specialised company for disposal. In 2025, more than 8,000 IT devices
were donated to Elektrozłom.pl by the Bank,
• the use of certified and recycled paper for printing equipment at the Bank as well as in mass correspondence.
Sustainable mobility initiatives
Every year, we carry out a range of initiatives supporting sustainable mobility in the area of business travel and fleet use.
For local business trips, employees are enabled to use public transport through a dedicated application, which eliminates
the need to print tickets or submit paper-based expense reports. This supports the policy of reducing resource consumption
and promotes the use of public transport for local business purposes. For intercity travel, we encourage the use of trains
and long-distance buses by providing convenient booking tools and promoting low-emission transport options.
In line with BNP Paribas Group recommendations, we have taken steps to reduce the number of business trips by verifying
their necessity and promoting remote meetings, which helps lower travel-related emissions. At the same time, we are
transforming our vehicle fleet, consistently phasing out petrol and diesel cars in favour of electric and hybrid vehicles. New
fleet vehicles meet low- and zero-emission requirements, supporting the reduction of the Bank’s carbon footprint.
Sustainable mobility within our organisation also means ensuring user safety. We conduct numerous educational,
communication and event-based initiatives, including family picnics, that build awareness of safe and responsible use of
various modes of transport. In everyday operations, we encourage employees to choose alternatives to cars, especially for
short distances, offering a wide range of mobility options and supporting habit change.
The measures introduced combine environmental, organisational and social aspects, strengthening a culture of responsible
mobility, reducing emissions and increasing employee awareness. Our goal remains to further expand solutions that
support climate neutrality, safety and sustainable development.
As part of the fleet electrification programme, the Bank aimed to phase out all diesel and petrol vehicles by 2025 in favour
of alternative-drive cars. This commitment has been fulfilled based on orders placed, although due to delivery delays the
vehicles were not yet in operation as of 31 December 2025. Following the delivery of the ordered cars, the target structure
of the alternative-drive fleet will comprise 1,251 vehicles, including 83% hybrid and 17% fully electric cars. The transition
to such vehicles supports the environmental objectives of the Bank’s GObeyond strategy for 2022–2025 and the updated
electrification goals of the BNP Paribas Group.
Transition resources
The Bank maximises its positive impact on environmental issues mainly by supporting the transition of its Customers and
offering them the right products, services and tools. At the same time, it mitigates the negative impact of its own activities.
The Bank has dedicated teams that oversee the integration of climate issues in all its activities, both commercial and own
operations.
The Bank has a Sustainability Area, which emphasises the Bank’s strategic approach to ESG factors. Its functioning is
described in detail in the section General Disclosures (ESRS 2) – Governance. The Real Estate Office and the Administration
Office are responsible for implementing the objectives related to own activities.
In 2025, nearly 100% of the Bank’s employees completed the mandatory e-learning course ESG Fundamentals at BNP
Paribas Bank Polska S.A., which introduced them to the basics of ESG topics, including climate-related issues. In addition,
the Bank promoted and encouraged all employees to expand their knowledge by participating in the comprehensive
e-learning programme developed by the BNP Paribas Group: the Sustainability Academy.
In 2025, the Bank and Group companies once again organised ESG Days, a series of educational events dedicated to ESG
topics. During ESG Days, employees explored subjects such as sustainable finance, products supporting the energy
transition, and sustainable buildings. They could also participate in webinars led by in-house experts, focusing on the
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Bank’s strategic approach to sustainability and related initiatives. As part of the MyWay training offer available to all
employees, the Bank organises Climate Mosaic workshops. The Climate Mosaic is an interactive workshop based on the
best available scientific knowledge, incorporating trend analysis and designed to explain the causes and mechanisms of
global warming using UN climate reports (IPCC reports). In 2025, 50 employees took part in the workshops, and 18
completed the training required to become certified facilitators.
The Bank also conducted training and consultation sessions for Advisors to ensure the highest quality of service in the area
of sustainable financial products. Advisors participate in internal and external training programmes, including the ESG
Development Academy for Business Advisors and the ESG Business Inspirations webinar series, which presents case studies
of green transactions.
The Bank organised a series of workshops entitled “Strategically on Decarbonisation in the Food Sector for Risk” and
Business teams. These workshops were aimed at Advisors and Analysts working with business Customers across all
segments, from sole-proprietor farmers to large corporate groups, as well as anyone interested in deepening their
knowledge of decarbonisation in the food sector.
The ability to carry out the activities described in this section does not depend on the availability and allocation of
resources. At the same time, through our activities of providing financing for, for example, innovations and solutions leading
to the decarbonisation of our Customers, we influence the decarbonisation of our loan portfolio.
The Bank’s capital expenditure in 2025 for the implementation of climate change mitigation and adaptation measures
amounted to PLN 866,9 thousand and included, among other things, the installation of photovoltaic equipment, BMS and
reactive power compensators. The Bank’s total capital expenditure in 2025 amounted to PLN 442,242 thousand. Operating
expenses for climate change mitigation and adaptation amounted to PLN 38,890 thousand and included, among other
things, the maintenance and review of the installations, the purchase of green energy and guarantees of origin and
certificates of origin, and the lease of hybrid and electric cars. The Bank’s total operating costs amounted to PLN 3,240,933
thousand. Details are described in the General administrative expenses, depreciation and amortisation.
Metrics and targets
Targets related to climate change mitigation and adaptation (E1-4)
Group targets and metrics related to climate change opportunities
Targets and metrics related to the Group’s business activities
The Bank focuses on financing activities that promote the decarbonisation of the economy, supporting these ambitions by
setting sales targets for financing transactions and projects aimed at using energy from renewable sources and actively
investing in sustainable technologies. In 2025, the value of sustainable financing provided by the Bank amounted to PLN
13.6 billion (compared to PLN 10.2 billion in 2024), including PLN 8.8 billion of financing for environmental objectives. The
strategic goal is 10% sustainable financing and is described in detail in the section Implementation of the strategy: Pillar
POSITIVE. The Bank has not defined targets for its loan portfolios and financed greenhouse gas emissions (Scope 3,
Category 15. Investments).
Targets and metrics related to the Group’s own operations
Approach and metrics
Sustainability measures are an integral part of the Bank’s GObeyond strategy 2022-2025, which includes commitments to
develop sustainable products, their sales volumes, as well as to reduce greenhouse gas emissions (Scope 1, 2 and 3 –
business travel).
The data required to calculate the metrics related to own operations are collected annually by all Group companies. The
period considered for data collection covers the 12 months from January to December 2025.
The measurement of CO
2
emissions from the Group’s activities is based on the GHG Protocol reference methodology. The
energy consumed (electricity, gas, oil, district heating) in the buildings occupied by the Group and the energy consumed in
the means of transport used by employees for business travel (excluding travel from home to work) by car, train or plane
are taken into account. Only the combustion of fossil fuels is considered; fuel extraction and transport are excluded from
this calculation. Through its activities, the Group is not a material source of noise pollution or any other specific industrial
pollution.
The base year for target setting is 2019. It was chosen because it reflects the organisation’s typical operating conditions. In
the following years, the Group’s own activities were disrupted by the COVID-19 pandemic, which had an impact on the
results regarding greenhouse gas emissions and energy consumption. The targets include all companies in the Group. The
GObeyond Strategy for 2022-2025 did not rely on climate scenarios.
In Scopes 1 and 2 as well as Scope 3 (business travel), the Bank set the goal of reducing greenhouse gas emissions by 55%
and reducing energy consumption by 35% by 2025 in the GObeyond strategy. The reduction of greenhouse gas emissions
includes CO
2
e. In 2024, both strategic goals defined in the GObeyond strategy were achieved. This is the result of the
factors described in the section The Group’s activities on climate-related opportunities, which include:
• changes in the Group’s vehicle fleet, consisting of a consistent increase in the share of electric and low-emission cars and
the phase-out of diesel vehicles
• actions aimed at reducing building emissions, such as replacing standard lighting with LED, optimising equipment,
upgrading air-conditioning units to more efficient models, implementing pilot programmes for heat pumps and
building-management systems (BMS), modernising IT equipment at the headquarters
These results were also influenced by the continued use of the hybrid work model, the implementation of ISO 14001 and
ISO 50001 environmental certifications, and efforts to build awareness and promote good practices among employees.
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Table 85. Achievement of GObeyond strategic target to reduce CO
2
emissions (2022-2025)
Emission volume (tonnes CO
2
e)
Target 2025
base year 2019
2025
2025 vs 2019
Reduction of CO
2
emissions from operations – 55%
20,149
7,860
-61%
Table 86. Achievement of GObeyond strategic target for energy consumption (2022-2025)
Energy consumption (GJ)
Target 2025
base year 2019
2025
2025 vs 2019
Reduction of energy consumption – 35%
153,389
76,424
-50%
Decarbonisation levers used to reduce greenhouse gas emissions in own operations are described in the section Actions and
resources in relation to climate change policies (E1-3). The key decarbonisation lever resulting in the reduction of
greenhouse gas emissions in Scope 1 is the use of an alternative drive fleet: transition to electric and hybrid cars reduces
Scope 1 emissions by approximately 50%. In Scope 2, it is electricity from renewable sources, which reduces greenhouse gas
emissions by an estimated 60%.
Energy consumption and mix (E1-5)
The Group measures electricity consumption at its sites, as well as the amount of electricity produced by the photovoltaic
installations installed at selected sites. The table below also presents the consumption of other types of energy.
The Group’s energy consumption and energy mix can be broken down as follows:
Table 87. Information on energy consumption and energy mix in the Group
Energy consumption and energy mix
2025
2024
1) Fuel consumption from coal and coal products (MWh)
0
0
2) Fuel consumption from crude oil and petroleum products (MWh)
13,884
15,535
3) Fuel consumption from natural gas (MWh)
3,420
3,563
4) Fuel consumption from other fossil sources (MWh)
0
0
5) Consumption of purchased or procured electricity, heat, steam and cooling from fossil
sources (MWh)
8,751
8,397
6) Total consumption of energy from fossil sources (MWh) (calculated as the sum of lines 1-
5)
26,054
27,495
Share of fossil sources in total energy consumption (%)
67%
71%
7) Energy consumption from nuclear sources (MWh)
–
–
Share of energy consumption from nuclear sources in total energy consumption (%)
–
–
Energy consumption and energy mix
2025
2024
8) Fuel consumption of renewable sources, including biomass (also including industrial and
municipal bio-waste, biogas, renewable hydrogen, etc.) (MWh)
0
0
9) Consumption of purchased or procured electricity, heat, steam and cooling from
renewable sources (MWh)
12,478
11,228
10) Consumption of self-generated renewable energy without fuel (MWh)
226
214
11) Total renewable and low-carbon energy consumption (MWh) (calculated as the sum of
lines 8-10)
12,704
11,442
Share of renewables in total energy consumption (%)
33%
29%
Total energy consumption (MWh) (calculated as the sum of lines 6, 7 and 11)
38,758
38,937
Gross Scopes 1, 2, 3 and Total GHG emissions (E1-6)
Greenhouse gas emissions from Scope 1 and 2 and 3 of own activities
In 2024, the Group’s total emissions from business activities [direct emissions (Scope 1), indirect emissions related to
energy purchases (Scope 2) and indirect emissions related to business travel (Scope 3)] amounted to 7,860 tCO
2
e (market-
based).
Direct emissions from fossil fuel combustion in Scope 1 amounted to 4,201 tCO
2
e, while in Scope 2 we recorded 3,116 tCO
2
e
of indirect emissions from energy consumption market-based. In Scope 3, business travel emissions amount to 543 tCO
2
e.
The methodology for calculating the carbon footprint in the Group is in accordance with the GHG Protocol. Scope 1 of the
carbon footprint includes direct emissions, i.e. emissions from the combustion of fuels in energy sources, production
processes and means of transport that belong to the organisation and are under its control, and emissions from the
leakage of refrigerants, e.g. from air conditioning systems. The Scope 2 carbon footprint includes indirect energy emissions
that are related to the electricity and heat purchased by the organisation. These are emissions that occur outside the
organisation at sources owned or controlled by other entities. The carbon footprint from the use of utilities has been
calculated for each of the Group’s 389 locations. The estimation includes the use of electricity, gas and central heating. In
2025, we used the carbon footprint calculation tool within the Envirly platform. It is based on the GHG Protocol and ISO
14064-1 and has been certified by the auditing company TUV NORD. The emission factors needed to calculate greenhouse
gas emissions come from the publications from the National Centre for Emissions Management (KOBiZE), the Energy
Regulatory Office (URE) and the DEFRA (Department for Environment, Food and Rural Affairs in the UK Government)
database, among others. Greenhouse gas emissions related to business trips are calculated based on the kilometres
travelled and are related to:
• bookings for air and train travel made through travel agencies with which the Group cooperates,
• travel by private car.
The Group uses contractual instruments such as guarantees of origin for renewable energy certified by Respect Energy as
well as certificates covering energy which is not directly supplied by Respect Energy that confirm that it is renewable
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energy. Consequently, all greenhouse gas emissions resulting from electricity consumption in Scope 1 and 2 are considered
zero-emissions according to the market-based method.
The Group does not buy energy for which the guarantees of origin indicate biomass. It has also no possibility of identifying
greenhouse gas emissions from the combustion or biodegradation of biomass in the value chain.
Scope 3 emissions
As of 31 December 2025, the estimated financed GHG emissions (category 15) are 2,295,129 tCO
2
e.
The calculations are made in accordance with the GHG Protocol and PCAF standard, which takes into account emissions
from direct corporate financing in the form of equity, debt and project finance. The calculation includes exposures of the
banking portfolio to non-financial corporates. The gross carrying amount of the Group’s exposures that form the basis of
the GHG calculations is PLN 53 billion. The calculations include:
• loans to large enterprises,
• loans to small and medium-sized enterprises,
• loans to micro-enterprises,
• corporate bonds and shares in third parties.
To determine the share of greenhouse gas emissions attributable to the Group, Scope 1, 2 and 3 Customer emissions data is
used, which is publicly available, obtained from external suppliers and directly from Customers. Where Customer data is
not available, the Group makes calculations using average emission factors determined for regions and sectors according to
the PCAF standard. For the oil, gas and car sectors, the Group presents all three Scopes of Customer emissions. For the
other sectors, Scope 3 Customer GHG emissions are not included in the emission calculations due to the lack of a
standardised framework for reporting certain emissions, leading to a lack of precise, consistent and comparable data. While
the Group has made efforts to obtain data, most Customers have not provided data regarding Scope 3, or the data provided
indicates poor quality. Many Customers do not yet have the capacity or systems in place to track total emissions, which can
lead to the disclosure of fragmented data. The Group believes that presenting incomplete data may mislead report
recipients. Since the quality of data depends on external factors, it is not possible to indicate a time horizon in which the
Group will be able to include Scope 3 data of satisfactory quality in its calculations for the other sectors.
In 2025, the Group introduced a change in the data sources used to estimate financed emissions for the food production
sector, ensuring that the calculation is based not only on the Customer industry classification but also on the volume of
specific agricultural products they produce. As a result, for such Customers, Scope 1 and 2 emissions are calculated using
emission-intensity indicators derived from external agricultural market databases, including FADN, FAO, the Agro-food Data
Portal and Eurostat. These sources make it possible to estimate the size of farms based on their plant and animal
production volumes and to assign emission intensities appropriate to the goods produced. This change resulted in a more
accurate reflection of the Bank’s emissions associated with financing the agricultural sector and led to a reduction of 2
million tonnes of CO₂ equivalent. To ensure comparability, the 2024 data were also recalculated retrospectively using the
new methodology.
As of 31 December 2025, approximately 20% of emissions in the portfolio of financed non-financial corporate emissions are
reported by Customers. Accordingly, the calculation of 80% of issues is based on sector and geographic averages. However,
the Group is taking steps to increase the share of data obtained directly from Customers through, for example, its
collaboration with Envirly and by providing Customers with ESG questionnaires required in the credit process to collect
such data directly from Customers.
The following balance sheet exposures were not included in the measurement of greenhouse gas emissions (gross carrying
value according to the approach used in the emissions calculation):
• securities (other than corporate bonds), including treasury bonds and development bank bonds (with a total value of PLN
57 billion) – this exclusion is due to the fact that this portfolio is not of a commercial nature – its purpose is to ensure the
safe management of the Group’s liquidity, in particular to enable the banks to maintain the minimum ratio of liquid assets
to net outflows (meeting regulatory obligations) and to manage interest rate risk; in addition, the available data used to
calculate greenhouse gas emissions from bonds is based on averaged data for the entire economy; the average emission
intensity of this portfolio according to the PCAF standard is 56 tCO
2
e/million PLN;
• mortgages (PLN 23 billion) and car loans (PLN 5 billion) – the data collected on building energy certificates is currently
insufficient (despite the broader range of available certificates made possible by the use of data from the central register
of building energy performance), so calculations are mainly based on proxies and averages; in the case of GHG emissions
for car loans, the range of data collected is not sufficient to make accurate calculations; at the same time, car loans relate
to part of the value chain which may result in multiple emission counts; the exclusion of financed emissions from
mortgages and car loans has no material impact on total financed emissions.
Off-balance sheet items are not included in the calculation. Other Scope 3 categories are not calculated by the Group due
to their non-materiality.
Table 88. Methodology for calculating Scope 3 greenhouse gas emissions in the Group
Source of Scope 3 emissions
Methodology for calculating Scope 3 emissions
6 Business travel
The emission factors needed to calculate emissions are derived from the DEFRA standard.
15 Investments
The reporting of financed greenhouse gas emissions resulting from the Group’s lending and debt
capital investments follows the PCAF Funding Emission Part A methodology (Partnership for
Carbon Accounting Financials)
The Group is not aware of any material events or circumstances related to differences between the reporting period of the
Group and the reporting period of Customers.
Summary of gross Scope 1, 2, 3 and total greenhouse gas emissions
The Group’s greenhouse gas (GHG) emissions are distributed as shown in the table below. Scope 3 Category 15 emissions
account for nearly 100% of total emissions.
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Table 89. Total gross Scope 1, 2 and 3 greenhouse gas emissions in the Group in tCO
2
e
2025
2024
Scope 1 greenhouse gas emissions
Gross Scope 1 greenhouse gas emissions (tonnes of carbon dioxide equivalent)
4,201
4,723
Percentage of Scope 1 greenhouse gas emissions from regulated emissions trading
schemes (%)
–
–
Scope 2 greenhouse gas emissions
Gross Scope 2 greenhouse gas emissions by location-based approach (tonnes of
carbon dioxide equivalent)
10,008
10,986
Gross Scope 2 greenhouse gas emissions under the market-based approach
(tonnes of carbon dioxide equivalent)
3,116
2,991
Significant Scope 3 greenhouse gas emissions
Total gross indirect Scope 3 greenhouse gas emissions (tonnes of carbon dioxide
equivalent)
2,295,672
2,280,768
6 Business Travel
543
567
15 Investments
1,2
2,295,129
2,054,667
3
Total greenhouse gas emissions
Total greenhouse gas emissions (location-based)
(tonnes of carbon dioxide equivalent)
2,309,881
2,070,943
Total greenhouse gas emissions (market-based)
(tonnes of carbon dioxide equivalent)
2,302,989
2,062,948
1
As more described above in detail, the value does not take into account sovereign bond issues and Scope 3 Customers.
2
Category 15 of Scope 3 includes lease receivables.
3
The value of investments has been recalculated retrospectively to reflect the changes introduced in 2025 to the methodology for calculating financed emissions, as described in the section Scope 3
emissions. These changes include the incorporation of Scope 3 emissions for the oil, gas and automotive sectors, as well as the change in emission-factor sources for the agricultural sector. The 2024 figures
also include improvements in the quality of data received from Customers regarding their own emissions measurements for that period, which were not yet available at the time of last year’s report. The
retrospective recalculation ensures year-on-year comparability of the data. In line with last year’s calculations, emissions from investments amounted to 4,701,774 tCO
₂
e.
The Group is not aware of any material events or changes in circumstances between the Group’s reporting period and the
reporting period of its Customers.
GHG intensity
In the absence of standards for the application of a GHG intensity per income metric for financial institutions, the Group
publishes the GHG intensity (financed emissions) per unit of financed assets, equal to 44 tCO
2
e/PLN mln. The GHG intensity
ratio for 2025 calculated in accordance with the requirements of ESRS E1-6, relating total GHG emissions to net income
published in the Financial results section of this report, location-based and market-based, is 0.18 tCO
2
e/thousand PLN. Net
income of PLN 12,776,988 thousand represents the sum of the following items: interest income, fee and commission
income, dividend income, net trading income (including result on currency exchange), result on investment activities, result
on hedge accounting, and other operating income.
The greenhouse gas emission intensity indicator for 2024, calculated using both the location-based and market-based
approaches, amounted to 0.16 tCO₂e per thousand PLN. This is a corrected figure that reflects the updated methodology for
calculating financed emissions and therefore differs from the value reported in the 2024 statement. Net revenue for 2024
amounted to PLN 12,896,755 thousand. The Bank’s own greenhouse gas emission intensity indicator per unit of financed
assets in 2024, based on the adjusted GHG emission values, amounted to 42 tCO₂e per million PLN.
Table 90. BNP Paribas Group greenhouse gas emission intensity
Greenhouse gas emission intensity per net revenue
2025
2024
1
Greenhouse gas emission intensity (financed emissions) per unit of financed assets (tCO
2
e/PLN million)
56
42
Total greenhouse gas emissions (location-based) per net revenue
(tCO
2
e/PLN’000)
0.18
0.16
Total greenhouse gas emissions (market-based) per net revenue
(tCO
2
e/PLN’000)
0.18
0.16
1
Adjusted for change in the methodology for calculating financed emissions.
GHG removals and GHG mitigation projects financed through carbon credits (E1-7)
The Group does not purchase carbon credits.
Internal carbon pricing (E1-8)
The Group does not use internal carbon pricing systems.
Taxonomy disclosures
Regulatory framework and reporting obligations for financial institutions
The EU Taxonomy (Taxonomy) is a system for classifying sustainable economic activities according to their contribution to
the six environmental objectives defined by the European Commission in the various Regulations and Delegated Acts
published between June 2020 and January 2026.
In July 2025, the European Commission adopted a proposal to simplify the application of the EU Taxonomy. In the
disclosure presented below, the Bank applied the new approach in line with the provisions of Commission Implementing
Regulation (EU) 2026/73 of 4 July 2025 (“Regulation (EU) 2026/73”). As the new indicators include, among other changes, a
different denominator scope, the disclosures presented below are not comparable with those published for 2024.
The Taxonomy is based on two central concepts:
• eligibility of an activity, if the latter is described in one of the Delegated Regulations of the Taxonomy because of its high
potential to contribute to any one of the six environmental objectives;
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• alignment, which confirms the significant contribution of an eligible activity to one of the six environmental objectives,
based on measurable criteria. An aligned activity is defined as an activity that makes a substantial contribution to one of
the environmental objectives without causing harm to the other objectives and that meets the minimum safeguards.
The main alignment indicator for credit institutions is the Green Asset Ratio (GAR), which concerns financing instruments
(loans and advances, debt securities, equity instruments) on the institution’s balance sheet. Additional performance
indicators include: the Green Asset Ratio (flow), the assets under management ratio, and the financial guarantees ratio. The
Bank made use of the option to omit reporting on the financial guarantees’ ratio, as provided for in Regulation 2026/73,
given that net income from guarantees accounts for less than 10% of the Bank’s total net income (net banking income).
Scope of financial assets subject to alignment analysis
Taxonomy disclosures are prepared on a consolidated basis in accordance with prudential consolidation.
Green asset ratio (GAR)
The measurement of financial assets covered by the Taxonomy is based on the gross carrying amount.
The ratio numerator measures the amounts of financial assets corresponding to aligned activities within the meaning of the
Taxonomy. Its scope of analysis covers the following financial assets (loans and advances, debt securities, equity
instruments, enforced collateral):
• outstandings on European financial and non-financial companies subject to the CSRD in 2025
7
and subject to the
obligation to disclose sustainability information under the amended Accounting Act;
• outstandings on households in the three loan categories covered by the regulation (mortgage loans, building renovation
loans, motor vehicle loans granted from 1 January 2022);
• outstandings on local administration for financing of public housing and other specialised financing (only for which the
allocation of funds is known).
In accordance with Commission Delegated Regulation (EU) 2026/73 of 4 July 2025, the denominator of the GAR now
includes the financial assets listed above, as well as other exposures to households. It should be noted that in the previous
year the denominator also included other assets that were not subject to a Taxonomy-eligibility and alignment assessment.
As at 31 December 2025, the denominator includes approximately 50% of assets eligible under the Taxonomy, i.e., assets
that potentially meet the alignment criteria and may therefore be included in the numerator. Taxonomy-eligible assets
consist primarily of mortgage loans granted to households (approximately 70% of Taxonomy-eligible assets). The remaining
assets include exposures to financial and non-financial corporates (approximately 14% of Taxonomy-eligible assets), as
well as vehicle loans and building renovation loans (approximately 17% of eligible assets). In practice, these latter
categories of household loans cannot be included by banks in the numerator due to the lack of available data. The
remaining portion of the denominator (approximately 50%) corresponds to assets that do not meet the Taxonomy
7
Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 on corporate sustainability reporting (CSRD)
requirements and are therefore inherently excluded from the numerator. Approximately 70% of these assets are exposures
to households, with the remaining 30% representing exposures to corporates.
The GAR, which is measured on a stock basis, is complemented by a flow-based metric. This indicator reflects the share of
new Taxonomy-aligned on-balance-sheet exposures granted during the financial year and active at the reporting date,
relative to the total value of on-balance-sheet exposures included in the denominator granted during the financial year and
active as at 31 December 2025.
Additional key performance indicators
Concerning the green ratio of assets under management, the scope covers instruments invested in EU companies subject in
2025 to the CSRD in the Group’s management of Customer assets, i.e. the assets of the portfolio management service of the
Brokerage Office of the Bank and investment funds managed by BNP Paribas TFI. Other funds – i.e., those not managed by
BNP Paribas TFI – were not included in the green managed assets indicator in 2025.
The Green Assets Under Management flow indicator for the 2025 reporting year is calculated as the difference between the
value of assets under management at the end of 2025 and their value at the end of the previous year.
Methodology for assessing alignment with the EU Taxonomy
The approach to analysing the eligibility and alignment of financial assets with the Taxonomy varies depending on the type
of entity.
For companies subject to the NFRD, if the financing instruments are with unknown use of proceeds, the Group uses the data
received from and published by counterparties, such as the aligned turnover ratio and the aligned capital expenditure ratio
(CapEx). This treatment applies to the Green Asset Ratio (GAR) and the green ratio for assets under management.
In case of known use of proceeds, the alignment measure should be based on information collected from the counterparty.
The communication notice published by European Commission on 8 November 2024 on the interpretation of certain
provisions of Delegated Regulation (EU) 2021/2178 specifies that financial institutions must collect supporting documents
proving the alignment for each of the technical criteria, in order to ensure that they are met. The level of collection and
verification of the requirements set by the Commission is not fully achievable. This is why no financial instrument with
known use of proceeds has been reported in the GAR numerator, whether with respect to companies or local governments.
For financing granted to households, financial institutions must also collect evidence confirming compliance with all
technical screening criteria in order to assess Taxonomy alignment. The Group is able to perform such a comprehensive
assessment only for mortgage loans. Compliance with the substantial contribution criteria for financed residential
properties is verified based on the primary energy demand indicator (“EP”) included in energy performance certificates.
These data are obtained directly from Customers during the credit process or from the Central Register of Energy
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Performance Certificates maintained by the Ministry of Development and Technology. We classify exposures financing the
purchase or construction of properties as meeting the substantial contribution criteria if their EP indicator does not exceed:
• for properties built before 31 December 2020:
81.86 kWh/m²/year for multi-family buildings;
83.91 kWh/m²/year for single-family houses;
• for properties built after 1 January 2021:
58.5 kWh/m²/year for multi-family buildings;
63 kWh/m²/year for single-family houses.
The DNSH (“do no significant harm”) criteria were verified based on the Bank’s internal process for assessing physical
climate risk. As a precautionary measure, the Bank classified as Taxonomy-aligned only those exposures that are located in
areas not exposed or with low exposure to physical risks. The significant increase in Taxonomy-aligned housing loans
compared with the previous year results from improved data quality and availability, including the use of the ministerial
energy performance register, as well as from moving away from an overly restrictive interpretation of the EP indicator.
8
At this stage, the Group does not collect evidence confirming compliance with all technical criteria for household
renovation loans or car loans. Consequently, the numerator of the indicator includes only household mortgage loans.
Key indicators
Table 91. Summary of key performance indicators to be disclosed by credit institutions in accordance with Article 8 of the Taxonomy Regulation
31.12.2025
Total exposure to Taxonomy-aligned activities
(PLN’000)
KPI(1)
(%)
KPI(2)
(%)
% coverage (over total assets)(3)
(%)
Exposures not covered (% of assets covered
by the KPI)(4)
(%)
Exposures not covered (% of assets covered
by the KPI)(4)
(%)
Turnover-based
CapEx-based
Turnover-based
CapEx-based
Turnover-based
CapEx-based
Main KPI
Green Asset Ratio (GAR) stock
1,471,865
2,023,346
2.58%
3.55%
31.12%
0.00%
0.00%
Additional KPIs (5)
GAR (flow)
562,834
541,068
4.30%
4.13%
32.68%
0.00%
0.00%
Financial guarantees (6)
n/a
n/a
n/a
n/a
Assets under management
39,033
66,953
0.63%
1.07%
(1) Fee and commission income other than from lending and asset management services. (2) Based on the Turnover KPI of the counterparty. (3) Based on the CapEx KPI of the counterparty. (4) % of assets covered by the KPI over the Bank’s total assets. (5) KPIs of fee and commission income and the trading book apply only from 2028. (6) The Bank made use of the option to omit reporting on the financial guarantees
ratio, as provided for in Regulation 2026/73, given that net income from guarantees accounts for less than 10% of the Bank’s total net income.
8
In the 2024 disclosure, meeting the substantial contribution criteria was possible only for properties whose EP did not exceed 58 kWh/m²/year.
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31.12.2024
Total exposure to Taxonomy-aligned activities
(PLN’000)
KPI(1)
(%)
KPI(2)
(%)
% coverage (over total assets)(3)
(%)
Exposures not covered (% of assets covered
by the KPI)(4)
(%)
Exposures not covered (% of assets covered
by the KPI)(4)
(%)
Turnover-based
CapEx-based
Turnover-based
CapEx-based
Turnover-based
CapEx-based
Main KPI
Green Asset Ratio (GAR) stock
562,704
889,167
0.50%
0.80%
65.90%
41.50%
34.10%
Additional KPIs (5)
GAR (flow)
50,240
106,768
0.30%
0.20%
32.68%
0.00%
0.00%
Financial guarantees
90
1,049
0.006
0.07
Assets under management
112,646
65,852
1.40%
0.80%
(1) Fee and commission income other than from lending and asset management services. (2) Based on the Turnover KPI of the counterparty. (3) Based on the CapEx KPI of the counterparty. (4) % of assets covered by the KPI over the Bank’s total assets. (5) KPIs of fee and commission income and the trading book apply only from 2028.
The Group’s Green Asset Ratio (GAR) based on turnover of Customers amounted to 2.6% of assets covered by the KPI as at
31 December 2025. The GAR based on capital expenditure amounted to 3.6%.
Due to the change in the GAR calculation applied in 2025, including the exclusion from the denominator of assets that are
not subject to eligibility and alignment assessment under the Taxonomy (i.e. the new approach in line with the provisions
of Regulation 2026/73), the 2025 KPIs are not comparable with those for 2024, which amounted to 0.5% for the
turnover-based Green Asset Ratio and 0.8% for the capex-based Green Asset Ratio.
In addition, the increase in the GAR in 2025 was driven by a higher value of Taxonomy-aligned mortgage loans compared
with 2024, resulting from improved data quality and availability, including the use of the national register of building
energy performance certificates, as well as the shift away from an overly restrictive assessment of the EP.
The remaining tables required under Annex VI to Regulation 2026/73 are presented in Appendix 2. The Group’s full
Taxonomy disclosure for 2024 is available in the Management Board Report on the Activities of the BNP Paribas Bank
Polska S.A. Group for 2024, published on the Bank’s investor relations website.
.
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Own workforce (ESRS S1)
BNP Paribas Bak Polska S.A. (the Bank) recognises that engaged and satisfied employees are a key factor in ensuring a high
level of customer satisfaction. The Bank strives to create a work environment that supports the development of employee
competences, initiative and creativity, and that enables the testing of new solutions, including undertaking activities that
carry a risk of error.
To this end, the Bank promotes organisational values that include empowerment, collaboration, courage, simplicity and
transparency. Applying these values in everyday work strengthens the organisation’s ability to respond to changing market
conditions and contributes to the achievement of the Bank’s strategic objectives.
The Bank, together with its subsidiaries, forms the BNP Paribas Bank Polska Group (the Group), which is ranked sixth in the
Polish banking sector by total assets. The Group’s headcount expressed in active FTEs is 7.3 thousand.
Policies
To mitigate negative impact and risks, but also strengthen important opportunities, the Group has internal policies in place,
including: the BNP Paribas Group Code of Conduct (Code of Conduct), the Human Resources Management Policy, the Policy
on Dealing with Violations of Respect for Others, the Diversity Management Policy, the Employee Recruitment Policy, the
Employee Training and Development Rules, and the Employee Remuneration Policy. Descriptions of the policies are
presented in Table 93 below.
Actions
The Group describes the actions to support the material positive impacts, mitigate negative impacts and risks and
strengthen opportunities associated with the Group’s employees. These include the promotion of an inclusive
organisational culture, prevention of unequal treatment, discrimination, harassment and violence in the workplace,
ensuring social protection, prevention of psychosocial risks, measures for professional equality, social integration, and
development of competences.
Metrics and targets
The Bank is pursuing the goals that were implemented as commitments within the GObeyond strategy running from 2022.
In 2024, we started to prepare the business strategy for the next period and announced the Accelerate 2030 strategy for
2026-2030 in December 2025. The indicators presented in this chapter correspond to the Group’s employment data, as
well as all data relating to the working conditions of the Group’s employees (employment conditions, fair pay, social
dialogue, social protection, work-life balance, occupational health and safety) and equal treatment of employees
(professional equality, training and skills development, people with disabilities, diversity, prevention of violence and
harassment).
Strategy
Interests and views of stakeholders (ESRS 2 – SBM-2)
For the Group, employees are a key stakeholders group whose interests, views and rights must be integrated into the
Group’s strategy and business model. As a responsible employer, we ensure that the rights of employees are respected,
including those employed under an employment agreement and those in a relationship with the Group under other forms
of employment (contract, civil law contracts).
The Group has conducted a comprehensive impact assessment to identify material negative impacts that may affect its
employees, as well as risks and opportunities related to own workforce.
To achieve the strategic goals and objectives, a high level of alignment is required between the Bank’s strategy and the
Human Resources Area’s (HR Area’s) mission, which translates business requirements into expectations of employees. The
HR Area’s operating model, based on cooperation with HR Business Partners, is aligned and integrated with the Bank’s
business mode, enabling close collaboration with organisational units and business partners.
Attracting and retaining highly skilled employees, and effectively leveraging their capabilities, is a key factor in building the
Bank’s competitive advantage. Competent and proactive human capital management supports value creation for
stakeholders and enables the Bank to seize emerging market opportunities.
This is why the role of the Human Resources is to support managers in managing human potential and to continue to build
the Bank’s image as a good employer. For more information, see the section Interests and views of stakeholders (SBM-2).
Material impacts, risks and opportunities and their interaction with strategy and business model
(ESRS 2 – SBM-3)
As set out in the section: Description of the process to identify and assess material impacts, risks and opportunities (IRO-1),
the Group has identified a number of material impacts and risks related to its own workforce (see also Table 92).
The Bank, as a responsible employer, attaches great importance to the development of its employees, including those
employed in a form other than an employment agreement, and to provide them with a motivating working environment in
which everyone is treated with respect, dignity and on an equal basis. Violations result in a high probability of future losses,
mainly to the physical and mental health of employees and the proper functioning of the organisation as a whole. These
cover a wide range of situations, e.g. aggression, violence at work, sexual harassment, discrimination, etc.
Risks of the Bank’s liability may also arise if it fails to protect the health and safety of its employees. It is therefore
important to identify violations at the earliest possible stage and to take appropriate action to prevent them. Behaviour or
actions towards others that do not amount to discrimination or harassment may nevertheless be behaviour or actions that
do not comply with the Code of Conduct’s principles of respect for others.
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Unwanted behaviour, regardless of its form, must not be tolerated as it contributes to the deterioration of the working
conditions of the person who experiences them and the team in which they work. Any person providing services to the
Group has the opportunity to report violations without fear of retaliation.
The DMA process took into account information from internal and external stakeholders, including employees, NGOs,
Customers and investors. Material topics reported by stakeholders mainly concerned diversity and the need to build an
open organisational culture based on flexibility and development of skills. For more on stakeholder dialogue, see section
Interests and views of stakeholders (SBM-2).
The risk assessment was also based on an internal analysis of risks in the Risk ID tool related to employment, as reported
by the different business lines in which the Group operates, combining risk events and risk factors. Due to the nature of the
Group’s operations, there are no incidents related to forced labour or child labour.
Impacts identified by the Group
The material impacts include:
• Creating a friendly working environment, inclusion and diversity – Supporting actions aimed at preventing discrimination
and promoting an environment based on respect and equality. Activities focused on systematically improving working
conditions and strengthening employee well-being.
• Providing employees with development opportunities through access to training and upskilling programmes –
Strengthening social capital, employee competences and their position in the labour market through a broad range of
training. Providing employees with opportunities for professional development and supporting them in preparing for
future challenges.
• Discrimination, violence and mobbing at the workplace – Occasional cases of discrimination, harassment and violence at
the workplace.
Material risks identified by the Group
Based on the analysis of risk indicators conducted periodically in the BNP Paribas Group, material risks to the financial
results were identified:
• Psychosocial risks: recent changes in working methods, warfare in Ukraine, and a rapidly changing environment are likely
to increase pressure at work, which may be intensified by inappropriate behaviour by supervisors. These factors may have
consequences for the health of employees and include potential risks from unhealthy lifestyles, psychosocial risks and
possible job burnout.
• HR legal risks: the risk of HR processes failing to comply with applicable labour law regulations and with standards of
equal treatment and non-discrimination, which may lead to legal liability, employee disputes, and a negative impact on
the organisation’s reputation.
Opportunities identified by the Group
The Group focuses on opportunities and ensuring resilience against risks that may have a financial impact, including an
impact on strategic planning and risk management, but also a non-financial impact.
• Opportunities of gender diversity and work-life balance: promoting gender diversity, especially in the managing bodies
and senior management, as well as work-life balance initiatives: the Two Hours for Family/Human, Two Hours for Health,
Good Kilometres campaigns, the MyBenefit cafeteria system (cyclical points top-ups for employees), holiday subsidies for
employees and their children, Bank Close to the Family campaigns and activities – e.g. parent week, intranet page for
parents. By supporting an inclusive, sustainable and supportive working environment, we attract the best experts.
• Skill development opportunities: training and development programmes help to retain employees and support internal
mobility. Learning and development of new skills, promoting employee satisfaction and loyalty, helps to reduce external
recruitment costs for the Group. Our programmes enable the strengthening of employees’ skills in line with future needs.
In 2025, 89 topics were delivered in more than 240 sessions as part of the #MyWay training initiative. They were
attended by over 5,000 participants. This initiative includes an internal programme where 32 topics in 120 sessions were
delivered and 1,600 participants attended. The result of these activities is an increase in employment perspectives and
internal mobility of employees. All these elements contribute to an overall increase in the Group’s organisational
efficiency.
At the stage of conducting the DMA, it was not possible to quantify financially the opportunities listed above and therefore
they were not considered as material opportunities in the double materiality assessment process (see Table below).
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Table 92. Summary of material impacts and risks, and how they are addressed in our policies and actions
Category
Title of the material IRO
Policies
Actions
• Metrics
• Targets
Positive impacts
Creating a friendly working
environment, inclusion and diversity
• BNP Paribas Group Code of Conduct,
• BNP Paribas agreement on fundamental rights and
global social framework,
• BNP Paribas Bank Polska S.A. Diversity Management
Policy
• Employee Remuneration Policy
Diversity and inclusion initiatives,
Programme Dobrze
• Diversity metrics
• Work-life balance metrics
• Number of persons with disabilities in employment
• Incidents, complaints and severe human rights impacts
• Share of women in the Bank’s
Management Board > 30% (as of January
2026 – 42.9%)
Providing employees with development
opportunities through access to training
and upskilling programmes
• Rules of training and development for employees of
BNP Paribas Bank Polska S.A.
• Onboarding policy of BNP Paribas Bank Polska S.A.
Development offer of the central
programme #MyWay, language courses,
academies, re- and upskilling, university
programme fee refunds
• Training and skills development metrics
• eNPS [vs. 2021] -9 » 20 (2025) (employee
Net Promoter Score)
Negative impacts
Discrimination, violence and mobbing at
the work place
• BNP Paribas Group Code of Conduct
• BNP Paribas agreement on fundamental rights and
global social framework
• Policy of dealing with violations of respect for others
• BNP Paribas Bank Polska S.A. Diversity Management
Policy
• Employee Remuneration Policy
• Complaints and proposals on employee affairs –
instructions
• Whistleblowing Policy
• Anti-fraud Policy
Diversity and inclusion initiatives
Whistleblowing channels – reporting
discrimination, violence and mobbing
Corrective actions (disciplinary and
support measures, follow-up)
• Characteristics of employees
• Collective bargaining coverage and social dialogue
• Diversity metrics
• Adequate wages
• Number of persons with disabilities in employment
• Training and skills development metrics
• Work-life balance metrics
• Remuneration metrics
• Incidents, complaints and severe human rights impacts
• Health and safety metrics
• Eliminate sporadic incidents of
discrimination at work
• eNPS [vs. 2021] -9 » 20 (2025)
Risks
Psychosocial risk
• BNP Paribas agreement on fundamental rights and
global social framework
Programme Dobrze, Occupational Health
and Safety, whistleblowing system
• Characteristics of employees
• Health and safety metrics
• eNPS [vs. 2021] -9 » 20 (2025)
HR legal risk
• BNP Paribas Group Code of Conduct,
• BNP Paribas agreement on fundamental rights and
global social framework,
• Employee recruitment policy in BNP Paribas Bank
Polska S.A.,
• Employee Remuneration Policy,
• Diversity Management Policy in BNP Paribas Bank
Polska S.A.,
• Human resources management policy
RCSA (Operational Risk and Control Self-
Assessment), operational risk event
records RiskCare, KRI key risk indicators,
management training
• Characteristics of employees
• Incidents, complaints and severe human rights impacts
• eNPS [vs. 2021] -9 » 20 (2025)
• Monitoring the number of reports on
violations of respect for others and the
number of sanctions
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Managing impacts, risks and opportunities
Policies related to own workforce (S1-1)
The Group places particular importance on respecting human rights, ensuring safe and healthy working conditions, and
promoting diversity, equality and inclusion. Building a competitive advantage through the creation of diverse teams based
on collaboration, dialogue and knowledge sharing is a key element of the #TOGETHER strategic pillar. By fostering an
inclusive and safe working environment, we aim to strengthen employee well-being, prevent all forms of unequal
treatment and discrimination, and minimise risks related to health and safety.
The table below presents a summary of the key policies addressing the Group’s employees.
Table 93. Summary of key policies addressing employee issues
Policy*
Description of policy content
The scope of the policy and
its possible exclusions
The most senior level in the
organisation responsible for
implementation
Interaction with stakeholders
BNP Paribas Code of Conduct
The Code clarifies the responsibilities of all employees and managers in the spirit of the mission and values of the
BNP Paribas Group.
Group
Supervisory Board of the Bank
The Group Code of Conduct is available on the
Bank’s website and each BNP Paribas Group
employee is responsible for complying with it.
Physical Security Policy
in BNP Paribas Bank Polska S.A.
The Policy is an integral part of the Security Management System in BNP Paribas Bank Polska S.A., defines the
basic issues in the area of physical security and is the basis for the secure management of the Group’s activities in
the area of security of persons and its tangible and intangible assets.
Bank
Management Board of the Bank
Internal document available to employee on
the intranet, internal training
Policy on dealing with violations of
respect for others
The purpose of the Policy is to build employee awareness of the Code of Conduct’s principles of respect for others,
to prevent violations and to detect them at the earliest possible stage. The Policy further defines the ways in which
violations are reported, how they are dealt with and the range of possible sanctions for the offenders.
The procedure and form of actions taken at the Bank in relation to reported violations take into account the BNP
Paribas Group guidelines, while ensuring compliance with local laws, in particular ensuring the impartiality of the
persons carrying out these actions and the absence of conflicts of interest.
Group
Management Board of the Bank
Internal document available to employee on
the intranet
Whistleblowing Policy in BNP Paribas
Bank Polska S.A.
The regulation provides a procedure for the Bank’s internal reporting and aims to set out the principles, methods
of reporting of reasonable suspicions, without fear of retaliation following a breach notification. The whistleblower
is guaranteed that the alert will be treated with seriously, fairly and with full protection of personal data, including
data of the person who is the subject of the alert, third parties indicated in the report of a breach, and other
persons who appear in the content of the alert or during its analysis, e.g. the victim, witnesses of events.
Bank
Management Board of the Bank
Internal document available to employee on
the intranet
Diversity management policy in BNP
Paribas Bank Polska S.A.
The Policy sets out the Bank’s rules of conduct for managing the risk of discrimination in terms of respect for
diversity. The Policy takes into account the BNP Paribas Group’s principles and the DEI strategic axes defined
therein: professional equality between women and men regardless of gender; multiculturalism, diversity of origin;
disability; age and intergenerational diversity, sexual orientation and gender identity.
The Policy defines the role of employee networks.
Bank
HR Executive Director
Internal document available to employee on
the intranet
Contractor management policy in BNP
Paribas Bank Polska S.A.
The Policy describes the terms of cooperation with contractors to the extent necessary to conduct the Bank’s
business and describes the risks of cooperation with contractors and how to mitigate them.
Bank
Management Board of the Bank
Internal document available to employee on
the intranet
Rules for training and development of
employees of BNP Paribas Bank Polska
S.A.
The Rules describe the objective and procedure for planning and implementing development initiatives to improve
employees’ competences and for drafting of Individual Development Plans. A process for Contractors is also
described.
Bank
HR Executive Director
Internal document available to employee on
the intranet
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Policy*
Description of policy content
The scope of the policy and
its possible exclusions
The most senior level in the
organisation responsible for
implementation
Interaction with stakeholders
Onboarding policy in BNP Paribas Bank
Polska S.A.
The onboarding policy describes the rules, functions and stages of employee onboarding.
Bank
HR Executive Director
Internal document available to employee on
the intranet
Employee recruitment policy in BNP
Paribas Bank Polska S.A.
The recruitment policy contains a description of the rules and regulations according to which recruitment
processes are carried out in the Bank.
Bank
HR Executive Director
Internal document available to employee on
the intranet
Human Resources Management Policy
The Human Resources Management Policy is a set of principles and tools designed to ensure maximum support for
the Bank’s strategy by:
• ensuring an optimal workforce – attracting, retaining and motivating employees at the Bank, and
• ensuring fairness and transparency in the Bank’s people management policies.
All tools and processes in the Human Resources Management Area are designed to maximise their objectivity (they
are based on best market practices) and transparency – they are clear and widely known.
The general principles and guidelines described in the Policy are the basis to which other policies and regulations
of the Human Resources Management Area relate and on which further procedures and operational instructions
are based.
Bank
Management Board of the Bank
Internal document available to employee on
the intranet
Remuneration policy for Employees of
BNP Paribas Bank Polska S.A.
It ensures and defines transparent and uniform remuneration principles according to which employees
remuneration is awarded and paid. In 2025, the document was aligned with the principles implemented in the new
Collective Bargaining Agreement, in particular as concerns base salary (new job categories and salary grades).
Bank
Supervisory Board of the Bank
Internal document distributed internally and
communicated externally in the annual report
published on the Bank’s website
Remuneration policy for persons with a
significant impact on the risk profile of
BNP Paribas Bank Polska S.A.
In particular, it concerns:
• the principles for the identification of persons in the Bank and in the Bank’s subsidiaries who have a significant
impact on the risk profile and the principles of covering the Group’s employees by the Policy, as well as for
determining the basis (conditions) for obtaining variable remuneration and for acquiring the right to deferred
variable remuneration;
• the principles for determining the components of variable remuneration of persons with a significant impact on
the risk profile and its payment.
Group
Supervisory Board of the Bank
Internal document
*All employees are required to comply with the provisions of the policies.
Human rights
Social engagement
The Group:
• is committed to promoting respect for human rights across its entire sphere of influence and to treating all employees
with dignity; the Group maintains a strict prohibition on forced labour;
• specifically adheres to the ten principles of the UN Global Compact, the UN Guiding Principles on Business and Human
Rights, international human rights standards (as defined in the International Bill of Human Rights), and the fundamental
labour standards (as defined by the International Labour Organization);
• applies the most rigorous ethical and compliance standards, including anti-corruption, human rights protection and
environmental responsibility, regardless of the nature of its activities, drawing on the Code of Conduct and the BNP
Paribas agreement on fundamental rights and global social framework.
Given that the Group’s employees are predominantly highly qualified specialists working in the services sector, the risk of
modern forms of slavery and human trafficking has been assessed as very low.
BNP Paribas, through the BNP Paribas Group Code of Conduct, is committed to ensuring a motivating work environment in
which all employees are treated fairly and with respect, with particular emphasis on safeguarding employee dignity,
upholding the highest standards of professional ethics and rejecting all forms of discrimination.
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Furthermore, with regard to associates, the Group requires that suppliers employing such workers comply with the BNP
Paribas Sustainable Procurement Charter, which is based on the principles of the Universal Declaration of Human Rights
(UN, 1948) and the Fundamental Conventions of the International Labour Organization (ILO). The system ensuring
compliance with the Charter is described in the Group’s due diligence plan.
Last but not least, the Group provides employees with a whistleblowing system, including reporting channels and a
mechanism for raising concerns, available both to Group employees and to persons providing work under other forms of
engagement. More information is provided in the section: Processes to remediate negative impacts and channels for own
workforce to raise concerns (S1-3).
Occupational health and safety
In line with the BNP Paribas Group’s Code of Conduct, workplace safety (including during business travel) requires the
engagement of all employees in safety and protection efforts, as well as compliance with the Group’s internal policies. For
managers, this also includes striving to improve working conditions for their teams and reporting any actions that may
pose a risk to the physical safety of employees or external persons present on Group premises.
Employees of the Group and all persons present on its premises (interns, trainees, associates, subcontractors, Customers,
guests, etc.) are covered by a unified set of rules regarding personal safety and the protection of property. This framework
defines the fundamental principles relating to:
• security – risks associated with intentional or malicious acts that may harm individuals, assets or the Group’s operations;
• safety – risks arising from natural, climatic or technological events affecting Group locations, which may impact
individuals, assets or operations;
• business continuity and crisis management.
The functions responsible for safety and security form the foundation of a system designed to protect the Group’s
operations, resources and interests from safety and security incidents, based on continuous risk assessment.
Given the nature of the Group’s activities and the measures in place, the actual risks related to employee health and safety
are relatively low, and the number of workplace accidents remains very limited. The main health risks that may arise from
potential incidents relate to psychosocial factors and the effects of sedentary work. As a result, the Group has identified
mental health and issues linked to low physical activity as priority health areas under the Global Agreement and the
Group’s “Dobrze” health programme.
To ensure safe and comfortable working conditions, the Group fully complies with occupational health and safety
regulations (including, for example, rules on providing employees with corrective glasses or contact lenses for screen
work). The Group provides an ergonomic work environment and supports work-life balance. Mandatory initial and periodic
training on occupational health and safety is provided, and an e-learning course on workplace ergonomics is available to
all interested employees on the MyLearning training platform. These trainings aim, among other objectives, to prevent
musculoskeletal disorders and injuries.
The Group’s office spaces are equipped with facilities for employees, including persons with disabilities, as well as
relaxation areas and modern spaces that support teamwork. For employees with disabilities, assessments are carried out to
evaluate the adaptation of the work environment to their individual needs, enabling the implementation of appropriate
solutions.
The Bank has regularly organised first aid training for willing employees since 2022. To date, a total of more than 1,500
employees have been trained, with 189 employees in 2025. Another 20 employees of the Bank annually participate in a
Qualified First Aid refresher course.
Accidents
All workplace accidents are recorded in the accident register and in the RiskCare system. After each incident, an accident
report is prepared, containing conclusions and preventive recommendations. In addition, once a year the Occupational
Health and Safety Committee conducts a comprehensive analysis of accidents within the Group and, based on its findings,
implements actions aimed at raising awareness of workplace safety.
Occupational Health and Safety Days were organised in 2025, focusing on safety of employees who use a car for work,
reminding employees of the key principles of workstation ergonomics, informing them about changes to the reimbursement
rules for purchasing corrective glasses for screen work, and promoting safe sports activity. As part of Health Days,
employees were reminded how to respond in the event of sudden cardiac arrest and how to ensure cardiovascular
prevention, and those interested could register for first aid training.
The preventive activities of the Health and Safety Team prevent the occurrence of material negative impacts on employees.
In addition, periodic health and safety campaigns are organised to promote issues relating to safe work and healthy
lifestyles.
Diversity, equality and inclusion
The Bank promotes a work environment based on respect for diversity and the full utilisation of employees’ potential to
support the organisation’s development. A key principle is mutual respect, understood as adherence to the highest
standards in professional relationships, the rejection of all forms of unequal treatment and discrimination, and the
provision of a safe workplace where everyone can develop their skills and talents.
The foundation of an inclusive organisational culture relies on the values mentioned above, including transparency, courage
and collaboration. These values serve as a practical point of reference in both strategic and operational decision-making.
An additional tool supporting adherence to ethical and responsible business conduct is the BNP Paribas Group Code of
Conduct.
The Diversity Management Policy at BNP Paribas Bank Polska S.A. sets out the principles for identifying and mitigating the
risk of discrimination, and for promoting respect for diversity in the workplace. The Policy incorporates the BNP Paribas
Group guidelines set out in “Diversity, Equity and Inclusion Governance at BNP Paribas” and refers to the strategic DEI
(diversity, equity & inclusion) pillars defined therein:
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• professional equality between women and men,
• sexual orientation and gender identity,
• diversity of origin and multiculturalism,
• disability,
• age and intergenerational diversity.
Managing diversity and inclusion is one of the key elements in building an inspiring and development-oriented work
environment. For over a decade, the Bank has been a signatory of the Diversity Charter, an international initiative under the
patronage of the European Commission, committing organisations to counteracting discrimination and actively promoting
diversity. The Bank has also signed the BNP Paribas Agreement on Fundamental Rights and Global Social Framework, along
with the ILO Global Business and Disability Network Charter, confirming its commitment to respecting human rights in
business and to promoting diversity, gender equality, health protection and quality of life at work.
Oversight of compliance with diversity principles and coordination of activities in this area are carried out by a dedicated
person responsible for diversity and inclusion management, as well as by two Diversity Officers in the Bank’s structures.
Our diversity initiatives are subject to external evaluation. In 2025, for the seventh consecutive year, we were recognised
among the leaders (score above 80%) in diversity management in the Diversity In Check survey (formerly D&I Rating)
conducted by the Responsible Business Forum.
The Bank consistently promotes respect for diversity and an inclusive organisational culture, applying this approach both to
current employees and to candidates, in line with the Employee Recruitment Policy at BNP Paribas Bank Polska S.A. and the
standards applied in the onboarding process. The Bank actively supports employee-driven initiatives that promote gender
equality, equal parental rights, intergenerational dialogue, the inclusion of people aged 50+, persons with disabilities,
neurodivergent persons and the LGBT+ community. Regular activities are carried out to prevent unequal treatment and
discrimination and to promote DEI standards in the workplace. One of the key tools in this area is the Equal Treatment
Decalogue – “Notice differences, do not discriminate” – developed on the basis of the equal treatment perception survey
and serving as a set of principles aimed at counteracting discrimination, microaggressions and exclusion. The Bank also
organises recurring events that strengthen awareness and competences in the area of DEI, such as Diversity Days, Health
Days, “Health Starts in the Mind”, Parenting Days, Pride Month and Neuro-April.
Commitment to fair and equal treatment in HR processes
The Bank considers its employees a key factor in the organisation’s success. A professional approach to recruitment, based
on clearly defined criteria, enables the Bank to attract people with the competences necessary to achieve strategic
objectives. Recruitment decisions are made solely on the basis of objective, job-related criteria. The recruitment process is
grounded in clear job descriptions and defined competence requirements. One of the priorities is to fill positions, primarily
through internal recruitment.
Selection criteria are clearly defined and communicated transparently, and candidates are chosen based on an objective
assessment of their competences, in line with diversity principles. The Group’s companies ensure that all job postings, both
internal and external, are free from discriminatory criteria, and that the language used allows people of any gender to
apply. These principles apply to all types of employment contracts.
With regard to annual performance evaluation, the Human Resources Management Policy guarantees all employees equal
opportunities for professional development, based solely on skills, experience, performance and competences.
In line with the Remuneration Policy, the salary review process is based on the principle of equal treatment and on
transparent, consistent rules for determining remuneration.
Implementation of policies for incidents of unequal treatment and discrimination, mobbing and harassment, including
sexual harassment
Respect for employees’ dignity, boundaries and needs supports their integration, motivation and effective collaboration. It
builds trust, facilitates communication and helps resolve conflicts before they escalate into issues such as mobbing,
unequal treatment or discrimination. It is therefore a key element in preventing the most serious workplace violations. The
Bank has implemented the Policy on dealing with violations of respect for others, which sets out the rules for reporting
undesirable behaviours, the course of the investigation process and possible follow-up actions. The Policy guarantees
confidentiality and protection against retaliation for both reporting individuals and participants in the proceedings.
The Bank unequivocally recognises unequal treatment, discrimination and mobbing – including harassment and sexual
harassment – as unacceptable. All employment-related regulations comply with legal requirements, particularly those
concerning the prohibition of unequal treatment. Preventing undesirable behaviours includes preventive measures
(informational, educational and organisational) as well as corrective actions taken after violations are identified. The Bank
conducts awareness raising training to help employees understand which behaviours are unacceptable and why they
cannot occur in the workplace.
Good practices are promoted under the BNP Paribas Group Code of Conduct, including examples of behaviours that support
an inclusive culture free from discrimination and mobbing. These efforts aim to effectively prevent all forms of unequal
treatment.
Additional internal regulations against discrimination (in addition to the policies listed above in Table 92):
• BNP Paribas Bank Polska S.A. Work Rules,
• Rules of the Disciplinary Committee and rules of disciplinary proceedings in BNP Paribas Bank Polska S.A.
Processes for engaging with own workforce and workers representatives about impacts (S1-2)
Engaging with stakeholders who are impacted by the Bank’s activities and who impact its operations is a key element of the
due diligence process and of assessing the materiality of sustainability actions. The Bank conducts ongoing and transparent
dialogue with stakeholders, covering both day-to-day operations and the processes of identifying and assessing impacts,
opportunities, and actual or potential risks. As part of the due diligence process, the Bank, together with its employees and
their representatives, engages in matters that concern them or may concern them in the future. This dialogue with
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employees is based on several tools, whose description and quality assessment can be found in the section: Interests and
views of stakeholders (SBM-2).
This dialogue is overseen by the Bank’s Management Board, which is responsible for managing material impact, risks and
opportunities. Managers are responsible for ensuring employee engagement. The Organisational Culture Team (in
collaboration in the interdisciplinary Employee Voice Team) coordinates the collection of employees opinions. Managers
also have access to results of their teams’ weekly surveys (“Friday 6” Pulse Check).
The engagement of employee is assessed by analysing employee surveys and feedback, which is discussed by managers, HR
Business Partners and the Management Board.
In 2018, BNP Paribas Group and UNI Global Union signed an International Agreement covering seven areas of fundamental
labour rights, establishing a common framework of conduct for all Group employees. The Agreement was the result of
collaboration between HR teams from key Group entities and negotiations with trade unions. The Agreement continues BNP
Paribas’s long-standing tradition of social dialogue, previously reflected in three European agreements (on employment
management, gender equality, and the prevention of work-related stress). At the end of 2024, the Agreement was renewed
and will remain in force until the end of 2027.
Processes to remediate negative impacts and channels for own workforce to raise concerns (S1-3)
All Group employees are required to comply with the law and the standards set out in the BNP Paribas Group Code of
Conduct. When a negative impact on the Group’s employees is identified, we take appropriate corrective actions and assess
the effectiveness of the measures implemented.
Channels for reporting violations and handling employee issues
In its operations, the Group is guided by ethical principles and values that include, in particular, integrity, openness, mutual
trust, responsibility, transparency, professionalism and respect. These principles apply to all areas of the Bank’s activities,
regardless of their nature, and to all persons representing or cooperating with the Bank.
An integral part of the ethical framework is ensuring that employees can report suspected violations without fear of
retaliation. Employees who have experienced a lack of respect towards themselves or others should first report such
situations to their line manager or HR Business Partner. In cases where this is not possible, alternative reporting channels
are available, as defined in the Policy on dealing with violations of respect for others in BNP Paribas Bank Polska S.A.
Violations can also be reported through the channels listed in the Whistleblowing Policy at BNP Paribas Bank Polska S.A.
Such reports are dealt with in accordance with the standards set out in this regulation, ensuring confidentiality,
impartiality and protection of whistleblowers.
Handling reports
The Bank’s procedure for handling reported violations is aligned with BNP Paribas Group policies and applicable national
legislation. The Bank ensures the impartiality of individuals conducting investigations and eliminates the risk of conflicts of
interest. The principles of mutual respect form the foundation of the Bank’s organisational culture and should be reflected
in the decisions and actions of all employees. To ensure a safe and supportive working environment, the Bank expects
adherence to the highest standards of professional ethics and enables employees to report concerns about inappropriate
behaviour by colleagues in a confidential and secure manner. In such cases, the Bank promptly takes action to support
affected individuals, guided by responsibility and care for employees’ health and safety.
Every confirmed case of misconduct, regardless of the position of the person responsible, results in the application of
appropriate disciplinary measures. In addition, corrective recommendations are defined, and their implementation is
monitored.
Reports of violations are reviewed by the Employee Relations Team. Cases involving behaviours that may indicate mobbing
or discrimination – including harassment or sexual harassment – are referred to the Employee Conduct Standards
Committee. A report should include a description of the facts, including specific behaviours or actions that, in the reporting
person’s view, constitute a violation, as well as, where possible, evidence supporting the reported events and information
identifying the alleged perpetrator.
The Bank guarantees that every report will be examined thoroughly, fairly and with full confidentiality. Individuals who are
the subject of a report are afforded the presumption of innocence. At BNP Paribas, we do not tolerate any form of
retaliation against individuals who report violations in good faith or against those participating in the investigation process.
Employee effectiveness and trust assessment
The HR Compliance Team conducts regular reviews aimed at assessing the effectiveness of communication, the accessibility
of information and the functioning of reporting channels, as well as the quality of the process for analysing and handling
violations. When areas requiring improvement are identified, appropriate action plans are implemented, which may include,
among other measures, strengthening communication about the available channels for reporting irregularities.
Confirmed violations subject to investigation are reported in aggregate to the Bank’s Ethics and Conduct Standards
Committee. In addition, indicators related to violations are monitored quarterly in internal analytical systems available to
the Bank’s management, enabling ongoing assessment of trends and the identification of potential risk areas.
Code of Conduct, Diversity and Inclusion survey
In 2025, the Group conducted its third survey among all employees on the Code of Conduct and Diversity & Inclusion (the
survey is carried out every two years). The results of this year’s edition confirm employees’ strong commitment to the
organisation’s core values and principles of ethical conduct. The main indices – the Conduct Index and the DEI Index –
achieved high scores, exceeding 89%. A total of 94% of respondents declared that they are familiar with and apply the
principles of the Code of Conduct, while 92% confirmed awareness of the available channels for reporting inappropriate
behaviour. 94% of employees stated that the management team applies the Code’s principles in their daily work. More than
90% positive responses were recorded in areas related to the sense of fair treatment and respect, regardless of the various
dimensions of DEI.
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Taking action on material impacts on own workforce, and approaches to mitigating material risks and
pursuing material opportunities related to own workforce, and effectiveness of those actions (S1-4)
The Bank implements a range of measures aimed at preventing, mitigating and remedying potential and actual negative
impacts on employees, as well as effectively managing material social risks and opportunities. As part of building an
inclusive organisational culture, the Bank undertakes activities to prevent discrimination and promote equal treatment. The
policy of respect for others is based on raising employee awareness, providing training and maintaining safe channels for
reporting irregularities. The purpose of these measures is to prevent cases of discrimination, mobbing, harassment and
sexual harassment, and to ensure an effective response when such situations occur.
The Bank also implements initiatives that support the protection of employees’ mental and physical health, including a
broad range of benefits and the “Dobrze” well-being programme. To identify and mitigate psychosocial risks, psychological
support programmes and mental health training are provided. In addition, the Bank ensures good and flexible working
conditions that support work-life balance and allow employees to adapt their work arrangements to their individual needs.
The Bank actively promotes work-life balance and encourages employee volunteering (more information in the POSITIVE
Pillar, section: BNP Paribas Foundation).
Most of the implemented measures are short-term in nature, as they form an integral part of the annual processes and
cycles carried out by the HR Area. These include employee opinion surveys, training activities, performance reviews,
remuneration review processes, internal mobility, and initiatives related to health prevention and well-being in the
workplace.
A diverse and inclusive workplace
Preventing and mitigating the negative impact of exclusion and the risk of litigation related to discrimination and unfair
treatment
The Bank has for many years consistently developed an inclusive organisational culture that fosters creativity, supports
innovation and encourages openness to new ideas, markets and Customers. This approach strengthens our competitive
advantage while creating conditions that support employee development and contribute to the success of the entire
organisation.
Everyday collaboration is built on trust and respect. We strive to ensure that each employee can fully express themselves,
pursue their professional aspirations and passions, feel appreciated and have a genuine sense of influence on how the
organisation operates.
Corrective actions and effectiveness monitoring
Regular employee opinion surveys confirm the effectiveness of the Bank’s efforts to build an inclusive work environment. In
the most recent edition of the survey, 88% of employees declared that they can be themselves and feel accepted. A total of
89% of respondents believe that everyone has equal development opportunities regardless of diversity characteristics, and
around 92% confirmed that their manager treats all employees fairly, with dignity and respect.
Employee-led networks supporting individuals from groups potentially exposed to unequal treatment play an important
role in strengthening a values-based, respectful and inclusive organisational culture. In cooperation with these networks,
the Bank implements numerous initiatives available to all employees, promoting diversity and inclusion in the workplace.
In 2025, the Bank continued its regular educational and communication activities covering various aspects of DEI, including
campaigns, on-site events, meeting series, webinars and workshops, such as:
• Health Starts in the Mind – mental-health education,
• Diversity Days – a BNP Paribas Group initiative promoting DEI in every country, adapted to the local social context,
• Health Days – educational and preventive activities related to physical and mental well-being,
• Parenting Days – developing parental competences,
• Neuro-April – education on neurodiversity,
• Pride Month – initiatives supporting the LGBTQ+ community and promoting equal treatment.
Representatives of the Bank also actively participated in the work of the DEI Committee at the Polish Bank Association.
Following the publication of the report “Diversity Management in Commercial Banks” in the previous year, in 2025 we
co-created another sectoral publication – the report “DEI Good Practices in the Banking Sector”.
Respect for people: preventing unequal treatment, discrimination, harassment and violence at the workplace
Preventing and mitigating material negative impacts and risks of discrimination and violence at the workplace
Awareness-raising activities that help employees identify and effectively respond to potential violations – thereby
preventing their escalation – include, among others:
• regular reminders of the rules applicable in this area, along with examples of behaviours covered by the regulations,
• indicating the available channels for reporting violations,
• emphasising the importance of employees reporting any situations that raise concerns, as well as the role of providing
testimony during investigation processes, and ensuring protection for reporting individuals.
Managers have special responsibilities under the Code of Conduct to respect others, including:
• leading by example by complying with the highest ethical standards,
• creating an environment fostering open and honest communication,
• encouraging discussion of ethics and integrity in business decisions,
• regularly supporting employees and motivating them to raise any concerns without fear of negative consequences.
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Steps in the violation reporting process
All employees, especially those in managerial positions and those working in the HR Area, must be sensitive and vigilant to
any professional situation that may lead to inappropriate behaviour relating to the Code of Conduct on respect for others.
All reports are analysed with the necessary seriousness, integrity, fairness and discretion.
Steps in processing reported violations:
• Reporting violations – An employee who believes that he or she or another employee has experienced a violation may
make a report through the reporting channels available under the Policy on dealing with violations of respect for others
in BNP Paribas Bank Polska S.A.
• Preliminary analysis of the report conducted by a dedicated team – on its basis, a decision is made regarding further
consideration of the report and the mode in which it will be processed.
• Investigation – individual interviews are conducted with the persons involved, i.e. the reporting person, potential offender
and witnesses, as well as analysis of additional documentation provided by those involved.
• Final document – preparation of a document containing the findings made and recommendations for further action in the
case under consideration by the investigating team.
Sanctions
If the investigation confirms inappropriate behaviours or situations requiring intervention, the Bank takes appropriate
actions towards all individuals concerned, including disciplinary measures. Decisions regarding sanctions are made by the
Disciplinary Committee, based on the provisions of the Labour Code and internal regulations, taking into account the
severity of the breach of employee duties.
Corrective actions and monitoring of effectiveness:
• The affected individual receives support from their manager and HR representatives, as well as – if needed – medical,
psychological and social assistance. Guided by responsibility and care for employees’ health and safety, the Bank also
implements measures to prevent similar situations from occurring in the future.
• In 2025, the Bank reviewed 17 reports, one of which – due to the nature and seriousness of the allegations – was referred
to the Employee Conduct Standards Committee.
• Individuals responsible for inappropriate behaviour faced consequences proportionate to the confirmed violations, while
affected employees received the necessary support.
Social protection benefits
Preventing and minimising potential negative impacts on social protection
As part of the Lux Med health care programme, the Bank finances a medical care package for employees (those employed
at least 0.3 FTE). Employees can choose from several variants of benefit packages, each differing in the scope of available
services.
The Bank’s benefit offers include:
• Employee Capital Plans,
• financial and insurance benefits: life and accident insurance for employees and their relatives (also for part-time and
temporary employees),
• additional insurance for school-age children,
• discounts on travel insurance, hull and third-party liability automobile insurance,
• additional insurance packages, including oncology and cardiology packages,
• holiday subsidies for the employee and holiday subsidies for the employee’s children from the Company Social Benefits
Fund,
• financial assistance from the Company Social Benefits Fund (also for part-time and temporary employees).
Health and well-being:
• Lux Med healthcare programme for employees and their relatives (also for part-time and temporary employees),
• MultiSport Plus cards (employee, companion, children: Kids, Kids Aqua, Student, Senior),
• Worksmile application, which supports physical activities and integrates employees around their passions,
• Health Days for Group employees, which promote a healthy lifestyle (webinars on healthy eating, body composition
analysis, relaxation sessions, office exercises),
• flu vaccination,
• vouchers for preventive examinations (cancer prevention, mental well-being, heart and vascular diseases).
Actions taken and planned
The Bank has implemented initiatives and measures aimed at improving employee well-being and social protection.
Indicators related to the use of maternity, paternity and parental leave are monitored on an ongoing basis, enabling the
Bank to assess the effectiveness of existing solutions and identify employee needs.
In 2024, in cooperation with representatives of the trade unions operating within the Bank, amendments to the Collective
Bargaining Agreement for employees of BNP Paribas Bank Polska S.A. were agreed. These changes entered into force on 1
January 2025 and include, among others, the extension of employee entitlements related to childcare and support in
life-event situations. The new provisions introduce, among others, the right to:
• up to two weeks of leave, under rules equivalent to paternity leave (no later than until the child reaches 12 months of
age), available to an employee – regardless of gender – who does not hold parental authority but provides actual care for
the child,
• special-leave days in situations such as the birth of a child, a child’s wedding or the need to provide care for a child
under 14 years of age – also for employees in informal relationships (regardless of gender) and for employees who do not
hold parental authority but provide actual care for the child,
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• an additional day off for job-seeking in the event of termination of employment for reasons not attributable to the
employee.
Corrective actions and effectiveness monitoring
The Bank monitors employee needs and well-being, among others through regular surveys assessing the benefits offering
and well-being programmes. The insights gathered serve as a basis for tailoring actions and solutions to the real
expectations of employees.
In 2024, a survey was conducted regarding the benefits offering and the “Dobrze” well-being programme. The results made
it possible to define strategic directions and prepare action plans addressing the identified needs. The implementation of
these measures continued throughout 2025.
Psychosocial risk detection and corrective actions
Concern for the mental and physical health of employees
Programme “Dobrze”
The Bank actively supports employee well-being by creating a work environment that promotes health and overall well-
being, as well as business effectiveness. We care for employees’ mental and physical health, including protection against
the effects of occupational stress, and we implement flexible work arrangements and organisational solutions that reduce
the risk of overload and support efficiency.
We build a well-being oriented work environment through:
• regular surveys and ongoing monitoring of employee well-being, followed by data-driven actions aimed at improving
working conditions and overall well-being,
• education on mental and physical health delivered through the well-being programme, including workshops and training
on healthy lifestyles, stress management, burnout prevention and mental and physical self-care,
• providing continuous psychological support, including access to specialists and therapists, a psychological support and
anti-burnout helpline, and programmes that help employees cope with stress and other mental health challenges,
• encouraging physical activity, supported by the Bank’s Sports Sections, which promote regular exercise and integration
through sports,
• promoting a healthy lifestyle and encouraging employees to take care of their health through educational and preventive
initiatives.
Annual health-related initiatives:
• “Health Starts in the Mind” – an event dedicated to building awareness of mental resilience and mental health care,
• Health Days – an initiative promoting health prevention, including educational activities (webinars), stress reduction
sessions and vouchers for additional preventive examinations.
The Bank offers employees an attractive range of benefits and opportunities to take care of their health, develop sports
skills and pursue their passions. The benefits offering has been designed so that employees’ family members can also
benefit from it. The number and wide scope of available options allow employees to tailor the benefits to their individual
needs.
Process of action identification to prevent material risks, corrective actions and their effectiveness
Managers play a key role in preventing psychosocial risks by recognising early signs and taking appropriate action. Through
daily collaboration with their teams, they are able to notice unusual or concerning changes in employees’ behaviour, mood
or attitude. To support them in this responsibility, the Bank provides educational initiatives for managers – including
webinars and e-learning courses – and offers materials on topics such as mental health crises, burnout, working with
persons with disabilities and neurodivergent employees. The Bank also provides dedicated psychological support channels
for managers, taking into account the specific challenges of leadership roles in difficult or crisis situations.
Corrective actions focus on analysing identified manifestations of psychosocial risk and implementing appropriate
interventions. The Bank uses employee feedback – including comments from engagement surveys and regular pulse checks
– to respond quickly to emerging signals and needs.
The Bank ensures that managers have continuous access to information about the situation within their teams through
dashboards that include key HR risk indicators such as absenteeism, leave usage, overtime and turnover. Managers also
receive analyses of the results of the regular Pulse Check engagement survey and the weekly Friday 6 satisfaction surveys.
This enables them to identify concerning trends in real time and respond to signals indicating a potential decline in
employee well-being.
Professional equality actions
Actions on taking advantage of gender diversity opportunities
The Bank consistently fosters a culture of courage, empowerment and diversity, treating it as a foundation that supports
effectiveness, creativity and employee engagement. In close cooperation with employee-led networks, numerous initiatives
are carried out to strengthen various dimensions of diversity and inclusion.
In 2025, the Bank had six employee networks:
• “Women Changing BNP Paribas” – a network supporting the development of women,
• “Dad, You’ve Got This” – a network for fathers,
• “BNP Paribas PRIDE Poland” – supporting the LGBT+ community,
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• “Wiek Agawy” – focused on employees aged 50+ and intergenerational dialogue,
• “OZNacza mogę” – bringing together employees with disabilities and their allies,
• “Neuronauts” – focusing on neurodiversity.
Together, we carried out numerous diversity and inclusion initiatives, strengthening an organisational culture rooted in
equality and enriched by diverse perspectives.
Gender equality initiatives to promote equal opportunities for women and men
• reducing the gender pay gap by ensuring equal opportunities for promotion, access to talent and development
programmes and by setting specific gender-balance targets at all levels of the organisational structure, while
implementing a transparent remuneration policy focused on equal pay for equal work and performance,
• the marketing campaign “One Word Is Enough”, promoting the use of feminine forms in Polish as a tool for counteracting
stereotypes and supporting gender equality,
• partnership with the Share the Care Foundation and implementation of the projects “Equal at Home, Equal at Work”,
“Proud to Be a Working Mum” and “Facet na 100 pro”,
• cooperation within the #WiedzaNieMaPłci initiative, aimed at strengthening the presence of women experts in public
debate and reducing disparities in the media,
• partnership in the programmes “Sukces To Ja”, “Co z tą kasą” and in the Businesswoman of the Year competition
organised by the Sukces Pisany Szminką Foundation,
• supporting the initiatives of 30% Club Poland, #JamaisSansElles and the Champions of Change Club,
• partnership in the Women in IT Day events organised by Future Collars,
• implementation of proprietary development programmes run by the Women Changing BNP Paribas network, such as
Women UP and the Future UP mentoring programme (recognised in the “Super M” competition in the Business category
in 2025, and a finalist in 2024).
Parenting initiatives
• Parenting Days is a recurring event during which children have the opportunity to visit their parents’ workplace and take
part in a variety of workshops promoting values important to the Bank and aligned with the Sustainable Development
Goals. In 2025, the programme included, among others, first aid classes, financial education, survival skills, ecology, AMP
football workshops and activities using new technologies (VR). A dedicated space was also prepared for neurodivergent
children, with therapeutic support provided. Employees could develop their parenting competences through webinars,
workshops and expert sessions covering topics such as relationships with teenagers, adoption, autism spectrum and
ADHD diagnostics, school-related challenges and financial education.
• Partnership with the Share the Care Foundation, which promotes equal sharing of childcare responsibilities and supports
the development of engaged fatherhood. The Bank participated, among other activities, in the Foundation’s international
conference “Equal at home – equal at work. How to effectively support parents in balancing family and work life?”.
• Parenting consultations (parental support) available as part of the “Dobrze” well-being programme.
Initiatives to promote equal opportunities for people with disabilities
• the educational campaign “Different Abilities, One Goal” and a dedicated intranet space,
• the interview-based film series “People with Experience”, featuring conversations with employees living with disabilities
or health challenges, who share their stories with the Bank’s community,
• awareness raising activities, including a meeting with the film makers and a screening of the film “Szczęście Agaty”,
workshops with Sebastian Grzywacz (“Odlotowy Niewidomy”) and Małgorzata Szumowska (“Invisible Exhibition”), as well
as the immersive experience “Cinema You Cannot See”,
• training for managers on the inclusion of employees with disabilities,
• a savoir-vivre guide for interacting with persons with disabilities,
• support for employees in obtaining disability certificates and other benefits, including a webinar organised in cooperation
with the OZNacza Mogę network,
• a dedicated role responsible for disability inclusion and a dedicated position within the recruitment team,
• partnership in Incluvision by the Aktywizacja Foundation, aimed at facilitating labour market access for persons with
disabilities. The Bank is the main partner of the 3rd Inclu(vi)sion Congress and the virtual job fair for persons with
disabilities.
Initiatives to promote equal opportunities for neurodivergent persons
• the awareness campaign “A Different Look at a Different Look” on neurodiversity, including webinars, educational
materials and a dedicated intranet space,
• “People with Experience” testimonials focused on neurodiversity – including the story of an employee with ADHD and
their collaboration with a manager, as well as the perspective of a parent of an adult on the autism spectrum,
• a guide for managers on effective collaboration with employees on the autism and ADHD spectrum, prepared by the
Neuronauts community, along with dedicated expert psychological support for managers of neurodiverse teams,
• webinars and educational workshops on autism and ADHD, covering diagnostic aspects and forms of support, as well as
educational activities for parents and caregivers of neurodivergent children,
• cooperation with the AsperIT Foundation, including post-audit implementations and obtaining the certificate
“Neurodiversity-Friendly Workplace 2025–2027”,
• sharing the Bank’s good practices, including SWPS postgraduate studies, the JIM Foundation report, the NeuroShow event,
and initiatives by Top Employers and Orange.
Initiatives to support the LGBT+ community
• International Conference “BNP PARIBAS GLOBAL LGBT+ BUSINESS CONFERENCE” at the head office in Warsaw with
representatives of 17 countries, NGOs and businesses (Lambda, Open For Business, Orange PL, Ikea, CD Project, Love
Doesn’t Exclude, Us Parents, Warner Bros Discovery), Pride Parade in Warsaw,
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• implementation of a guide on serving non-heteronormative/LGBT+ people as Bank customers,
• participation in the Love Doesn’t Exclude association’s “Business Doesn’t Exclude – Here You Can Be Yourself” campaign,
cooperation with the Rainbow After the Storm Foundation, which offers psychological support for people from the LGBT+
community, and partnering with the Us Parents Association and the All Inclusive Festival (Sailor Cinema Foundation).
Initiatives to support age diversity
• education on the topics of diversity and inclusiveness in the area of age diversity around the report “Generations:
differences or similarities. From stereotypes to synergy”; Dynamic conversations on intergenerational topics delivered in
cooperation with the Off School Foundation; Intergenerational management in practice; initiatives on menopause and
andropause.
The Bank places strong emphasis on the genuine implementation of diversity principles, including ensuring appropriate
representation of women in statutory bodies. As at 31 December 2025, women accounted for 50% of the Supervisory Board
and 37.5% of the Management Board. Compliance with diversity principles is monitored not only at the level of the Bank’s
governing bodies but also across managerial positions. At the end of 2025, women held 45% of the top management
positions within the Group.
Social engagement
“You Can Count on Me” is the motto of the employee volunteering programme that the Bank has been running continuously
since 2011. A detailed description of the initiatives can be found in the POSITIVE Pillar, in the section: BNP Paribas
Foundation. Employee volunteering activities are also part of the BNP Paribas Group’s international initiative
#1MillionHours2Help, coordinated in Poland by the BNP Paribas Foundation.
These initiatives strengthen employee well-being, build engagement and support long-term retention within the Group.
Employee development
Action intended to take advantage of important skills development opportunities
The Bank is developing a competent organisation capable of effectively implementing its business strategy and building
long-term value. We invest in the development of leaders, talents, experts and all employees, responding to key
competence needs.
A central element of our development policy is strengthening effective leadership in line with the BNP Paribas LeaderUP
competence model. Competent leaders drive organisational growth, and the model promotes behaviours that support
strong business performance and a positive work environment. Leaders benefit from a wide range of development activities,
including webinars, workshops and individual consultations. The Bank also offers the Leader Development Academy
(NewBorn Leaders) – a programme dedicated to employees beginning their managerial path. For senior management,
Stronger Together events are organised on a regular basis.
Creating a continuous development culture
To ensure that the organisation has competent employees and is prepared for future challenges, the Bank consistently
develops a culture of lifelong learning. This culture is supported through reskilling and upskilling programmes and through
a mechanism of employees’ individual responsibility for personal development. Each employee creates an Individual
Development Plan that defines the scope and timeline for acquiring new competences.
The Bank provides access to a wide range of training courses and webinars. In addition to mandatory job-specific training,
delivered mainly in e-learning format, employees can benefit from an extensive package of individual training opportunities
as well as co-funding for foreign language learning and university programmes. In 2025, as part of development activities,
our employees filled 25,445 places across various training groups. We are also open to individuals who are just beginning to
shape their professional path. The Bank’s summer internship programme is dedicated to students who have completed at
least their second year of studies.
For employees who are leaving the Bank, we offer programs to help them find their way on the labour market: an
outplacement programme offering support in finding a job, defining a professional profile, assistance in preparing a resume,
preparing for a job interview.
Other training initiatives in 2025 in the Bank included:
• re-skilling and up-skilling programs: 3rd Lean Green Belt – 26 participants, Innovative Thinking – 61 participants,
• Digital Academy – a long-term up-skilling programme focused on developing knowledge and skills for working with AI.
More than 1,000 participants joined individually dedicated paths, 8 topics in 14 training sessions were implemented.
More than 1,000 participants used the AI knowledge library (e-learning training, videos, ebooks), 37 employees
participated in the #EngineAI 2.0 path. A total of 13 use cases aimed at optimising business processes were developed.
• #MyWay – more than 5,000 participants, 89 topics were implemented in 240 sessions,
• #MyWay internal expert community – more than 1,600 participants, 32 topics were implemented in more than 120
sessions,
• UniversITy – development programme delivered by internal experts, mainly NTCS experts, on high technology – more
than 1,600 participants, 27 topics were implemented in 40 sessions,
• Women Up development programme – 90 participants, Future UP mentoring programme – 140 participants, within the
‘Women Changing BNP Paribas’ employee network.
In 2025, the local edition of Career Days at BNP Paribas Bank Polska S.A. was held under the slogan “Developing your
career at the Bank is a #gooddecision.” The main objective of the events organised as part of Career Days was to increase
employees’ awareness of and engagement in their professional development by exploring opportunities for internal
mobility. We encouraged employees to actively manage their careers, learn about the various development paths available
within the organisation, and build the competences needed to transition into new roles within teams, as well as across
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teams, departments and/or BNP Paribas Group companies. Five events brought together more than 400 participants in
total.
One of the key target groups for investments in competences are Talents who are ambassadors of change and innovation.
We carry out development activities for our employees and leaders identified as high potential. Those identified as ‘Leaders
for Tomorrow’ participate in the international training offer prepared by BNP Paribas’ EM Talent Development. Emerging
LFTs (40 persons) joined a 10-month local development programme ended in June 2025. In December, we launched a local
programme for the Advanced group. We invited 42 participants to join, and the programme is scheduled to run until
September 2026.
Training: ESG
The Bank continuously strives to increase employees’ awareness of the sustainable transition. In 2025 an ESG e-learning
course mandatory for all Bank employees was launched. 7,052 people completed the training. More information on ESG
education can be found in the section Transition resources.
The Bank’s firm goal is to remain a leader in sustainable finance and a partner in supporting the sustainable development
of the economy. We build a Sustainability Community which offers the chance to gain a deeper understanding of current
challenges and to translate the knowledge gained into practical action for change in the organisation and the environment.
Sustainability Officers initiate and implement sustainability activities in individual areas and business lines.
Development at work
The AboutMe platform, which serves employees, managers and HR in managing career paths, is aimed at:
• declaring skills by employees, through which a range of programmes, training and resources are built to support
professional development. In 2025, 5,322 i.e. 72.4% of employees (of which about 65% are women) declared their skills on
their profile in AboutMe,
• supporting employees in their development and professional improvement,
• improving interaction between employees, managers and HR, facilitating internal mobility,
• conducting an annual professional evaluation process.
Internal mobility and the career-path system are important elements of the positive employee experience in the Group.
This mechanism is based on diagnosing individual strengths, predispositions and talents, which helps employees make
informed decisions about their professional development and set short- and long-term goals. The Bank supports employees
by providing tools and development activities that enable them to identify their potential and build their career paths
accordingly. These paths cover a variety of roles and specialisations, allowing employees to plan their development in line
with their aspirations while taking into account the needs of the organisation. The Bank identifies competences that are key
from the perspective of the strategy and individual business areas, preparing employees – through upskilling programmes
– for the professions of the future. As a result, people working at the Bank can shape their career paths in line with market
trends, technological advancements and the evolving business environment.
The internal job market and internal mobility are key pillars of career management, aligning the organisation’s needs with
employees’ development expectations.
The Bank encourages employees to pursue internal mobility by promoting job opportunities available within the Bank and
across Group companies through internal communications and a dedicated page on Echonet. Internal job postings are
communicated transparently within the Group, together with clearly defined criteria expected from candidates for each
position. Internal promotions are preferred, giving employees priority in recruitment for new roles. This approach aims to
retain and develop talent within the organisation and to strengthen a culture of loyalty. Employees play a proactive role in
their mobility, supported by their managers and HR, who encourage development through taking on new professional roles,
both within the current business area and in other parts of the organisation or Group companies.
Resources used to manage material impact
The role of the Human Resources Management Area is to support managers in managing the Bank’s human potential and
building the Bank’s image as an employer.
The HR strategy focuses on attracting and retaining the “best” employees, building strong and long-lasting relationships
with these employees through a fair offer that takes into account solid opportunities for self-development, and matching
the employee’s individual needs and ambitions with the Bank’s needs and goals.
The sum of employee and managerial behaviour creates the organisation’s culture that enables the Bank to achieve and
maintain a competitive advantage and realise its planned growth.
Metrics and targets
Targets related to managing material negative impacts, advancing positive impacts, and managing
material risks and opportunities (S1-5)
Our key goal is to continually build an organisation that is an exceptional place to work attracting the best candidates from
the labour market, fostering motivation and efficiency among employees. Only committed and effective employees,
managed by exceptional leaders, acting in the spirit of agile and in accordance with the values of the organisational culture
will allow us to ensure market success.
We want to achieve this through the continuous development of leadership skills future skills among our employees,
allowing them to find their way and continuously develop in today’s digital and changing times. A high standard of
leadership and qualified employees equipped with core competences and the values of the organisation are the basis for us
to create an exceptional workplace. All of this, supported by efficient and digitised HR processes, attractive employee
offerings and development opportunities, gives a complete picture of the organisation we are building.
We make sure that strategic targets are consistent with team and individual targets. That’s why we start the target-setting
process with the approval of business targets by the Supervisory Board for the Management Board. We practise cascading,
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that is, translating strategic targets into targets for individual structures, and at a later stage, during meetings between
supervisors and employees, into targets for individuals.
HR’s main goal in managing the employee experience is to create a work environment in which every employee feels
listened to, valued, and has a real impact on shaping the Bank’s organisational culture and processes. This approach allows
us to act comprehensively and focus on all aspects of employees’ working lives, from recruitment to departure. The
measures taken are aimed at increasing employee engagement and job satisfaction.
Employees experience management is implemented in the following areas:
• Building a culture of openness, trust and respect – creating an environment in which employees can be themselves, feel
safe, and freely share their opinions, ideas and concerns, with open communication serving as a foundation of
organisational success.
• Embedding the employee voice in strategic decisions – implementing solutions that enable the systematic inclusion of
employee experience in shaping strategy and making key decisions.
• Stimulating innovation and continuous improvement – using employee feedback to identify areas for improvement and to
implement new, effective solutions.
• Increasing engagement and satisfaction at all levels of the organisation – regularly monitoring engagement and
satisfaction levels and taking actions aimed at strengthening them.
These dimensions translate into concrete actions:
• Defining, describing and measuring employee experience – to create a satisfying and engaging work environment at every
stage of employment.
• Regular engagement and satisfaction surveys – conducting cyclical surveys whose results are systematically analysed,
enabling the identification of key trends and areas for improvement.
• Monitoring current sentiment – running short, weekly pulse surveys that allow for quick responses to emerging needs.
• Strengthening a feedback culture – promoting regular, constructive feedback as a natural element of collaboration.
• Enabling employee voice surveys on topics of strategic importance from the Bank’s perspective.
All planned commitments to a diverse and inclusive workplace were delivered:
• 37.5% participation of women in management positions,
• reduced adjusted pay gap,
• increased employment of people with disabilities,
• regular monitoring of key diversity and inclusion metrics,
BNP Paribas Group’s regular survey on the Code of Conduct and diversity and inclusion,
continuous support for grassroots employee initiatives for groups at risk of exclusion.
Table 94. Strategic indicators on social responsibility
Pillar
Strategic indicator
Target
2025
Implementation
2025
Social responsibility
Participation of women on the Bank’s Management Board [vs 2021: 22%]
30%
37.5%
Reduction of the adjusted pay gap between women and men [vs 2021: 7.3%]
<4%
3.7%
eNPS – employee Net Promoter Score [vs 2021: -9]
20
20
Characteristics of the undertaking’s employees (S1-6)
The tables below include all active employees of the Group hired under a fixed-term contract of employment (FTC) or a
permanent contract of employment (PTC) in the Bank or one of the subsidiaries. The following data does not include
employees employed in technical positions, i.e. those employed at 0.05 and 0.063 FTE. Employees working in a minimum of
two companies are counted once. Tables include data as at 31 December 2025.
Table 95. Employment by gender
Gender
2025
2024
Number of
employees
Number of FTEs
Number of
employees
Number of FTEs
Women
4,576
4,562
4,778
4,761
Men
2,679
2,667
2,734
2,717
Total
7,255
7,229
7,512
7,478
active employees without technical and duplicate positions within the Group
As at 31 December 2025, the Group employed 7,255 people. Compared with 2024, the number of employees decreased by
257 (i.e. by 3.4%). As at the end of 2025, 63% of the Group’s employees are women and 37% are men. All Group employees
are employed in Poland.
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Table 96. Employees by contract type
Form of employment
2025
2024
Women
Men
Total
Women
Men
Total
Total employees
Number of employees
4,576
2,679
7,255
4,778
2,734
7,512
Number of full-time
positions
4,562
2,667
7,229
4,761
2,717
7,478
Permanent employees
Number of employees
4,056
2,387
6,443
4,185
2,418
6,603
Number of FTEs
4,042
2,376
6,418
4,172
2,403
6,575
Fixed-term employees
Number of employees
520
292
812
593
316
909
Number of FTEs
519
291
810
589
314
903
active employees without technical and duplicate positions within the Group
The vast majority of employees are employed under permanent contracts (almost 89%), similar to 2024.
Table 97. Employees by contract type
Type of contract
2025
2024
Women
Men
Total
Women
Men
Total
Total persons employed
Full-time contract
4,531
2,649
7,180
4,719
2,696
7,415
Part-time contract
45
30
75
59
38
97
active employees excluding technical and duplicate positions within the Group.
In 2025, 75 employees were hired in part-time (approximately 1% of the Group’s workforce), compared to 95 in 2024.
Table 98. Leavers
2025
2024
Women
Men
Total
Women
Men
Total
Total number of leavers
Voluntary leavers,
including retirements
and others
383
234
617
472
258
730
Dismissal
260
130
390
287
120
407
active employees excluding technical positions and duplicates within the Group.
Table 99. Turnover
2025
2024
Women
Men
Total
Women
Men
Total
Turnover by employees
12.7%
13.3%
12.9%
14.4%
13.6%
14.1%
Turn-over by FTEs
12.7%
13.2%
12.9%
14.4%
13.6%
14.1%
Voluntary turnover by
employees
7.6%
8.6%
7.9%
8.9%
9.3%
9.0%
Voluntary turnover by FTEs
7.6%
8.5%
7.9%
8.9%
9.3%
9.0%
All Group employees excluding technical positions.
Turnover in the table above is calculated as the number of people leaving excluding technical positions to the Group’s
average annual headcount. The overall turnover rate in 2025 was 12.9% (compared with 14.1% in 2024).
Table 100. Number of new employees hired in the Group
2025
2024
Women
388
508
Men
306
331
Total
694
839
active employees excluding technical and duplicate positions within the Group.
In 2025, the Group hired a total of 694 new employees, which represents a 17% decrease compared with 2024.
Characteristics of associate workers in the undertaking’s own workforce (S1-7)
The total number of associates who are not employees and whose work is controlled by the organisation are office staff
responsible for registration of contracts for the sale of financial products, sale of insurance, completion of documentation,
verification of documents, etc. At the end of 2025, we had 345 associates, an increase of 26 compared with the end of 2024.
Table 101. Characteristics of associates in own workforce
2025
2024
Number of associates
345
319
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Collective bargaining coverage and social dialogue (S1-8)
A Collective Bargaining Agreement (CBA) is a type of collective agreement concluded through negotiations between the
employer and employees represented by company trade unions operating at the Bank.
The Collective Bargaining Agreement has a normative character, meaning that its provisions apply to the employees
covered by it in a manner similar to statutory regulations. The document defines the mutual rights and obligations of the
parties to the employment relationship, in particular working conditions, remuneration rules and other
employment-related benefits. The Agreement also makes it possible to introduce solutions that are more favourable than
those provided for in the Labour Code. Our Collective Bargaining Agreement includes provisions that go beyond the
standards commonly applied on the market, ensuring that employment and remuneration conditions are better aligned
with the specific nature of the Bank’s operations.
The Agreement has been made for the Bank’s employees, although the application of the agreement is excluded in its
entirety with regard to:
• members of the Bank’s Management Board,
• employees seconded to work abroad,
• persons working at the Bank on the basis of secondment from other entities of the BNP Paribas Group,
• persons employed at the Bank under management contracts.
Table 102. Percentage of employees covered by collective bargaining agreement
2025
2024
% of employees covered by the collective bargaining agreement
99%
99%
Table 103. Collective bargaining coverage and social dialogue in the Group
2025
2024
Collective bargaining agreement
Social dialogue
Collective bargaining agreement
Social dialogue
Coverage ratio
EEA employees
Non-EEA
employees
Representation
(EEA only)
EEA employees
Non-EEA
employees
Representation
(EEA only)
80-100%
Poland
-
Poland
Poland
-
Poland
A country/region (outside the EEA) where the BNP Paribas Group has significant employment is defined as a country or region with at least 50 employees, representing at least 10%
of the total number of employees.
There are five trade union organisations within the Bank. The employer cooperates with them on matters related to
collective labour law (e.g., conducting negotiations and concluding collective agreements, agreeing on employment and
remuneration rules) as well as individual labour law (e.g., consultations regarding the intention to terminate an
employment contract or change employment conditions, representing employees in the appeal process related to annual
performance reviews, participation in the Employee Conduct Standards Committee, and granting consent for the
termination or modification of employment conditions for trade union representatives and social labour inspectors).
The employer regularly meets with trade union organisations to engage in dialogue on the rights and professional and
social interests of employees. In 2025, eight agreements were signed under collective labour law.
The development of social dialogue between employees and management takes place not only at national level, but also
internationally, through the European Works Council (EWC).
BNP Paribas Bank Polska S.A. and other companies of the Group operating in Poland have their permanent representatives
in the EWC, elected in local elections for a four-year term.
The European Works Council is authorised to obtain information and conduct consultations on key aspects of the company’s
international and local operations that may affect the working conditions of employees in countries belonging to the EWC
(European Union countries and, in BNP Paribas, also England).
The EWC participates in the consultation with the Management Board of the BNP Paribas Group on decisions that may
impact the cross-border situation of employees. It represents employees working in all BNP Paribas Group units in Poland
internationally, has an impact on the Group’s global initiatives and on the content of documents and agreements developed
at the international level which apply also in Poland. It supports the promotion of the best experiences of other countries in
the area of social dialogue and care for employees in Poland.
Diversity metrics (S1-9)
The Bank attaches great importance to the real implementation of diversity, including ensuring adequate participation of
women in the Bank’s bodies. The Bank has made strategic commitments in this regard (see Table 94).
Compliance with the principle of diversity is monitored not only at the level of the Bank’s bodies, but also at the level of
managerial positions.
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Distribution of employees by gender and age
Table 104. Group employment structure by gender – number and percentage of employees
Employment structure
2025
2024
Women
Men
Total
Women
Men
Total
Management Board (of the
Bank and subsidiaries)
4
29%
10
71%
14
4
27%
11
73%
15
Top management (B1+B2)
166
45%
207
55%
373
196
46%
233
54%
429
Lower-level management
283
55%
229
45%
512
287
58%
210
42%
497
Other employees
4123
65%
2233
35%
6,356
4,291
65%
2,280
35%
6,571
Total
4,576
63%
2,679
37%
7,255
4,778
64%
2,734
36%
7,512
active employees excluding technical and duplicate positions within the Group.
Table 105. Group employment structure by age – number of employees
Employment structure
2025
2024
<30
years
30-50
years
>50
years
total
<30
years
30-50
years
>50
years
total
Management Board (of the Bank and subsidiaries)
-
5
9
14
-
6
9
15
Top management (B1+B2)
3
254
116
373
4
316
109
429
Lower-level management
5
382
125
512
7
386
104
497
Other employees
766
4,379
1,211
6,356
838
4,620
1,113
6,571
Total
774
5,020
1,461
7,255
849
5,328
1,335
7,512
active employees excluding technical and duplicate positions within the Group
In 2025, the Group had 774 employees under the age of 30, 5,020 employees between the ages of 30 and 49, and 1,481
employees over the age of 50.
The overall average age in the Group in 2024 is 42 years: 42 years for men and 43 years for women (in 2024: 41 years for
men and 42.1 years for women). The longest length of service is 42 years (in 2024: 41 years).
Adequate wages (S1-10)
In order to determine the adequate salary in all the countries in which it operates, the BNP Paribas Group relies on data
from FairWage Network, which calculates adequate wages according to various criteria, such as location (by country and
within countries in the main cities where employees work), household size (assuming two adults and a certain number of
children, depending on the country’s fertility rate) and the average number of income earners in the household.
The adequate wage data is updated annually by FairWage Network and forms the basis for the development and
implementation of the Group’s action plans. According to such guidance, all employees of the BNP Paribas Bank Polska
Group receive adequate wages.
The Group adheres to the minimum wage rules in effect in Poland. As of January 2025, the gross minimum wage was PLN
4,666. With regard to adequate wage, the Group defines it as a level of remuneration that is adequate to cover the basic
needs of the employee and their family, particularly with regard to housing, food, health, education, transportation,
transport, and savings.
In accordance with the Bank’s pay grades, the minimum base salary for an FTE was PLN 5,300 as of March 2025.
In addition to base salary, employees may receive variable remuneration (bonuses), awarded based on the Bank’s bonus
regulations. Bonus amounts are determined based on the quantitative and qualitative performance of employees, the team,
and the Bank.
Bank employees can also receive non-wage benefits.
Social protection (S1-11)
All employees of the Group are covered by income protection insurance in the event of any of the following: illness,
unemployment, accident at work/disability, parenthood, retirement. The benefits offered to the Bank’s employees are
described in detail in the section Social protection benefits.
Persons with disabilities (S1-12)
Table 106. Percentage of employees with certified disabilities employed by the Group by gender in 2025
2025
2024
Women
Men
Total
Women
Men
Total
% of employees
1.9%
1.4%
1.7%
1.7%
1.5%
1.6%
active employees excluding technical and duplicate positions within the Group.
As at 31 December 2025, the Group had 123 active employees with disabilities (2024: 122 employees), which represents
1.7% of active employees in the Group. In 2025, 5 employees with disabilities were hired.
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Training and skills development metrics (S1-13)
Table 107. Percentage of employees subject to regular performance and career development reviews in 2025
2025
2024
Women
Men
Total
Women
Men
Total
Percentage of employees
subject to regular
performance and career
development reviews
100%
100%
100%
100%
100%
100%
The process of setting targets and conducting annual evaluation covers employees employed by the Bank on the basis of an
employment contract, provided that the following conditions are met cumulatively in the year to which the evaluation
relates:
• remaining in an employment relationship with the Bank continuously for at least three months,
• working (“presence at work”) a total of at least 90 calendar days.
The percentage of employees who took part in the performance review was calculated based on the population eligible for
the review (i.e. 7,104 employees). In addition, the percentage of employees who took part in the employee reviews only
includes employees in entities that use the AboutMe platform, which is used to manage employee performance, career and
development.
Training
Training in the Group is understood as initiatives implemented by the Group companies that aim to maintain the level of
skills or improve the skills and knowledge of own workforce. They include both training at the headquarters of the
Bank/Group company as well as online training (e-learning).
Table 108. Average number of training hours for employees in 2025
2025
2024
Women
Men
Total
Women
Men
Total
Average number of training
hours completed by
employees
36.1
33.9
35.3
27.1
29.3
27.9
Average number of training
hours completed by
employees (excluding
mandatory training)
26.8
28
27.2
13.8
18.7
15.5
active employees excluding technical and duplicate positions within the Group.
The increase in training hours compared with the previous year results primarily from the expansion of the development
offering for employees. Throughout the year, numerous new training programmes were introduced, including the innovative
LeaderUP programme for managers, which focuses on developing leadership skills based on the Bank’s competence models
and values. In addition, the duration of the #MyWay development sessions – available to all employees – was extended,
enabling deeper professional and personal growth. A further noticeable increase in training hours stems from active
participation in various business academies and from training delivered as part of the agile transformation, which supports
teams in adapting to new ways of working and enhancing operational efficiency.
Health and safety metrics (S1-14)
Table 109. Health and safety at work
2025
2024
% of employees covered by an occupational health and safety management system based on
legal requirements and/or recognised standards or guidelines
100%
100%
Number of fatalities due to work-related injuries and illnesses
0
0
Number of registered work-related accidents
29
18
Percentage of recordable occupational accidents (frequency rate: number of accidents per 1
million hours worked)
1.31
0.77
Number of recordable cases of work-related ill health (subject to legal restrictions on data
collection)
0
1
Number of days lost due to work-related injuries and work-related fatal accidents; work-
related ill health and fatal accidents related to ill health
566
577
The occupational health and safety management system covers all employees of the Group who are employed under an employment contract.
In 2025, most accidents in the Bank occurred in the office. As in the previous year, these were mainly slips, unfortunate and
uncoordinated movements, and incidents resulting from failure to follow safety rules on internal walkways. Five accidents
during business travel were also recorded and classified as work-related accidents, as well as seven incidents during
remote work. There were no fatal accidents or cases of serious injury.
Work-life balance metrics (S1-15)
All Group employees are entitled to at least one of the following types of absence for family reasons: maternity leave,
paternity leave, paternal leave, unpaid time off and child or family carer’s leave.
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Table 110. Percentage of eligible employees who took family-related leave by gender
2025
2024
Percentage of employees entitled to take leave for family reasons
women
100%
100%
men
100%
100%
Total
100%
100%
Percentage of employees entitled who took family-related leave
women
27%
28%
men
11%
13%
Total
21%
23%
active employees excluding technical and duplicate positions within the Group.
The Group also carries out numerous activities promoting parenthood, as described in the section: Taking action on
material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities
related to own workforce, and effectiveness of those actions (S1-4).
Renumeration metrics (pay gap and total renumeration) (S1-16)
Table 111. Pay gap metric
2025
2024
Pay gap metric (total pay)
30.4%
31.5%
Pay gap metric (fixed pay)
29.1%
29.6%
active employees excluding technical and duplicate positions within the Group.
We implement a rational, balanced and controllable remuneration policy at the Bank that is consistent with our strategy,
accepted level of risk, standards and key values. The policy is based on clear principles and addresses good market
practices in the field of remuneration. Formally, the remuneration rules are set out in the “Company Collective Bargaining
Agreement” and the “BNP Paribas Bank Polska S.A. Employee Remuneration Policy”. In addition, the Bank has a policy for
remunerating persons who have a significant impact on the Bank’s risk profile.
The pay gap is calculated for active employees employed as at 31 December 2025, excluding: persons hired after 30
September 2025; employees absent for at least 3 months whose absence continued on 31 December 2025; technical and
duplicate positions within the Group; members of Supervisory Boards and expatriates. The indicator was calculated based
on the annualised gross base salary from 2024, using the December 2025 rate, and the annualised variable remuneration
awarded in 2025 for the achievement of 2024 targets. Night-shift allowances and overtime pay were excluded from the
calculation.
Table 112. Ratio of the highest annually paid individual to the median total annual renumeration
Remuneration metric
2025
2024
Ratio of the highest annually paid individual to the median total annual renumeration of all
employees (excluding the highest paid individual)
35.3
41.5
The ratio of the annual total remuneration of the highest-paid individual in the organisation to the median annual total
remuneration of all employees (excluding the highest-paid individual) amounted to 35.3 (vs. 41.5 in the previous year). The
level of the metric and its change in 2025 compared with 2024 result from the following factors:
• The annual review of base salaries, including pay updates in line with the applicable remuneration policy and actions
aimed at reducing pay gaps across specific positions.
• The transformation of roles within the Bank driven by process optimisation – including automation, digitalisation and
improvements in operational activities – which leads to the creation of new roles and an increased demand for key
market competences, often associated with higher remuneration.
Incidents, complaints and severe human rights impacts (S1-17)
Table 113. Incidents, complaints and severe human rights violations
Incidents, complaints, violations
2025
2024
Number of discrimination cases handled, including harassment and mobbing
0
2
Number of complaints handled regarding social issues related to working conditions, equal
treatment (excluding discrimination, harassment and mobbing)
17
15
Total amount of significant fines, penalties, and damages as a result of incidents and
complaints (discrimination and harassment)
0
0
Number of serious incidents involving human rights violations
0
0
Employees who have experienced disrespect towards themselves or other people should first contact their superior or HR
Business Partner. If, for various reasons, this is not possible, they can also use other channels (described in the Policy of
dealing with violations of respect for others at BNP Paribas Bank Polska S.A.). The violation reporting process is described
in detail in the section Processes to remediate negative impacts and channels for own workforce to raise concerns (S1-3).
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Consumers and end-users (ESRS S4)
This section of the Sustainability Statement focuses on four key topics related to consumers and end-users of the Group’s
products and services: data privacy protection, transparency and adequacy of information, Customer satisfaction, and social
inclusion.
Customer relations are a key element of the Group’s business model, as reflected in the Bank’s business strategy. The
objectives developed under the four pillars of the strategy, including those related to Customers, are described in detail in
the chapter Implementation of the GObeyond Strategy, and the results of the strategy’s implementation are presented in
the section Strategy, business model and value chain (SBM-1) under General Disclosures (ESRS 2).
The following sections present an analysis of the Group’s strategy, policies and actions in the area of consumers and
end-users, understood as direct retail Customers of the Retail and Business Banking segments as well as Personal Finance.
Strategy
Material impacts, risks and opportunities and their interaction with strategy and business model
(ESRS 2 – SBM-3)
Based on the double materiality assessment (DMA) conducted by the Group, presented in the section Description of the
process to identify and assess material impacts, risks and opportunities (IRO-1) under General Disclosures (ESRS 2), the
material impacts, risks and opportunities (IRO) related to consumers and end-users have been identified
Material impacts identified by the Group
Negative impact related to transparent and adequate information
Financial products and services offered to retail Customers could generate a material negative impact if communicated
information is not sufficiently clear and fair. For example, if the terms of a loan or investment product are not presented in
a clear and fair manner, there is a risk that Customers may be misled, resulting in decisions that are not adequate to their
needs or financial situation. This exposes Customers to possible financial difficulties.
Customers who are vulnerable or have limited knowledge of complex financial instruments may be particularly exposed to
negative consequences, which increases the risk of financial losses or making unfavourable investment decisions. To
mitigate this risk, the Group applies the legally required MiFID appropriateness test, also available in online banking, which
Customers complete before starting to invest. For individuals interested in credit products, the Bank conducts a
creditworthiness assessment that protects Customers from taking on obligations that are not aligned with their financial
capacity. Marketing materials and Customer communications are reviewed for plain language to ensure that the
information provided is clear and easy to understand. In addition, the Bank carries out control activities, including
Customer satisfaction surveys, which assess not only product-related experiences but also the transparency of documents
and credit processes, as well as the quality of information provided during the sales process. Based on survey results,
phone interviews and Customer complaints, appropriate corrective actions are taken when necessary.
Although the Bank’s broad range of products and services means that a lack of adequate information could potentially
affect a large number of Customers, this risk is effectively mitigated through the measures implemented by the Bank.
Negative impact related to Customer satisfaction
Customer dissatisfaction can be the result of a one-off incident and means that the Bank has not met the Customer’s
needs. Such an incident may relate to operational issues (e.g. difficulties in accessing online banking) or business issues
(e.g. selling a product that does not match the Customer’s risk profile).
Positive impact related to social inclusion
In the Bank and the Group, the impact includes facilitating access to services and products by taking specific action, for
instance for seniors and people with disabilities, and by aligning and developing applications and digital tools for
Customers experiencing any difficulty with access, for instance related to disability, neurodivergence, or low digital skills.
Negative impact related to personal data protection
The Group processes a certain amount of personal data of its Customers, such as identification data (e.g. full name, ID card
number, PESEL number, etc.) or contact details (e.g. mailing address, e-mail address, telephone number, etc.). Violations of
personal data protection regulations – including the General Data Protection Regulation (GDPR) applicable in the European
Union – and/or the loss or theft of confidential information concerning individual Customers may result in a material
negative impact on Customers caused by the Group.
When defining data protection measures, the Bank takes into account impact on specific Customer groups, such as seniors,
children, and online banking users, who may be particularly vulnerable to the risk of breach. This analysis is part of the
personal data protection assessment.
Material risks identified by the Group
Risks related to clear, transparent and non-misleading information
Failure to protect Customers’ interests may result in the risk of sanctions being imposed by regulators and in potential
claims raised by Customers in court.
Risk related to loans denominated in Swiss francs (CHF) or foreign currency loans
The Bank identifies legal risks related to pending litigation involving loans denominated in Swiss francs or Swiss franc
foreign currency loans, which it has not offered since 2012. The Bank estimates the impact of legal risk on an ongoing basis,
taking into account the current status of judgements in cases against the Bank and the line of case law. At the same time,
since December 2021, individual negotiations have been conducted with Customers with whom the Bank remains in dispute
or for whom there is a reasonable risk of entering into a dispute. For more information on the proceedings in this case, as
well as a description of other proceedings involving Customers, see Note 53 in the Consolidated Financial Statements.
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Material opportunities identified by the Group
During the double materiality assessment, it was not possible to quantify the expected financial scale of opportunities
relating the area of social inclusion. Consequently, the Bank considers this opportunity as non-material
.
Table 114. Summary of links between the material IRO and Policies, Actions, Metrics and Targets
Category
Material IRO
Name of the policy
Actions
Metrics and Targets
Negative impact
Financial difficulties due to lack of
information
Code of Conduct
Policy on the protection of the interests of
Customers
Transversal training actions
Implementation of clear, transparent and non-misleading information and specific measures, such as
formalizing guidelines for drafting contracts
Complaint management, rules for informing retail Customers and responding to their inquiries
Continuous improvement process
–
Negative impact
Customers dissatisfaction
Code of Conduct
Policy on the protection of the interests of
Customers
Transversal training actions
Net Promoter System with Innerloop (activities undertaken in response to current issues raised by
Customers by the first line of service) and Outerloop (activities requiring inter-organisational
cooperation) processes
NPS
Negative impact
Impact related to legal risks and
reputational risks resulting from the loss
or theft of confidential data
Code of Conduct
Bank’s personal data protection policy
Transversal training actions
Data protection risk management process
Dedicated management
Dialogue channels with retail Customers
Continuous improvement process
–
Positive impact
Social inclusion
Code of Conduct
Policy on the protection of the interests of
Customers
Transversal training actions
Continuous improvement process
Accessibility improvements
Development of digital services (website, application, etc.)
Accessibility projects
Number of Customer Centres with the
‘Barrier-free Facility’ certification
Risks
Legal risks and reputational risks due to
lack of information and Customer
complaints
Code of Conduct
Policy on the protection of the interests of
Customers
Policy for handling complaints and reports of
unauthorised payment transactions at BNP
Paribas Bank Polska S.A.
Policy for managing reputational risk at BNP
Paribas Bank Polska S.A.
Transversal training actions
Implementation of clear, transparent and unambiguous information and concrete measures, such as
formalizing guidelines for the creation of commercial documents
Complaint management, rules for informing retail Customers and responding to their inquiries
Continuous improvement process
–
Risks
Legal risks associated with Swiss franc
mortgages
–
Individual settlements offered by the Bank to Customers with loans denominated in Swiss francs or
foreign currency loans in Swiss francs
–
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Interaction with the Group’s strategy and business model
The material negative impacts on retail Customers identified by the Group – such as financial difficulties resulting from a
lack of information or dissatisfaction, as well as the loss or theft of data – do not stem from the Group’s strategy. They
represent external side effects of the Group’s operations, arising from unintentional flaws in products or services and
unforeseen negative consequences of the Group’s activities.
The material risks identified by the Bank in relation to retail Customers primarily concern situations involving breaches of
legal or regulatory requirements and insufficient information about products and services introduced to the market. These
risks are an inherent part of banking activities, and the Group consistently seeks to mitigate them as part of its strategic
actions.
Managing impacts, risks and opportunities, metrics and targets
Policies related to consumers and end-users (S4-1)
In its efforts to manage the material impacts of its products and services on Customers and end-users, as well as the
related risks and opportunities, the Group has implemented a set of policies presented in the table below. These policies
apply to all retail Customers, in line with the definition provided in the introduction to this chapter, and do not include any
exceptions.
Table 115. Summary of Policies relating to Consumers and end-users
Name of the policy
Description of the policy content
Description of the scope of the policy or
exclusions
Description of the highest level of the organisation
responsible for implementing the policy
Interaction with stakeholders
BNP Paribas Group Code of Conduct
The Code of Conduct sets out the rules of conduct
that apply to all activities and employees of the
Group.
The Code applies to all entities of the BNP
Paribas Group
Bank’s Management Board and Bank’s Supervisory
Board
The Code of Conduct is available on the Bank’s
website.
BNP Paribas S.A. Bank Personal Data Protection
Policy
It regulates the Bank’s strategy in this area,
setting out rules for all categories of data subjects
(Customers, employees, service providers, etc.)
and all personal data processing activities in all of
the Bank’s distribution models.
BNP Paribas Bank Polska
Subsidiaries have their own policies
Bank’s Internal Audit Department, Bank’s Management
Board
The policy is available internally only.
The Bank publishes “Personal Data Protection
Information Notice” in Polish, English, Russian and
Ukrainian and the “Personal Data Protection Charter”
on its website for its Customers.
The purpose of the documents is to explain to
Customers how the Group and the Bank process their
personal data and how they can exercise their rights.
Policy on the protection of the interests of
Customers
The policy sets out the organisational and
procedural rules that must be applied throughout
the Customer relationship and at all stages of the
product and service life cycle.
BNP Paribas Bank Polska
Compliance and Ethics Department of BNP Paribas
Bank Polska, Bank’s Management Board
The policy is published internally only. A summary
containing information on the Protection of Customer
Interests is available in the BNP Paribas Group Code
of Conduct available on the Bank’s website.
Policy for handling complaints and reports of
unauthorised payment transactions at BNP
Paribas Bank Polska S.A.
The Policy sets out the general principles
applicable to the process of accepting and
handling complaints and reports of unauthorised
payment transactions at BNP Paribas Bank Polska
S.A. Its provisions apply accordingly to the Bank’s
Brokerage Office.
BNP Paribas Bank Polska S.A.
Daily Banking Operations Department, Bank’s
Management Board
The policy is published internally only.
Information for Customers on complaint handling is
available on the Bank’s website.
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Name of the policy
Description of the policy content
Description of the scope of the policy or
exclusions
Description of the highest level of the organisation
responsible for implementing the policy
Interaction with stakeholders
Policy for managing reputational risk at BNP
Paribas Bank Polska S.A.
The Policy defines the framework for identifying,
preventing and managing reputational risk, which
may arise, among others, from transactions and
activities carried out by the Bank (regardless of
whether they relate to Customers or to the Bank’s
own operations).
BNP Paribas Bank Polska S.A.
Communication, Marketing, Customer Experience and
Social Engagement Division, Bank’s Management Board
The policy is published internally only.
In overseeing all applicable policies listed above, the Group applies both ongoing and periodic internal controls. The Bank’s
Personal Data Protection Policy is monitored by the Data Protection Officer, operating within the Risk area as part of the
second line of defence. It may also be subject to first-line controls in accordance with the control plan adopted for a given
year.
The policies listed in the table above are fully in line with international frameworks regarding consumers and end-users,
including the UN Guiding Principles on Business and Human Rights. The Bank refers to human rights in dispersed ways, i.e.,
across various internal regulations, including the BNP Paribas Group Code of Conduct, which obliges the Bank to respect
human rights in its operations and to promote human rights within its sphere of influence, including among Customers.
The right to privacy with regard to retail Customers is recognised and integrated into the Bank’s Personal Data Protection
Policy and its internal procedures, established in accordance with European regulations in this area, such as the GDPR. The
Group, as a financial institution, does not identify any severe violations of the fundamental human rights of retail
Customers in connection with its activities. No cases were recorded of non-compliance with the UN Guiding Principles on
Business and Human Rights, the International Labor Organization Declaration or the OECD Guidelines for Multinational
Enterprises. No human rights incidents were reported in 2025.
External stakeholders, including Customers, may use the whistleblowing system via the channels made available on the
Bank’s website.
The protection of whistleblowers against the risk of retaliation has been strengthened through the incorporation into
internal regulations of the requirements of the Whistleblower Protection Act of 14 June 2024. Individuals involved in
handling a report are required to maintain the confidentiality of the whistleblower’s data as well as all parties to the
proceedings. At the same time, the Group ensures that whistleblowers are protected from the risk of potential retaliatory
actions, and any person who believes they have been subjected to such actions may report this; the report will be reviewed
in accordance with the standards applicable in the Human Resources Management Area. This protection applies regardless
of the reporting channel used by the whistleblower.
Processes for engaging with consumers and end-users about impacts (S4-2)
Transparent and non-misleading information
The policy of protecting Customers’ interests sets out the general principles for which all segments and organisational
units of the Bank are operationally responsible, including the Compliance and Ethics Department. These principles include:
• ensuring that Customers have access to information that is reliable, fair, transparent, understandable and not misleading,
regardless of the communication channel or format;
• providing, prior to the distribution of a product or service, all information necessary to understand:
− the nature of the product or service being purchased, including its functions, benefits and limitations. Information that
does not present the advantages and disadvantages of a product or service in a balanced manner would be considered
misleading;
− the costs associated with the product, service or advisory support;
• supplying information to Customers throughout the entire lifecycle of a product or service, where needed;
• designing products and services in a way that allows them to be easily explained and understood by Customers in the
target group;
• responding to Customer inquiries as promptly as possible and with the highest quality.
In addition, the Group ensures:
• compliance with local legal requirements,
• the implementation of an internal control system that guarantees the transparency of information provided to Customers
and compliance with regulations.
Each business manager is responsible for fulfilling these obligations.
Employee training, particularly for teams responsible for Customer relations and service, includes topics related to the
protection of Customers’ interests (more information in the section Taking action on material impacts on consumers and
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end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-
users, and effectiveness of those actions (S4-4).
Customer satisfaction
Since 2017, the Bank has been implementing the Advocacy programme, under which a system enabling broad and
continuous listening to Customer voice has been introduced. The programme is built on two pillars, i.e., opinion surveys and
the analysis of Customers’ spontaneous statements:
• a multi-channel survey system to collect Customer opinions at various stages of their relationship with the Bank:
− annual Net Promoter Score (NPS) benchmarks, which measure the level of recommendation of the Group’s Customers
and compare it with the level of competition in many areas of Customer relations;
− relationship surveys: Customers are asked about four times a year to give their opinion on their relationship with the
Bank;
− transactional surveys conducted after a Customer-bank interaction such as a branch visit or phone call;
− surveys dedicated to a specific Customer journey (e.g. establishing a relationship, managing credit card).
In addition to the NPS score and operational indicators (e.g., conversion rate, service time, etc.), the Bank considers the
experience of employees to get the most comprehensive and in-depth picture of the Customer Journey, i.e. how Customers
feel when they are in contact with the Bank.
• analysing Customers’ spontaneous statements, such as complaints (discussed in the next section Processes to remediate
negative impacts and channels for consumers and end-users to raise concerns (S4-3)) or their activities on social media.
The results of the NPS benchmark supplemented the entire Customer feedback system. The lessons learned and topics to
be addressed are communicated to the Management Board, unit managers and all employees concerned.
In 2025, approximately 125,000 surveys were conducted among retail Customers. Each year, the Bank sets a goal of
improving its position relative to competitors.
All employees of the Bank are responsible for building Customer satisfaction while the highest function in the area of
Customer experience is the Management Board. The central unit responsible for Customer experience at the Bank is the
Customer Experience Strategy and Development Department.
Focusing on Customer needs, the Bank designs its products and services to better address their key expectations. An
example of this approach was the implementation of initiatives aimed at improving Customer experience in the area of car
purchase financing. By enhancing the documentation required at the application stage and introducing reminders for
Customers about the need to submit documents, the process was significantly simplified and shortened. As a result,
transparency increased, Customer convenience improved, and NPS scores related to this process rose substantially. By
analysing Customer experiences and emotions along Customer purchasing journeys, the Bank accompanies Customers at
every stage of the process. It considers both Customer voice and the perspective of employees who have in-depth
knowledge of how individual steps are carried out. This approach makes it possible to identify moments that may pose
challenges for either the Customer or the employee.
Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
(S4-3)
Managing complaints
A key element of the Group’s policy on protecting Customers’ interests is the handling of complaints, carried out in
accordance with detailed operational procedures. The Policy on protection of Customers’ interests sets out the rules for
complaint handling, under which:
• Customers receive clear information about the available channels and the complaint handling process, and, where
applicable, about the mediation protocol. The Bank also has a Customer Ombudsman, whose cases – handled by a
dedicated team – are processed independently of the original complaint procedure,
• each complaint is acknowledged, and Customers are regularly informed about the progress of its review,
• a response to a complaint must be provided within no more than 60 calendar days,
• the complaint handling process is free of charge for Customers.
In addition, the Group ensures:
• that employees who interact with Customers have an appropriate level of knowledge about the complaint submission
process,
• the monitoring of compliance with complaint handling rules,
• the analysis of complaint root causes and the communication of corrective actions and quality improvement programmes
enabling the continuous enhancement of processes.
Standards for handling complaints and providing responses are described in the Policy for handling complaints and reports
of unauthorised payment transactions at BNP Paribas Bank Polska S.A. The Policy defines the responsibilities at each stage
of the process and indicates the division of roles, tasks and responsibilities of the units involved. It also indicates the forms
of complaint submission available to Customers.
The Bank offers Customers several convenient ways to submit complaints, allowing everyone to choose the form that best
suits their needs. A complaint can be submitted via the chat function in the GOonline banking system or the GOmobile app,
through the complaint form in electronic banking, by phone, by mail, or in person at any branch. Customers also have the
option to refer their case to the Customer Ombudsman by using an online form, email contact, or traditional
correspondence. This ensures that the complaint submission process is widely accessible and flexible.
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The complaint handling process is one of the Bank’s main sources of Customer voice. The insights received support the
Bank’s development and enable it to respond more effectively to Customers’ expectations and needs.
The Complaints and Correspondence Operations Team in the Daily Banking Operations Department consists of four
specialised areas (circles), each responsible for different types of complaints, including the Customer Ombudsman Team.
All Bank units involved in the complaint handling process jointly diagnose the issues reported by Customers, aiming to
eliminate them in the future and to further align the quality of activities with regulatory expectations. This approach also
enables faster responses to Customers. In this way, the Bank delivers on the two key pillars of the complaint handling
process: quality and operational efficiency. In 2025, the number of complaints decreased by 2% compared with 2024, and
the NPS for the complaint handling process reached 13 points at the end of 2025.
• 14 calendar days – average complaint processing time in 2025.
The number of complaints registered by the end of December 2025 was 55,880 (this covers all retail Customers and all
types of complaints).
Table 116. Number of complaints received
2025
2024
Number of complaints received
55,880
56,930
The Bank responds to Customer voice not only through the complaint handling process. In situations requiring an individual
approach, cases are referred to the Customer Ombudsman Team, particularly when a Customer disagrees with the decision
issued after the complaint review. The Team also analyses submissions addressed to the Management Board, the
Supervisory Board or the Press Office, and supports communication with Customers who raise issues important to them on
social media.
• In 2025, the Customer Ombudsman received 2,335 cases (including 143 referred directly to the Bank’s Management
Board, Supervisory Board, and Press Officer).
• 82.5% of the people who used the Customer Ombudsman’s help in 2025 were retail Customers.
• 18.2% of the topics (the highest percentage) for which the Customer Ombudsman took action in 2025 concerned personal
accounts.
A Customer who disagrees with the response to their complaint may submit an appeal through the available channels, as
well as make use of the option to refer the matter to the appropriate external institutions. The entities authorised to
conduct out-of-court consumer dispute resolution include the Banking Arbitrator at the Polish Bank Association, the
Financial Ombudsman, and the Court of Arbitration at the Polish Financial Supervision Authority. Until June 2025,
Customers could also use the ODR platform – a tool enabling the submission of complaints to entities responsible for
out-of-court dispute resolution within the European Union in cases involving contracts concluded electronically.
In carrying out the complaint handling process, the Bank aims not only to identify areas requiring improvement for product
and process owners, but also to ensure that the entire process is transparent and intuitive for Customers.
Customers and employees use the GObetter complaint system, which enables the handling of submissions within a single,
integrated environment. The system provides simple and intuitive navigation, real-time access to complaint status, and the
ability to submit cases thanks to its integration with the GOonline electronic banking platform. It also supports advisors in
resolving issues quickly through the Goodwill Gesture function. Increased automation and centralised data facilitate
complaint analysis and the implementation of improvement measures.
The complaint handling process is continuously monitored in both qualitative and quantitative terms, and its results may
influence the performance assessment of units involved in handling submissions. The Bank systematically collects and
analyses information arising from complaints to draw conclusions, eliminate errors and assess the financial impact of
incoming cases. The resulting reports are provided to the Management Board and the Bank’s leadership in line with the
defined responsibilities of individual units, and the entire process is described in the Policy for handling complaints and
reports of unauthorised payment transactions.
All Customer submissions are treated confidentially, with full respect for privacy and data protection. However, full
complaint handling is not possible if a submission is anonymous or does not contain information allowing the identification
of the Customer or the product.
Customers can submit their complaints and comments in complete safety, without fear of any consequences. Although the
Bank does not have separate policies specifically protecting individuals using the complaint process from retaliatory
actions, the applicable legal regulations clearly prohibit any form of retaliation against Customers for filing a complaint.
The proceedings initiated in 2022 by the Office of Competition and Consumer Protection (UOKiK) regarding customer
complaints related to unauthorised transactions were still ongoing in 2025. The Bank is cooperating with UOKiK with
respect to the further course and conclusion of the proceedings. More information is presented in the section Court and
administrative proceedings in the chapter Additional information.
Customer satisfaction
Individual corrective actions apply to all Customers who completed a satisfaction survey following contact with the call
centre. An advisor contacts each Customer within a few days, with particular attention given to those who provided
suggestions – this follow-up helps to better understand Customers’ opinions and the reasons behind them.
Wherever possible, the Customer is provided with an immediate solution. The advisor or consultant directly serving the
Customer must implement corrective measures if the problem for the Customer occurs at the local level (Innerloop) or
forward it to the Customer Experience department if it is a process problem whose solution is not directly controlled by the
unit serving the Customer at the local level (Outerloop).
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The results of the analyses are incorporated into cross-sectional reports and into a platform presenting Customer feedback,
which facilitates their regular sharing and monitoring within the Bank. The Bank draws conclusions from the corrective
actions undertaken, supporting a continuous learning process. The Customer Experience Team regularly provides managers
and business units with information on Customer issues and action plans, which are continuously updated based on new
data from satisfaction surveys and complaints.
The Bank offers a variety of contact channels that enable Customers to raise their questions and needs. These enquiries are
clarified by the first line of support and, where necessary, registered as complaints. Customers can use, among others: the
chat function in the GOmobile app and GOonline banking, the chat on the Bank’s website for individuals without access to
online banking, video chat and online video meetings with experts, a contact form, the helpline with the option to connect
directly from the app, as well as traditional Customer Centres. Customers also share their opinions and comments through
satisfaction surveys and via social media. Information about available access channels can be found on the Bank’s website
in the Contact section or obtained at Bank branches or through the helpline.
The contact channels offered by the Bank are diverse and tailored to the different needs of Customers. Based on quarterly
analyses of difficulties reported by Customers and shared with product owners, corrective actions are planned to address
these needs. The Bank’s units apply a multichannel approach and ensure high-quality access – particularly in the area of
improving accessibility for persons with special needs. The Bank also operates an Online Expert Centre for Retail Customers
in the mortgage area, which is also available to the premium segment. The Centre supports the development of remote
services and the transition from branch-based banking to online banking, pursuing the mission of creating a fully remote
branch accessible to Customers regardless of their place of residence.
The efficiency of communication channels is assessed based on NPS (Net Promoter Score) surveys, i.e. whether Customers
recommend the bank, FCR (First Contact Resolution), i.e. whether the Customer has resolved the issue in the first contact,
and CES (Customer Effort Score), i.e. the effort put in by the Customer to resolve the issue. In the Contact Center, we also
monitor the percentage of calls answered within 30 seconds, the percentage of calls answered in relation to all calls, and
the average waiting time for a call.
When conducting surveys of Customers, the Bank follows the applicable GDPR regulations. Depending on the type of survey
conducted, they are anonymous or not, but the Customer has the right to object and not to share the data with the Bank,
including objecting to being contacted about the opinion provided after the satisfaction survey.
Social inclusion
As regards its impact on social inclusion of retail Customers, the Group focuses on increasing the accessibility of its
products and services, as described in the section below. The Group relies on the same corrective processes that are used
for other retail Customers, which are presented in the sections on Customer satisfaction and complaint management.
Taking action on material impacts on consumers and end-users, and approaches to managing material
risks and pursuing material opportunities related to consumers and end-users, and effectiveness of
those actions (S4-4)
The Group implements various measures to prevent, minimise and correct negative impacts on retail Customers, to manage
the associated material risks and to take advantage of the related opportunities.
Transversal training actions
The goal of training for employees provided by the Group is to properly manage key risks and leveraging opportunities
related to the service for retail Customers. This includes training on the protection of Customers’ interests, most notably an
extensive Code of Conduct training, mandatory for all employees and covering information on channels for reporting ethical
concerns as well as a module dedicated to diversity, equity and inclusion.
In addition, every employee must complete mandatory privacy protection training, and regular internal campaigns reinforce
awareness of cybersecurity threats and the principles of secure data processing.
Actions for personal data protection
Risk management process related to the protection of personal data
The personal data protection policy of the Group and Bank includes identifying, classifying and assessing the risks
associated with personal data processing activities affecting data subjects, including retail Customers.
The Group uses a range of organisational and technical measures aimed at limiting and preventing risks related to the
processing of personal data, including the risk related to the loss of confidential personal data, breach of its integrity or
availability. In accordance with Article 32 of the GDPR, these measures include:
• pseudonymisation and encryption of personal data;
• the ability to ensure the confidentiality, integrity, availability and resilience of data processing systems and services;
• the ability to restore the availability and access to personal data in a reasonable time in the event of a physical or
technical incident.
Management
The management of Customer personal data protection is based on the cooperation between the network of Chief Data
Officers operating in the first line of defence (Group Data Office) and the Data Protection Officers functioning within the Risk
structures as the second line of defence – they are responsible for applying the data protection framework. This network is
further supported by legal experts, also within the second line of defence. The functions responsible for ongoing and
periodic controls, forming the third line of defence, verify the correct application of this framework and assess its
effectiveness.
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Channels for dialogue with retail Customers
The Group’s rules, aligned with the GDPR, provide for the direct notification of individuals whose personal data has been
affected by a breach. This ensures that Customers can quickly learn about their rights and take actions to enhance their
security.
Retail Customers may contact the Bank at any time – directly or through data protection authorities – if they have
questions or complaints regarding the processing of their data. The Bank’s suppliers are required to forward any Customer
requests and support the Bank in providing responses.
The channels facilitating dialogue with Customers are described in the Data Protection Notices and on the Bank’s website,
where guidance on submitting complaints to the President of the Polish Data Protection Authority (UODO) is also available.
Complaints are handled confidentially and in accordance with the principle of restricted access.
The dialogue with retail Customers regarding personal data protection is organised in the Group around Data Protection
Officers, who work in cooperation with the Group Data Protection Officer and act as personal data guardians for data
subjects. They act within an autonomous control function, thus ensuring sufficient independence. The Data Protection
Officer appointed at the Bank, who is located in the Risk area, ensures independent supervision of the processing of
personal data.
Operational responsibility for the dialogue within the Group lies with the teams responsible for managing personal data
protection as part of the second line of defence and the management boards of the companies.
Continuous improvement process
In 2025, the Bank continued to expand its network of data protection specialists. The Bank has a team of Data Protection
Officers (as part of the second line of defence), responsible for the application of personal data protection principles and
increasing the level of maturity in the field of personal data protection.
The effectiveness of the processes for handling data protection complaints and incidents is monitored within the Group
through ongoing controls carried out by control functions, as well as periodic audits. In addition, this process may be
subject to assessment by supervisory authorities and courts, and the contact details of the supervisory authority are
provided in the “Personal Data Protection Information Notice” and made available to Customers upon request.
The Group draws conclusions from personal data breach incidents and from interactions with data subjects, in order to
improve dialogue channels and more effectively prevent and mitigate future breaches. Where necessary, additional
communication with Customers is conducted to clarify their requests or supplement information, enabling the Bank to
provide the most accurate response.
Actions for transparent, clear and non-misleading information and complaints management
Clear, transparent and non-misleading information
These actions are described in the section Processes for engaging with consumers and end-users about impacts (S4-2) The
Group takes action tailored to the needs of Customer groups, such as formalising guidelines for drawing up contracts or
practices to prevent greenwashing.
Complaint management
Details of these activities are presented above in the section Processes to remediate negative impacts and channels for
consumers and end-users to raise concerns (S4-3). Information on the complaint handling process and the mediation
protocol is provided to Customers both in Customer Centres and on the Bank’s website. A Customer who submits a
complaint receives confirmation of its receipt within five business days if the matter is still under review. Customers are
kept informed about the progress, and the final response is provided within no more than 60 days.
Continuous improvement process
The analysis of root causes of complaints and the ways in which they are resolved supports the Group’s continuous
improvement. Once a quarter, a complaint report is presented at meetings of the Management Board and the Supervisory
Board, and issues related to complaints are discussed during regular sessions devoted to the Code of Conduct
The Bank invests in the development of the GObetter complaint system and other tools that support effective complaint
management. It also uses compliance procedures to manage risk and ensure the highest quality of services. Customer
experiences along sales and service journeys are monitored through Customer Journey studies and NPS surveys, as
discussed in the section Processes for engaging with consumers and end-users about impacts (S4-2).
Focus on Customer satisfaction
The following resources are responsible for handling complaints:
• Daily Banking Operations Department and Complaint and Letters Processing Team,
• the Bank’s Customer Ombudsman – a Lead Flow Expert at the Daily Banking Department.
When the Bank identifies an error resulting in a financial loss or undue charges for a Customer, a set of corrective actions is
initiated.
• in the case of incorrectly applied fees or commissions, the employee handling the complaint issues a refund as part of
the complaint process, and information about the error is forwarded to the relevant product or process owner.
• if the error results in an operational loss, the event is recorded and settled in accordance with the Bank’s Instruction for
Recording Operational Events and Action Plans.
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When a Customer’s claim is accepted, losses are immediately remedied within the complaint handling process (for
example, by cancelling an incorrectly applied fee). Financial losses arising from system failures, process errors or human
errors are assigned directly to the managers responsible for the product or process affected by the error.
Actions for Customer satisfaction
The Bank has developed a set of tools designed to identify key issues that may negatively affect Customer satisfaction.
These tools enable more effective recognition of Customer expectations and appropriate responses to them. One such tool
is the NPS. The Customer Experience team is responsible for the cooperation model, monitoring and sharing of NPS results
and:
• is responsible for the standards and methodologies for implementing the NPS system;
• regularly communicates the results of the NPS survey and monitors Customer pain points;
• is a member of internal decision-making teams and represents the voice of Customers, recommending changes and
improvements to sales and after-sales processes in the Customer journey.
As part of its work on the Customer journey, the team also conducts the Outerloop stage described in Processes to
remediate negative impacts and channels for consumers and end-users to raise concerns (S4-3), which includes:
• regularly collecting all available feedback from Customers (from surveys, complaints, social networks and other
sources).
• in-depth analysis of feedback to identify the key difficulties experienced by Customers and their causes;
• prioritising and jointly solving identified problems with the relevant operational teams.
The Bank implements the following measures to ensure a positive impact on Customers:
• develops processes in digital channels, for example by:   
enabling Customers to use the “exempt amount” on accounts subject to enforcement seizure via the mobile app and
online banking,   
providing new remote channel processes for mortgage loans, such as shortening the loan term after a partial early
repayment and enabling tranche disbursement to the developer;
• improves savings management, for example by introducing the GOdreams service in the Bank’s app, whose functionalities
supports Customers in saving regularly for their dream goals while banking with the Bank;
• has introduced a more modern and functional web application for brokerage accounts, called GOwebmakler;
• streamlines credit processes, including by:   
enabling the signing of loan agreements via SMS code and providing an additional identity verification method through
the mObywatel app for instalment loans,   
introducing enhancements to the loan agreement signing process in the Bank’s mobile app to increase accessibility for
Customers,   
enabling Customers to apply for a cash loan using Open Banking in the phone-based application path;
• simplifies the language of agreements, promotional terms, applications and other documents, including in the credit
process and account opening process, to make them even clearer and more understandable for Customers;
• introduces improvements for employees to help them serve Customers more efficiently and effectively, for example by
expanding and standardising tools and systems used to process key Customer instructions on the Helpline, as well as for
scheduling Customer appointments with Advisors through various channels such as the Customer Centre, Helpline or
Video Meeting.
In addition, the Bank takes measures to develop the knowledge and raise the awareness of employees in order to
strengthen the organisational culture focused on Customers’ needs. In 2025, the Bank:
• presented the development of Customer paths (i.e. Customer experience maps) for the needs of further owners of
products and processes;
• as part of onboarding, trained new leaders in Customer Experience in recognition of the fact that active manager
involvement is necessary in building a Customer-centric organisation;
• continued the Advocacy Programme, which covers key aspects of Customer centricity: building awareness of employees
about the importance of focusing on the Customer, using knowledge about Customers and employees to improve the
Customer experience, and verifying whether the initiatives taken have had the expected results;
• continued the three-module online training course Customer Experience – NPS and made a new training course available
to all Bank employees on working with Customer journeys, incorporating both the Customer and employee perspectives;
• developed the Customer Experience Strategy, enabling the creation of consistent and customer-centric solutions;
• organised Customer Days aimed at inspiring employees to design exceptional Customer experiences in line with the
Customer Experience Strategy and at emphasising the importance of plain language in communication with Customers;
• appreciated Customers by preparing special offers and vouchers, and by providing financial education through, among
other things, educational webinars, conversations on how smart everyday decisions can lead to greater peace of mind
and real savings, as well as on children’s online safety; we also made available educational guides for children from the
Mission Education series;
• expanded knowledge about the needs of neurodivergent Customers across various Bank areas responsible for designing
solutions, digital channels and Customer service through dedicated training, and examined the experiences of
neurodivergent Customers in the Bank with the support of external experts specialising in neurodiversity. Based on the
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insights gathered, the Bank began improving service standards, processes and solutions to take another step towards
more accessible, conscious and responsible banking.
The Bank has advanced risk monitoring systems and anti-fraud programmes in place, and their results are regularly
reported to the Management Board.
Through regular assessment and monitoring of its practices, the Bank ensures that they do not cause or contribute to
material negative impacts on Customers. The use of the Customer voice in journey analysis enables the precise
identification of difficulties Customers encounter. Based on these insights, the Bank adjusts its solutions to better address
Customer needs and expectations. One important source of knowledge is the analysis of complaints, which informs the
implementation of measures aimed at preventing similar issues from recurring.
Surveys are conducted among Customers acquired through partner channels, and the findings from these analyses are
discussed with the Bank units cooperating with partners.
Both the collection of Customer feedback on their experiences with products and service channels, and the subsequent
work with such information in the Innerloop and Outerloop processes, enable the implementation of improvements across
the Bank’s operations.
The resources that the Bank uses to manage material impacts on Customer satisfaction include the Customer Experience
Strategy and Development Department, which is responsible for collecting and analysing Customer feedback from various
sources.
Actions for social inclusion to support financial inclusion through accessibility of products and services
Social inclusion holds a particularly important place in the Group’s activities, understood as ensuring that every Customer
has equal, convenient and simple access to banking services. This commitment is reflected in the POSITIVE pillar of the
Bank’s GObeyond strategy for 2022–2025, which included, among other objectives, ensuring access to banking for all. The
Bank engages in initiatives that promote greater accessibility of financial services, diversity and equality, thereby
supporting a more inclusive society. Particular emphasis is placed on facilitating access to banking for individuals at risk of
social exclusion. Customers with disabilities and seniors can rely on both physical and digital channels offering solutions
tailored to their needs. In this way, the Bank mitigates risks related to limited access to financial services and supports
Customers in achieving their goals. All access channels are regularly reviewed for functionality and user-friendliness, in
line with WCAG guidelines.
Accessibility matters within the Bank are regulated by the document Principles for Providing Banking Documents in
Accessible Formats for Customers with Special Needs. The Bank complies with the requirements of the Act on Ensuring
Accessibility for Persons with Special Needs and pursues its activities with a long-term perspective.
Accessibility for people with special needs
As at the end of 2025, 144 Customer Centres and the Bank’s headquarters were certified as “Barrier-Free Facilities” by the
Integration Foundation. This is the best result among banks in Poland. The certificate confirms that the building has
facilities for people with physical, visual and hearing disabilities, senior citizens and people looking after children. In
practice, this means that Customers can move around the Bank’s premises without obstacles and use the available
facilities. The Bank’s strategic objective was to ensure that by 2025 at least 50% of Customer Centres would hold the
“Barrier-Free Facility” certificate. At the end of 2025, 41.5% of Customer Centres were certified. The target was not achieved
due to cost optimisation decisions regarding the sales network taken during the strategy period. The certification process
began in 2018. Adapting the Customer Centres that remained uncertified in 2025 would require significant investment in
reconstruction, or they are located in buildings where meeting the certification requirements is very difficult or impossible
due to structural or technical constraints. Nevertheless, in the coming years, the Bank will continue its efforts to increase
the number of Customer Centres holding the certificate.
All of the Bank’s branches hold the OK Senior® certificate awarded by the National Institute of Senior Economy. The
certificate confirms that the solutions offered are senior-friendly and that services are safe, understandable and reliable. In
2023, the Customer Centres obtained recertification for the years 2023–2025 for the third time, following an audit
assessing the extent to which services are adapted to the needs of senior customers. The OK Senior® Quality Mark
guarantees the credibility and accessibility of services for senior Customers, and the Bank remains the only financial
institution in Poland to hold this distinction.
The Bank offers a range of solutions for deaf and hard-of-hearing Customers to facilitate access to financial services across
different channels. Assistance from a Polish Sign Language (PJM) interpreter is available in all Customer Centres.
Customers can also connect with a PJM interpreter online and book an appointment at a branch in PJM via an online form.
A PJM interpreter is also available on the helpline, enabling smooth remote communication. Additionally, the Bank provides
visual recordings of documents in PJM, and induction loops supporting hearing-aid users operate in 195 Customer Centres.
Customers may also request visual recordings of documents in PJM. Each branch is equipped with a magnifying glass and a
signature guide frame for Customers with visual impairments, and the Bank offers contract templates in audio format,
large-print versions and in Braille. Thanks to these solutions, deaf and hard-of-hearing Customers can use banking services
in a convenient and accessible way, tailored to their needs.
Banking services are also more accessible to Customers with visual impairments thanks to solutions that support safe and
independent use of banking. Blind and partially sighted Customers can review documents in audio format, in large-print
versions or in Braille. Branches are equipped with magnifying glasses and signature guide frames. Glass elements in
Customer Centres are appropriately marked to improve safety and comfort of movement, and ATMs have been adapted for
use by partially sighted Customers. In 2025, the number of ATMs equipped with accessibility features for partially sighted
or low-vision users – such as enhanced screen contrast – increased to 602 devices. Ninety-six of them were fully compliant
with the requirements of the Accessibility Act. In 2025, work began on equipping all ATMs with a voice-guidance function so
that the entire network meets the requirements of the Act.
The Bank regularly trains its employees in serving Customers with disabilities and implements the Standards for Serving
Customers from Vulnerable Groups. To ensure accessibility of products, services and branches, the Bank cooperates with
partner organisations: Dostępność Plus, Fundacja Integracja, Dostepny Bankomat, Krajowy Instytut Gospodarki Senioralnej,
Migam “RKPK” Sp. z o.o. S.K.A. and Fundacja DeafRespect.
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Digital accessibility
The Bank takes action aimed at increasing the digital accessibility of its services:
• In accordance with the requirements of the Act of 26 April 2024 on ensuring that economic operators meet accessibility
requirements for certain products and services, which implements Directive (EU) 2019/882 of the European Parliament
and of the Council of 17 April 2019 on the accessibility requirements for products and services, we submitted reports on
the level of service accessibility to national regulators: the Financial Ombudsman and the Ministry of Digital Affairs.
• The Bank cooperates with companies specialising in digital accessibility – Widzialnia and Accens – and plans to establish
cooperation with another company, Kinaole. The agreements in place allow, among others, for conducting service audits
in line with the WCAG standard as well as commissioning training and expert consultations.
• In 2025, the Bank conducted 10 audits of key digital channel services for Retail Customers.
• A schedule of further work was developed, covering: audits of additional services for Retail Customers, training (including
on document accessibility), expert consultations, and activities aimed at improving the accessibility of selected services in
digital channels.
Digital accessibility is a highly complex topic, difficult to interpret and requiring open dialogue between national regulators,
non-governmental organisations and industry representatives. Therefore, the Bank engages in initiatives in this area:
• we cooperate with the Polish Bank Association to develop a common and consistent interpretation of the Act and to clarify
the content of recommendations;
• we participates in the trialogue – meetings aimed at developing recommendations related to the digital accessibility Act.
These meetings involve national regulators, NGOs, the Polish Bank Association, representatives of the banking sector and
the e-commerce sector;
• we are a member of the Business Accessibility Forum (BAF), a platform for dialogue and cooperation that supports Polish
companies in implementing the requirements of the European Accessibility Act.
Plain language
Simplifying the language the Bank uses to communicate with its Customers is one of the important ways to enhance social
inclusion. Since 2019, the Bank has followed the plain language standard in its letters, messages, e-mail and text
messages, and promotional material. The rules cover communication with all Customer segments, from private individuals
to micro-enterprises and corporate Customers, as well as legal texts, including contracts and rules. More about approach
to plain language is presented in the section Filar POSITIVE.
Effectiveness of actions related to the identified negative impacts
The actions described above, divided into topic-specific (transparent and not misleading information, Customer satisfaction,
social inclusion) and transversal (training) actions, allow the Bank to effectively prevent, mitigate and correct identified
impacts on retail Customers. By monitoring complaints and NPS, the Group monitors to what extent its actions deliver the
expected results for retail Customers.
The Group also ensures the implementation of processes that address all material impacts and verify the effectiveness of
corrective actions. This includes assessing whether solutions, such as the response time rules for handling complaints
described above, actually deliver the expected results.
The effectiveness of initiatives and actions undertaken in relation to the Group’s key impacts is continuously monitored and
evaluated.
By using its internal risk management system and acting in compliance with personal data protection regulations (such as
the GDPR and the Regulation on Privacy and Electronic Communications), the Group prevents negative impacts on data
subjects in matters related to personal data protection, including areas connected with marketing practices and data use.
The personal data protection risk management process is the foundation of the system for assessing each data processing
operation and process for compliance with the GDPR and the Group’s personal data protection policy, taking into account
current or planned protection measures. This system also enables the implementation of the actions mentioned in the
section Actions for data protection, such as encryption or pseudonymisation. The Group’s Code of Conduct promotes the
highest ethical standards in this regard; in accordance with the Bank’s Personal Data Protection Policy, the Bank does not
sell the personal data of its Customers to its business partners.
Metrics and targets
Targets related to managing material negative impacts, advancing positive impacts, and managing
material risks and opportunities (S4-5)
Customer satisfaction
Thanks to the NPS Benchmark survey, the Bank knows the Customers’ propensity to recommend its services. The metric is
determined in cooperation with a market research institute. The key goal in the area of Customer satisfaction is to be a
TOP3 bank by Net Promoter Score. In 2025, the Bank was in the middle of the ranking (6
th
place at the end of 2025).
The Bank’s targets regarding its Customers are stable and measurable over time and are defined in the GObeyond strategy
for 2022-2025. The strategy was developed internally with the participation of employees representing all key areas of the
Bank, subsidiaries and the Customer Experience team and the Customer Ombudsman, who represented the perspective of
Customers. The objectives developed under the four pillars of the strategy, including those relating to Customers, are
described in detail in the chapter Implementation of the strategy, and the results of the strategy implementation are
presented in the section Strategy, business model and value chain (SBM-1) under General Disclosures (ESRS 2). The Bank
uses consistent definitions and measurement methodologies, which enables year-on-year comparison of results. Every
year, Customers can familiarise themselves with the Bank’s objectives and results by reading the Management Board’s
Reports on the activities of BNP Paribas Bank Polska S.A. Group and the Reports presenting non-financial information of the
BNP Paribas Bank Polska S.A. Capital Group published in previous years.
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212
Business conduct (ESRS G1)
Corporate governance
The Group’s adopted policies are presented below, including those relating to anti-corruption as well as other compliance
risk issues (financial security, market integrity).
Strategy: In relation to the themes identified, the Group’s strategy is determined by the impacts, risks and opportunities
(IROs) identified in the double materiality assessment. The material impacts, risks and opportunities related to the rules of
conduct and other compliance risk topics are presented below in the section: Managing impacts, risks, opportunities (IRO).
Principles: The principles in place to manage material impacts, risks and opportunities in business conduct and to manage
compliance risk are described in the section: Business conduct policies and organisational culture (G1-1).
Actions: Actions to mitigate business conduct risks and other compliance risk issues are also described.
Metrics and targets: The following indicators were adopted for business conduct and other compliance risk topics:
• percentage of employees in positions most exposed to risk of corruption covered by training programmes on corruption
and bribery;
• number of fines and penalties for violations of anti-corruption legislation.
The management of compliance risks is part of an overall risk management system that includes the identification and
assessment of risks and a set of actions to be taken against the identified risks.
Managing impacts, risks and opportunities (IRO-1)
As a result of the double materiality assessment described under General Disclosures (ESRS 2) in the section: Description of the processes for identifying and assessing material impacts, risks and opportunities (IRO-1, we identified a number of material
IROs related to business conduct.
Table 117. Summary of the links between material IROs and policies, actions, metrics and targets
Category
Material IRO
Policies, principles
Actions
Metrics
Targets
Negative impacts
Legal and reputational risks associated with
corruption or influence peddling
• Anti Money Laundering and Counter-Terrorist
Financing Programme
• Policy on reporting suspected irregularities
• Gift policy
• Anti-corruption policy
• Conflict of interest management policy
• Code of Conduct
• Know Your Customer (KYC) process
• Anti money laundering and counter-terrorist
financing / monitoring activity
• Reporting of suspicious transactions
• Negative information
• Business relationship review
• Transaction monitoring
• Percentage of people in positions most
exposed to risk of corruption covered by
training programmes on corruption and
bribery
• Number of fines and penalties for violations
of anti-corruption regulations
N/A
Positive impacts
Impact associated with adherence to values and
ethical standards by employees
• Code of Conduct
• Whistleblowing channels – reporting
discrimination, violence and mobbing
• Corrective measures (disciplinary and support
measures, follow-up), RCSA (operational risk
and control self-assessment), RiskCare
operational risk event records, Development
offer of the central programme #MyWay,
management training,
• Inclusion, diversity and Code of Conduct Group
employee survey
• Training and skill development metrics
• eNPS at 20 points (2025)
• employee Net Promoter Score
N/A
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Category
Material IRO
Policies, principles
Actions
Metrics
Targets
Risks
Legal risks associated with not identifying
suspicious Customer activity
• Anti Money Laundering and Counter-Terrorist
Financing Programme
• Sanctions and Embargoes Transaction Verification
Rules
• Sanctions Policy
• BNP Paribas Customer Acceptance Policy (KYC Policy)
• Financial Markets Transparency Policy
• Know Your Customer (KYC) process
• Anti money laundering and counter-terrorist
financing / monitoring activity
• Reporting of suspicious transactions
• Negative information
• Business relationship review
• Verification of relations against sanctions
N/A
N/A
Business conduct policies and corporate culture (G1-1)
The table below shows the main policies for managing impacts, risks and opportunities relating to business conduct.
Table 118. Policies adopted regarding business conduct
Policy
Description of policy content
The scope of the policy and
possible exclusions
The most senior level in the undertaking’s
organisation that is accountable for the
implementation
Interaction with stakeholders
Code of Conduct
The Code of Conduct guides the actions of all individuals at all levels of the
organisation. Accordingly, all internal policies and procedures in the Group are
aligned with the Code where necessary. It consists of three parts:
• Mission and Values: helps to guide and inspire behaviour;
• Rules of conduct to be shared and applied
• Code of Conduct – provides useful guidance on how to apply the principles of
conduct.
BNP Paribas Group
President of the Management Board of BNP
Paribas Group
No interaction
The Code of Conduct is available via the Bank’s intranet
and website of the Bank.
It is available in Polish and English versions
BNP Paribas Bank Polska S.A. Group Policy
on Anyi Money Laundering and Counter-
Terrorist Financing
The Policy is the foundation on which the Group’s anti-money laundering and
counter-terrorist financing activities are based.
Group
Management Board
No interaction
Whistleblowing Policy
The Policy specifies the system implemented in the Group to enable Employees and
third parties to report, in full security and in accordance with the conditions defined
by the regulations, any breach or suspected breach of the law or the Group’s Code of
Conduct.
Group
Management Board
Availability of dedicated channels
Gift Policy
This Policy sets out the rules that Employees must follow regarding gifts and
invitations
Group
Management Board
Clause in agreements with contractors on Anti-
Corruption Principles
Anti-Corruption Policy
This Policy sets out the expectations of the Management Board of all employees, who
must actively participate in the fight against corruption in order to prevent and detect
corruption.
Group
Management Board
No interaction
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Policy
Description of policy content
The scope of the policy and
possible exclusions
The most senior level in the undertaking’s
organisation that is accountable for the
implementation
Interaction with stakeholders
Conflict of Interest Management Policy
The Policy aims to:
clarify the subject of conflicts of interest in the context of the Group’s activities and
more generally in the business context; outline the Group’s rules for identifying,
preventing and managing situations of conflict of interest.
Group
Management Board
No interaction
Policy on Verification of Transactions under
Sanctions and Embargoes
The Policy sets out standards, internal processes and minimum controls to mitigate
BNPP’s exposure to the risks associated with breaches of financial sanctions laws and
regulatory requirements and the risks associated with business relationships with
sanctioned parties.
Bank*
Management Board
No interaction
BNP Paribas Customer Acceptance Policy
(KYC Policy)
The Policy defines the principles of Know Your Customer, determines how the risk of
money laundering and terrorist financing (ML/FT) is managed and contains the
responsibilities regarding financial security measures towards the Bank’s Customers.
Bank*
Management Board
Customer acquisition
Market Integrity Policy
The Policy is a reference for market transparency. It addresses various regulatory
issues, in particular:
• issues related to market abuse,
• issues related to conflicts of interest,
• MiFID II market integrity requirements,
• benchmark regulation and IOSCO principles,
• FX market rules (Global Code of Conduct for the FX market),
• rules on transparency (crossing thresholds) and short selling).
Grupa
BNP Paribas
Management Board
No interaction
*regulation appropriately implemented in Group subsidiaries in accordance with the principle of proportionality
The described policies are subject to a monitoring process, as defined in the chapter Corporate Governance, section Internal
control system (including control and risk management system for the preparation of financial reports).
Adherence to the highest ethical standards is a requirement for all Group companies. All Group employees are obliged to
strictly comply with the laws, directives and regulations applicable in all areas, as well as with the professional standards
and internal regulations that apply to their activities. In the event of a potential discrepancy between the country’s
legislation and BNP Paribas’ ethical principles, employees are required to comply with the applicable Polish legislation if it
is more restrictive, while seeking ways to apply and comply with internal ethical principles.
Compliance with these principles, as detailed in the BNP Paribas Group Code of Conduct, is key to maintaining the Group’s
reputation and the trust placed in it by its Customers and business partners.
Code of Conduct
The Code of Conduct, which applies to all employees and all business lines, sets the direction for employees and guides
decisions at all levels of the organisation. In 2025, the Code was updated and aligned with changes in the regulatory,
normative and social environment. The fundamental principles of the Code and its anti-corruption appendix remained
unchanged; however, we introduced amendments relating in particular to the compliance culture, risk management and
the whistleblowing procedure, as well as updates to certain definitions and examples to reflect the evolution of our
environment and to incorporate best practices in ethics, integrity and sustainable development. These changes focused
primarily on three areas:
• permitted communication channels in the markets, ensuring the integrity of correspondence;
• data protection – in response to the growing importance of cybersecurity and confidentiality;
• alignment with international anti-corruption standards.
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In accordance with the BNP Paribas Group Code of Conduct, the Bank requires its employees to comply with specific
standards of conduct in the performance of their duties. For this purpose, mandatory training courses are made available to
all employees or to a dedicated group of employees as appropriate. More details in the section: Training and skills
development metrics (S1-13).
In accordance with the “Zero Tolerance to Fraud” principle, whenever an event is discovered that fulfils the characteristics
of a breach, including fraud, regardless of the form in which it was committed, the extent of the financial loss or lack of
loss, the Bank, with due diligence, takes all measures to identify those responsible, their mechanisms of action, facts of the
event and, if justified, apply sanctions, introduce corrective or preventive measures.
All employees are assigned a target: Compliance with the principles described in the Code of Conduct, which is assessed
during the annual appraisal process. The task of the Committee for Continuous Employee Assessment in BNP Paribas Bank
Polska S.A. is to analyse the assessment of each employee who does not comply with the compliance requirements (target:
“Compliance with the principles described in the Code of Conduct”) and the employee’s risk behaviour (target: “Risk
assessment and management”). In line with the principle of proportionality, in the smaller Group subsidiaries, the above
objectives are performed by a designated Conduct Officer.
The Disciplinary Committee decides on the application and type of disciplinary sanctions against the Bank’s employees
involved in any case of violation and other necessary actions related to the violation.
Furthermore, the Bank has an Ethics and Standards of Conduct Committee, the purpose of which is to initiate and monitor
initiatives aimed at popularising rules of conduct in all units in compliance with the Code of Conduct and to make
appropriate recommendations. The Committee’s meetings present key indicators (KPIs) related to compliance with the Code
of Conduct, as well as an assessment of the risks associated with the Standards of Conduct and the degree of
implementation of projects relating to these topics. At the Committee meetings, with the participation of the Management
Board, final decisions are taken on the recommendations presented, approving management information on conduct, and
approving solutions and resources appropriate to the scale and complexity of the business to effectively manage the Bank’s
activities.
The Code of Conduct includes:
• a section on mission and values to help create a positive impact and promote BNP Paribas’ corporate culture;
• a section on the principles of conduct to be followed and applied in various areas, such as:
Customer interests,
financial security,
compliance with market standards (market integrity),
conflicts of interest,
professional ethics,
respect for others,
protection of the Group,
commitment to society;
• “Code of Conduct in Practice”, which provides useful guidance on the application of rules of conduct, including:
decision-making,,
compliance with local and international laws,
reporting opinions and raising concerns,
additional responsibilities of managers;
• “Code of Conduct – Anti-Corruption”.
A survey of Group employees carried out in of 2025 confirmed a high level of commitment to the values and behaviours
defined in the Code of Conduct, as well as a good knowledge of the channels for whistleblowing (see below, section:
Whistleblowing system).
Managing conduct risk
All issues covered by the Code of Conduct are subject to policies and procedures that set out principles and processes
specific to each type of risk.
The policies and processes are part of the overall internal control system, which defines in particular the rules of risk
assessment, control, detection and handling of incidents, monitoring of corrective actions and communication of
management information. More information in chapter: Risks and opportunities, section: Control and monitoring of
operational risks.
Anti-Corruption, Anti-Money Laundering and Countering the Financing of Terrorism
The Group maintains systems to detect money laundering and terrorist financing operations, which are based on a set of
standards and controls and on the vigilance of employees, maintained through mandatory training programmes.
A system for the prevention and detection of corruption and influence peddling has been formalised and implemented.
More information below in the section: Prevention and detection of corruption and bribery (G1-3).
Respect for market integrity
The Group’s market activities, on behalf of Customers or for its own account, are subject to strict mechanisms for the
prevention and detection of market abuse and the management of confidential information and conflicts of interest.
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Countering tax avoidance and evasion
Comprehensive compliance with tax obligations is part of the Group’s commitments to economic and social responsibility.
In this context, policies and procedures have been implemented to ensure compliance with the applicable tax law
requirements.
The Group makes every effort to ensure the tax compliance of its Customers: including ensuring the correct application of
all regulations governing the withholding of taxes at source, as well as the remittance of these taxes to the competent tax
authorities. In addition, the Group fulfils its obligations to provide fiscal information to public authorities, both through
automated processes and at the request of the authorities, while ensuring that the data provided is as comprehensive and
of high quality as possible.
Protection of Customers’ interests
Protecting Customers’ interests is a priority for the Group. For this reason, it has decided to place this topic among the
most important issues in the Code of Conduct and establish a dedicated expertise area as part of the Compliance function.
More information: Consumers and end-users, section: Policies related to consumers and end-users (S4-1).
Whistleblowing system
The Whistleblowing System is governed by relevant policies and procedures adapted to Polish legal requirements, as well
as to the BNP Paribas Group’s standards under the French Sapin II act on combating corruption and business transparency.
All employees are required to be familiar with the standards and comply with the relevant laws, rules, internal regulations
and professional standards in all areas of the Bank’s activities. Any irregularities identified by employees should be
reported.
The whistleblowing system is also open to external parties, in particular former employees, suppliers and their
subcontractors, for information obtained during their activities for the Group.
The issues that can be reported include the following:
• acts of corruption and paid patronage or any offence which undermines integrity,
• cases of fraud,
• behaviour contrary to the rules on respect for persons (sexual and moral harassment, discrimination, aggression,
violence, acts of sexism),
• breaches of professional ethics,
• breaches of financial security rules,
• anti-competitive practice,
• violations of market integrity,
• violations of rules protecting Customers’ interests,
• unauthorised disclosure of confidential information, theft or leakage of data,
• violations of human rights and fundamental freedoms, of the health and safety of persons or of the environment,
committed by a Group entity, supplier or subcontractor to a supplier, in the context of a business relationship established
with the Group or one of its entities,
• violations of the Group’s policy on suppliers,
• violations of the Group’s policy on the use of social networks.
The whistleblowing regulations set out the reporting channels available to employees and external third parties, the
immediate timeframes for processing reports, data processing methods and the protection guaranteed to whistleblowers
including against retaliation.
Independent and secure communication channels available to employees and external third parties
The Whistleblowing process is governed by the Whistleblowing Policy in BNP Paribas Bank Polska S.A., which is designed to
protect the interests of the Bank, employees, Customers, third parties and to monitor compliance with the law. It defines,
among others, the communication channels through which potential violations can be reported. The Whistleblowing Policy
at BNP Paribas Bank Polska implementing the provisions of the Whistleblower Protection Act was updated in November
2025.
The Bank appointed dedicated Whistleblowing Officers who, while respecting the principles of confidentiality, ensure
impartial, independent and prompt investigation of each report.
Whistleblower protection
The Bank gives whistleblowers the opportunity to report suspected violations without fear of retaliation. Any retaliation e.g.
dismissal, discrimination, in particular with regard to recruitment, remuneration, promotion, training will be treated as a
breach of this policy. The same protection applies to employees who provide information in the course of the investigation,
persons who assist in making the report, persons associated with the whistleblower.
The whistleblowing system ensures the confidentiality of the identity of the whistleblower and the persons named in the
report, including the persons concerned by the report, as well as the information collected in the report and during the
investigation.
Authorised persons are responsible for the implementation of the protection rules, as well as for their compliance with the
rules applicable to the processing, recording and storage of personal data reported by the whistleblower.
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Processing alerts
Whistleblowing Officers are responsible for receiving reports and overseeing follow-up. These actions take place promptly
and with due diligence and impartiality. The processing of whistleblowing reports at every stage is subject to identity
protection and confidentiality.
The analysis of the admissibility of the report is carried out on the basis of the facts and documents provided in the report.
In the event of a positive preliminary diagnosis, an investigation is carried out. The report is analysed and investigated
independently using expert knowledge. Reported violations are verified within strict deadlines. The whistleblower is
informed at each stage of the process of the analysed case (i.e. acknowledgement of receipt of the notification, preliminary
result of the admissibility analysis or closure of the case after its analysis), unless there is a justified obstacle in sending
the information, e.g. an anonymous report was made without providing a contact address for the whistleblower.
Raising employee awareness
All Group employees are informed about the Code of Conduct and the whistleblowing system as part of mandatory training.
The rules relating to the whistleblowing system and how to use it are also communicated on the Bank’s website and
intranet.
Control
An internal control system is in place to verify that, among others, only authorised persons have access to reported
violations and that the verification of reports is carried out in accordance with the applicable regulations.
A report on the adequacy and effectiveness of the Whistleblowing Policy is submitted annually to the Management Board
and the Supervisory Board. In 2025, 12 alerts were reported through the Bank’s whistleblowing channels, the same as in
2024.
Training
All topics covered in the Code of Conduct are integrated into a training course called Conduct Journey. It is regularly
updated and enriched with topics on whistleblowing channels, diversity, equality and inclusion. The course was last
updated in 2025. The training develops the core principles outlined in the Code of Conduct, discusses expected employee
behaviour and addresses the issue of detecting and preventing fraud.
New employees, upon joining the Group, are systematically enrolled in financial security training (Know Your Customer,
anti-money laundering, counter-terrorist financing, international sanctions and embargoes).
Employees who are particularly exposed to certain risks receive advanced training. Management Board members also
participate in the Conduct Journey programme and security training.
Table 119. “Conduct Journey” training for employees and managers on anti-corruption policies and procedures in 2024
and 2025
year
2025
2024
Type of training
“Conduct Journey” on
conduct – 2025
edition
(Compliance) – anti-
bribery and
corruption – most
exposed employees
“Conduct Journey” on
conduct
(Compliance) – anti-
bribery and
corruption – most
exposed employees
Number of employees
attending training
6,738
3,018
(1)
7,119
493
Percentage of
employees in
corruption-exposed
roles who completed
the training
n/a
44.8%
n/a
6.9%
Type of training
e-learning
e-learning
Duration and frequency
1.5 h – every year
40 minutes – every
two years
1.5 h – every year
40 minutes – every
two years
Completion rate
99.9%
98.8%
99.7%
96.8%
(1) In 2025, a larger number of employees were assigned to anti-bribery and anti-corruption training, which is why the percentage of employees in corruption-exposed roles who completed the training is
higher. For comparison, the combined percentage of employees in corruption-exposed roles who completed the training in 2024 and 2025 is 48.36%. The data has been adjusted to exclude employees on
long-term leave.
Prevention and detection of corruption and bribery (G1-3)
The Bank has implemented standards for the prevention and detection of corruption and bribery. The standards have been
developed taking into account the requirements of Polish law and extraterritorial regulations (the French Sapin II Act, the
UK Bribery Act and the US Foreign Corrupt Practices Act). The anti-corruption standards are included in the “Anti-
Corruption Policy” and are updated taking into account the results of the corruption risk assessment. The regulation
provides guidelines for the identification and mitigation of corruption risks and defines the main principles of conduct and
responsibilities in this area. With the adoption of the aforementioned regulation, all incidents that are – even potentially –
corrupt in nature are monitored.
The ABC (Anti-Bribery and Corruption) standards are maintained by means of:
• Anti-corruption statement by the BNP Paribas Group CEO confirming BNP Paribas’ zero tolerance for corruption and
influence peddling.
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• Governance: overseen by a dedicated Compliance Team responsible for designing and coordinating ABC standards and
overseeing a network of ABC Correspondents present across business lines and functions.
• Corruption risk assessment: corruption risks are regularly assessed, and the results of the risk assessment are presented
to the Management Board. The risk assessment methodology allows for a detailed assessment of corruption risks based
on scenarios assessed by the business lines and functions and their prioritisation (through risk factors), as well as action
plans to counter corruption risks.
• The Group’s Code of Conduct, which includes the appendix “Code of Conduct – Anti-Corruption” and examples of
prohibited situations or those that should come to the attention of employees if encountered. Policies related to the Code
of Conduct are also available, such as policies on gifts and invitations, lobbying, conflicts of interest, philanthropy and
sponsorship, providing guidance to employees on how to ensure that these issues address corruption risks.
• Whistleblowing standards: Group employees have access to whistleblowing channels to report any violations of the “Code
of Conduct – Anti-Corruption”.
• Due diligence processes: the Bank’s standards set out due diligence requirements in relation to Customers (including
politically exposed persons), intermediaries, suppliers and other types of third parties. This enables the identification and
management of counterparties most exposed to particular corruption risks (such relationships are subject to specific risk
mitigation measures). A tool for analysing adverse information related to third parties has also been implemented.
• Control mechanisms to manage corruption risks: the Bank’s control framework is organised around three lines of defence,
with the business units responsible for first-line controls, the second line of defence carried out by units such as
compliance, risk, finance, and audit as the third line of defence with periodic audits, including on ABC. An anti-corruption
(including financial) internal control system is in place to mitigate the risk of corruption Analysis of corruption-related
operational events is carried out quarterly and the results are included in the risk assessment. All these control functions
and key metrics enable ABC standards to be monitored and negative results to be addressed with recommendations or an
action plan.
• Training and communication: (see below: Training).
• Disciplinary system: any suspected corruption involving a Bank employee is analysed and appropriate disciplinary
sanctions are imposed if violations are confirmed.
The Bank continuously evaluates the management and control system (procedures, reporting, controls, training)
implemented to counteract corruption. Appropriate internal regulations in this regard are implemented and updated on an
ongoing basis. Central oversight is given to the creation of corruption risk maps and the analysis of corruption-related
information from reporting. The Managing Director of the Compliance Monitoring Division appoints persons to act as ABC
Correspondents, whose tasks include coordinating anti-corruption activities. In the event of suspected corrupt activities, an
independent anti-fraud unit conducts an investigation. As part of its anti-corruption efforts, the Bank monitors metrics such
as reported cases of fraud, identified conflicts of interest, gifts and invitations accepted/given, due diligence in establishing
relationships with Customers/contractors/intermediaries, and the level of employee awareness. IT solutions have also been
developed to enable more effective monitoring of key corruption indicators.
We expect our business partners (suppliers, counterparties, contractors working with the Bank and its Customers on behalf
of the Bank) to act in accordance with the principles set out in the Group’s Code of Conduct. An ethics and anti-corruption
clause is an integral part of every contract the Bank enters into with its suppliers and business partners.
Applicable policies in the area of anti-corruption are listed above in Table 118 Policies adopted for business operations.
Training
The anti-corruption process must be known and understood by all Bank employees. For this purpose, appropriate training is
provided that is accessible to all employees, and there is regular internal communication in this regard.
We have implemented mandatory Code of Conduct training for all employees, one module of which is dedicated to the topic
of anti-corruption. All Group employees must receive training on corruption and influence peddling as part of the Conduct
Journey training.
Employees most exposed to risk of corruption must also participate in specialised training, adapted to their specific
activities, throughout the period in which they hold these positions. Positions are identified by taking into account risk
mapping (those working with third parties or performing high-risk activities) and by identifying those responsible for
implementing the anti-corruption system. Among those most at risk of corruption, the Bank has included employees
involved in sales, purchasing, recruitment, real estate processes. ABC Correspondents, auditors, senior managers,
Whistleblowing Officers are also subject to extended anti-corruption training due to their functions.
The ABC Correspondents prepare training courses and workshops dedicated to specific units of the Bank. In addition, the
Bank has a dedicated intranet page where the anti-corruption system is described.
Metrics and targets
Confirmed incidents of corruption or bribery (G1-4)
Neither the Bank nor any Group entity has been convicted or fined for violations of anti-corruption or anti-bribery
legislation in the last five years.
All reports of violations of anti-corruption procedures and standards are promptly investigated by an independent, non-
involved entity and are then included in the overall analysis of the anti-corruption system in order to identify possible
corrective actions at a systemic level. See Prevention and detection of corruption and bribery (G1-3). Members of the
Management Board and the Supervisory Board are informed of reported cases of corruption or bribery.
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Additional information on the entity
Market integrity
General information
Open and transparent markets are essential for economic development. The Bank is committed to helping maintain and
preserve transparency in financial markets. We define it as the need to ensure the fair and safe functioning of markets in
order to instil the widest possible confidence in them and promote high levels of savings and investment.
The framework for ensuring market integrity has been developed in strict compliance with regulations and is based on the
following pillars:
• operational policies and procedures;
• IT tools;
• specialised teams of staff;
• an independent internal control and audit system;
• a continuing education programme.
It consists of two main activities:
• management of inside information and conflicts of interest;
• monitoring capital markets transactions and contributing to the smooth functioning and transparency of the markets.
Governance
Policies and processes
The Bank has a Market Integrity Protection Policy, which is a set of key provisions on the principles of financial market
transparency. It defines the rules and controls to prevent and detect market abuse and addresses the detection and
management of conflict of interest situations. The policy defines key roles in the processes related to the prevention of
market abuse and is based on the market abuse regulations (MAR) as well as selected aspects of the MIFID requirements.
The policy addresses issues such as detection and prevention of market abuse (price manipulation, benchmark
manipulation or insider trading), management of inside information, management of conflicts of interest, rules on
benchmarks, as well as rules of conduct in the foreign exchange market.
Management of inside information and prevention of conflicts of interest
The Bank and the Group comply with the applicable laws and regulations, both at European and international level, as well
as with the best practices and recommendations of the competent national authorities regarding the protection of inside
information.
Accordingly, the Bank ensures that inside information is properly processed and circulated and that an internal mechanism
is in place to determine the nature of this information and to decide when it is made public.
Inside information, as well as persons with access to inside information, is subject to registration. Administrative and
organisational arrangements such as information barriers and organisational separation of banking activities (such as
investment banking, proprietary trading and asset management) are maintained to guarantee the confidentiality of inside
information and prevent its use.
In addition, the Bank has implemented a system to prevent and manage conflicts of interest and, where applicable,
transactional conflicts of interest, while detecting or appropriately managing situations of conflict of interest related to
market activities.
We have a process in place at the Bank to detect and manage situations of potential conflict of interest involving BNP
Paribas Group entities by maintaining and managing lists of issuers or Customers.
All persons with access to inside information are required to comply with rules of conduct, an essential element of which is
the proper management of inside information and information relating to situations of conflict of interest.
Managing impacts, risks and opportunities (IRO)
Monitoring transactions and contributing to the proper functioning and transparency of the markets
In order to protect market integrity and prevent the dissemination or misuse of inside information, we have put in place an
internal system to prevent market abuse. This system prevents, supports the detection and reporting of market abuse. In
particular, it prevents insider trading, price manipulation and the disclosure of information regarding brokerage orders or
transactions placed by Customers or by the Bank (when acting on its own account, as a counterparty).
Detected orders or transactions that may constitute market abuse are the subject of a notification (STOR ‘Suspicious
Transaction Order Report’) to the relevant regulatory authority (authorities).
The Bank monitors transaction orders in relation to all brokerage activities and fulfils obligations regarding pre- and post-
trade transparency and the submission of notifications regarding transactions involving the financial instruments it
executes.
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In addition, in certain business areas, the Bank has implemented monitoring of recordings of voice and electronic
communications, in accordance with the regulations and guidelines of the Regulator.
Incidents
As part of the Market Integrity Protection Policy, the Bank has a process in place to identify incidents of non-compliance,
including breaches that could develop into market abuse. Reporting under this process takes place quarterly and concerns
identified market abuse for personal transactions in financial instruments and market abuse (for inside information or
suspicious transactions and orders).
Reporting path and systems
Reporting to the Bank’s Management Board, Audit Committee and Supervisory Board takes place periodically as part of the
management information system and the compliance function’s reporting system.
Financial market abuse is reported to the Polish Financial Supervisory Authority in Suspicious Transaction Order Reports
(STOR).
The Bank uses IT systems to identify potential fraud in personal transactions or financial market abuse, mechanisms to
manage inside information and solutions to identify and manage situations of conflict of interest.
Training
Employees complete mandatory e-learning training, regarding market abuse and personal transactions, which covers
topics related to financial market integrity.
In addition, for selected employees of the Ethics and Market Transparency Team who perform tasks strictly related to
countering price manipulation, benchmarks or insider trading, additional, more detailed training is provided on topics in the
area of market integrity.
Financial security
General information
BNP Paribas Bank Polska S.A., as part of the BNP Paribas Group, is obliged to comply with international sanctions and to
combat money laundering, terrorist financing and corruption. The BNP Paribas Bank Polska Group has implemented, in line
with the scope of its activities in the companies, procedures governing the area of financial security. Through internal
policies, it implements legal requirements, recommendations and guidelines of regulators, and seeks to minimise risks
related to money laundering and terrorist financing. It constantly adapts to the changing business and regulatory
environment by systematically reviewing market trends, changes in Customer assessment profiles and transactions. It
takes into account new developments leading to the introduction of funds from illegal sources into financial circulation. It
adapts internal rules for the operation and prevention of such phenomena to these events, implementing more modern
solutions and improving existing tools. One of the objectives of the policies is to ensure the highest level of knowledge of all
those involved in the prevention of money laundering and terrorist financing through continuous training, which in the long
term will translate into an increased level of financial security for the Bank and the Group.
Governance
In pursuit of the above commitments, the Bank implements and continuously updates its financial security policies, which
consist of:
• Know Your Customer Policy (KYC),
• Anti-Money Laundering and Counter-Terrorist Financing Programme,
• Policy on the application of international sanctions,
Know Your Customer Policy (KYC)
The Bank has implemented a Customer Acceptance Policy in BNP Paribas Bank Polska S.A. (“KYC Policy”), Know Your
Intermediary Policy (“KYI Policy”), Know Your Supplier Policy (“KYS Policy”), Policy on relationships with categories of
persons or entities other than those indicated above (“KYX Policy”). All of the Bank’s financial security policies are updated
on an ongoing basis. The Bank continuously reviews its procedures and instructions, adapting them to the dynamic legal
environment, including both domestic regulations and international standards. Ongoing strengthening of financial security
helps avoid exposure to risks and ensures full regulatory compliance.
The purpose of these policies is to implement the necessary arrangements to ensure that the Bank avoids entering into
business relationships with individuals and entities involved in suspicious, illegal or unethical activities or put on sanctions
lists. The primary purpose of the policies is to protect the reputation and good name of the Bank, to set standards of due
diligence in relation to knowledge of the Customer, supplier, intermediary and any other uncategorised relationship, by
setting the scope for applying financial security measures, assessing the risk of money laundering and terrorist financing
and deciding whether to establish or continue a relationship with these entities. This is an essential component of the
AML/CTF process and compliance with international financial sanctions.
Besides financial security risks, these policies help to assess and manage other risks related to the Bank’s relationships
with third parties, such as market integrity, protection of Customer interests, reputational risks and ESG risks.
The Bank’s Customer Acceptance Policy fulfils the obligation to apply the financial security measures set out in the Act of 1
March 2018 on the prevention of money laundering and terrorist financing. It covers with its scope the principles
concerning:
• identification, verification and updating of information on the identity of Customers;
• Identification of the beneficial owner and the actions taken in connection with the need to establish the identity of the
beneficial owner and, in the case of legal persons, to establish the ownership and control structure of the Customer;
• Identify other related persons, including those acting on behalf of and for the Customer;
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• Understand and obtain information on the purpose and intended nature of the business relationship;
• Conduct continuous monitoring of the business relationship and control of transactions undertaken during the course of
the relationship to ensure that the transactions carried out are consistent with the Bank’s knowledge of the Customer,
its business and risk profile, including, where necessary, the source of funds;
• The application of enhanced due diligence in relation to high-risk Customers, politically exposed persons, correspondent
banking and situations of increased risk (connection to a high-risk third country, corruption risk, etc.);
• Factors taken into account in the Customer risk assessment process.
The KYC policy defines the scope of information collected and analysed for each type of Customer (individuals, corporations,
financial institutions, public entities, etc.). It describes the methodology used to determine the due diligence measures to be
applied, using a risk-based approach in line with applicable legislation and the recommendations of The Financial Action
Task Force (FATF). It also defines the roles and responsibilities of the various teams involved in the KYC process, from data
collection to compliance checks on internal procedures.
The KYI, KYS, KYX policies set out similar precautions to be taken, in line with a risk-based approach, for intermediaries,
suppliers and other parties who are not Customers, intermediaries or suppliers (e.g. beneficiaries of donations, participants
in trade finance transactions, etc.)
Anti-money laundering and counter-terrorist financing programme
The Programme is a strategic document indicating the course of action followed by the Bank as an obliged institution in the
implementation of its obligations under the Act of 1 March 2018 on preventing money laundering and terrorist financing.
The main objectives are to reduce the Bank’s exposure to money laundering and terrorist financing risks by implementing
top-quality solutions and improvements to mitigate these risks.
The programme includes:
• a description of the activities or actions taken to mitigate the risks of money laundering and terrorist financing and to
properly manage the identified risks of money laundering or terrorist financing;
• principles for identifying and assessing the risk of money laundering and terrorist financing associated with the business
relationship concerned, including principles for verifying and updating the prior assessment of the risk of money
laundering and terrorist financing;
• measures applied to properly manage the identified risks of money laundering or terrorist financing associated with the
business relationship concerned;
• rules on the application of financial security measures;
• rules on record keeping and information;
• rules on fulfilling obligations involving the transmission of transaction data and notifications to the General Inspector of
Financial Information;
• rules on the dissemination of knowledge of the provisions of the Act on preventing money laundering and terrorist
financing among employees;
• rules on reporting by employees or other persons performing activities for the Bank on actual or potential violations of
the AML/CTF provisions;
• rules on internal control or supervision of the Bank’s compliance with the AML/CTF regulations and the rules of conduct
set out in the internal procedure;
• rules on noting discrepancies between the information gathered in the Central Register of Beneficial Owners and the
information on the Customer’s beneficial owners;
• rules on documenting the impediments identified in connection with the verification of the identity of the beneficial
owner and the actions taken in connection with the identification as beneficial owner of an individual holding a senior
management position;
• means of designating the person responsible within the Bank for the implementation of the obligations set out in the Act
and the list of duties involved;
• means of appointing the Programme Coordinator (AMLRO) and his/her tasks, as well as the identification of a
replacement in case the Coordinator is unable to perform their tasks;
• the AML/CTF responsibilities of all Bank employees.
Bank’s international sanctions policy
We have developed a set of policies and procedures to ensure uniform standards in complying with international sanctions
regulations. In particular, the policy adopted at the Bank, based on the relevant legislation and the Bank’s internal risk
assessment, is not to process or otherwise engage in activities or transactions, regardless of currency:
• for, on behalf of, or for the benefit of, directly or indirectly, individuals, entities or organisations subject to sanctions
imposed by Poland, France, European Union or United States, United Nations or other applicable local sanctions
authorities, or involving, directly or indirectly, countries or territories subject to comprehensive sanctions, including the
Crimea/Sevastopol area, territories over which Ukraine has lost control due to the Russian aggression (Donetsk, Kherson,
Luhansk, Zaporozhe), Cuba, Iran, North Korea and Syria; or
• in any way associated with persons, entities, organisations or territories that may be affiliated with or controlled by a
terrorist organisation recognised as such by the relevant authorities in Poland, the European Union, the United States
and the United Nations;
• in 2025, the Bank introduced the Russia Questionnaire, which enables the identification of any links to Russia at the level
of the Customer as well as their parent company or subsidiaries.
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It is the Bank’s policy that when a country, territory or region with a high level of financial security risk is directly or
indirectly involved (for example, AML/CTF risk, particularly based on FATF or European Union (EU) classifications,
corruption risk confirmed by the World Bank, risk of circumvention of sanctions, country/territory/region subject to
targeted/sectoral sanctions, lack of cooperation with the EU on tax issues, economic instability, political instability, war,
conflict, proliferation), the Bank may on a case-by-case basis and regardless of currency:
• refuse to enter into a relationship,
• close an existing relationship,
• refuse to process certain transactions, or
• decide not to engage in certain activities or transactions.
In order to implement this policy, the Bank has implemented and is continuously improving tools to control the Bank’s
Customer database and to ensure the filtering of transactions in order to comply with legal requirements.
Managing impacts, risks and opportunities
The risks associated with money laundering and terrorist financing, as well as the Bank’s potential exposure to
international sanctions, are constantly evolving. The Bank undertakes a number of measures in an effort to mitigate these
risks and improve the security of the financial market. As part of the BNP Paribas Group, in addition to the requirements
resulting directly from Polish law, it introduces restrictive rules to secure the products and processes offered to its
Customers. One of the factors mitigating risk exposure is training
Training
The Bank provides comprehensive training programmes for those performing AML/CTF duties. Training includes onboarding
training (prior to the commencement of official activities) and regular training with knowledge updates. Training materials
are provided through an e-learning platform, as well as in the form of meetings with staff responsible for implementing the
Bank’s financial security policies. Training aims to continuously improve the competences of employees, thereby reducing
the risks to which the Bank and the Group are exposed.
Cybersecurity
General information
In the constantly evolving landscape of the global financial industry, the Group recognises the crucial role of cybersecurity
in maintaining operational resilience. The Group faces challenges related to ensuring the security, confidentiality, and
integrity of its data, as well as the stability and resilience of its information and communication technology (ICT) systems.
The interconnected nature of its operations, combined with the rapid pace of technological advancement and the growing
need to rely on external entities to provide critical services, requires a strategic and adaptive approach to risk
management. The Group is exposed to cybersecurity risk, including risks arising from malicious and/or fraudulent actions
carried out virtually with the intent to manipulate information (confidential, banking, technical, or strategic data),
processes, and users, in order to cause significant losses to the Group.
Regulatory authorities now consider cybercrime to be a growing systemic risk for the financial sector. They have stressed
the need for financial institutions to improve their resilience to cyber-attacks by strengthening internal IT monitoring and
control procedures. A successful cyber-attack could therefore expose the Group to a regulatory fine, especially should any
personal customer data be lost.
Risks associated with cyber-attack are currently one of the key elements which every organisation needs to consider from
the perspective of its business model, operations and value chain. Every successful cyber-attack, system failure, disruption
of IT services, confidential data breach impacting the Group or its vendors could lead to serious financial losses, penalties
from supervisory authorities and have an adverse effect on reputation, operating results and financial position of the Group.
During the double materiality assessment (DMA), cybersecurity risk was estimated on a medium level.
The Bank implemented a third party technology risk management framework that governs ICT risk management with
internal and external entities, both in procurement and in partnerships, in line with Group guidelines. The Bank follows a
risk-based approach covering identification, assessment, contracting, implementation, monitoring and termination of
services. The framework incorporates the requirements of the European Digital Operational Resilience Act (DORA), defines
stakeholder responsibilities and introduces appropriate controls, taking into account the level of third party risk as well as
the criticality and nature of the services provided.
In 2025, the Bank’s cybersecurity initiatives were recognised both locally and internationally. The Bank received the
Cybersecurity Golden Shield award in the Złoty Bankier competition for the highest standards in data protection and digital
security. The award was based on an independent audit (RiskRecon, CyberQuant) and an assessment of our cybersecurity
education initiatives. BNP Paribas Bank was also the winner of the Forrester’s 2025 Security & Risk Enterprise Leadership
Award, recognising its leadership in cybersecurity, customer trust, excellence in security and risk management, and its
efforts to empower customers through education and innovation in digital security.
Governance
The Bank oversees cybersecurity through dedicated governance based upon developed and implemented procedures and
policies on information technology and security of the ICT environment, originating from the objectives defined in the
Bank’s IT Strategy IT@Scale, local regulatory recommendations and legislation, as well as the Group’s standards. The
strategy is periodically reviewed/updated, at least once a year and progress is reported to the Bank’s Management Board
and Supervisory Board. The current strategy covers the period 2022-2025. The risks associated with the activities carried
out under the strategy are monitored, identified and mitigated.
In order to increase the effectiveness of the supervision and control of the ICT environment security, to ensure effective
communication and compliance of its activities with the Bank’s objectives and needs, a Security and Business Continuity
Management Committee and an IT Architecture Committee were established with the Vice-President in charge of New
Technologies and Cybersecurity as chairperson. The tasks of these committees include overseeing and controlling the
security of the ICT environment, ensuring effective communication, compliance with objectives and needs. The tasks and
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working procedures of these committees are governed by dedicated rules of procedure. Relevant topics from an operational
risk perspective are also presented at the Internal Control Committee (ICC).
The Security and Business Continuity Management Division has been operating within the Bank’s structure since September
2015. The activities of this Division are defined around key responsibilities:
• Secure Customer: secure service in digital channels, innovative and secure authentication and authorisation method.
Continuous education of Customers on secure banking.
• Secure Bank: continuous improvement of security infrastructure, effective vulnerability management and efficient incident
response, building robust business continuity and crisis management plans fit for purpose, innovative approach to
building employee awareness and competence.
• Compliance & innovation: full alignment with the BNP Paribas Group Cybersecurity Programme, strengthening the
Agile@Scale digitisation programme and partnerships, extensive sector and cross-sector collaboration, secure use of
Open-API collaboration, regulatory compliance.
Particular emphasis is placed on raising the Group’s employees’ awareness of good cybersecurity practices. Each year,
employees complete mandatory online training modules, and a set of “golden rules” to be followed within the organisation
is regularly shared and updated. Employees are also systematically reminded of the Group’s phishing reporting process to
ensure an appropriate level of vigilance and risk awareness at all levels of the company.
The Managing Director of the Security and Business Continuity Management Division (Chief Security Officer) ensures that
the management of cyber-security and information and communication technology (ICT) risks is consistent with local
regulations and the BNP Paribas Group’s standards. The CSO is responsible for the implementation of appropriate policies,
best practice and guidelines, and for the implementation of security requirements defined by the Group under the
Cybersecurity Programme. The CSO oversees corrective projects which mitigate identified cybersecurity risks.
Managing impacts, risks and opportunities (IRO-1)
Table 120. Summary of the links between material IROs and policies, actions, metrics and targets
Category
Material IROs
Policy
Actions
Metrics
Targets
Risks
Operational risk caused by cyber
attacks
• Information Security Policy
• ICT Security Policy
• Framework requirements
translated into actions
and action plans
• Key Performance Indicators (KPIs)
• BNP Paribas Group Cybersecurity Programme.
• IT@Scale strategy
• Target maturity broken down by entity under the
BNP Paribas Group Cybersecurity Programme
• Implementation of the IT@Scale strategy
Reputational risks caused by
cyber attacks
Legal risks caused by cyber
attacks
Policies and procedures related to cybersecurity in the Bank
Table 121. Policies adopted in the course of business
Policy
Description of policy content
The scope of the policy
and possible exclusions
The most senior level in the undertaking’s
organisation that is accountable for the
implementation
Dialogue with stakeholders
Information Security Policy
The Policy defines the basic principles for ensuring the security of the Bank’s tangible
and intangible assets, including information assets, in order to provide high-quality,
Bank*
Management Board of the Bank
Internal document
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Policy
Description of policy content
The scope of the policy
and possible exclusions
The most senior level in the undertaking’s
organisation that is accountable for the
implementation
Dialogue with stakeholders
Customer-oriented services and maintain a high level of Customer confidence in the
Bank.
ICT Security Policy
Security framework for ICT and ICT-related risk management
It consists of a set of documents (policies, recommendations and standards) that
define the basic requirements for information security
Bank*
Management Board of the Bank
Internal document
*The regulation has been implemented in the subsidiaries of the Group in accordance with the principle of proportionality
Within the Bank’s ICT and cyber risk management framework, there is a specific framework for cybersecurity, composed of
a set of documents (policies, procedures, processes and standards) that define the basic requirements for cybersecurity,
offering a standardised approach to mitigating risks. These are aligned with industry best practices. This ensures consistent
implementation of processes and associated controls within the Bank, strengthening the overall cybersecurity profile.
The Bank remains compliant with data protection regulations and principles i.e. the principles of GDPR are applied. The
Bank has implemented the Personal Data Protection Policy, which ensures the management of confidential and sensitive
information, the protection of personal data in accordance with current legislation and the recommendations of the
competent authorities. The Bank has an Information Security Policy, certified under ISO 27001, an ICT Security Policy and a
Business Continuity Management Policy certified under ISO 22301. Cybersecurity best practices are available to employees
and regular awareness campaigns are performed.
The Bank has also implemented a procedure: Principles for Information Security and Cybersecurity Incident Management,
which includes principles for dealing with incidents of security breaches of the IT environment, with a clear indication of
the responsibilities of the various participants in the process.
As part of its business continuity management, the Bank has developed, implemented and periodically tests a number of
different scenarios to which it may be exposed, assessing their potential impact on the continuity of business processes and
services.
Metrics and targets
Targets
The Group applies the requirements defined in the cybersecurity targets originating from the IT strategy of the Bank,
binding regulations and standards as well as the BNP Paribas Group Cybersecurity Programme. A proactive approach is
used as to ensure compliance with the cybersecurity targets by efficiently allocating the scope, applicability, timelines,
necessary resources, including human, technological and budget resources. This proactive approach prioritises activities
based on risk level, regulatory mandates and operational objectives. This translates into concrete actions and initiatives.
The sequence of activities is organised based on the level of risk, regulatory deadlines and operational objectives. Emphasis
is placed on establishing clear responsibilities and deadlines for each task to ensure effective execution.
The progress of each cybersecurity target is monitored in line with Bank’s IT Strategy IT@Scale for 2022-2025, which
identifies major objectives and specific quantified targets.
Metrics
In order to measure cybersecurity resilience, internal Key Performance Indicators (KPIs) have been implemented in the
Bank.
Each year, the Security and Business Continuity Management Division, under the BNP Paribas Group Cybersecurity
Programme, takes part in a number of campaigns in order to assess compliance with the BNP Paribas Cybersecurity
Programme objectives. The results are announced to management during meetings organised within the Cybersecurity
Panorama initiative in the BNP Paribas Group.
Progress of IT@Scale strategy implementation is regularly discussed by the Management Board and monitored by
dedicated teams, which focus on presenting the progress of each initiative integrated into the strategy, supervision of KPIs
delivery and assigned budget execution.
Moreover, the Group regularly conducts internal controls and audits of the implementation of requirements relating to IT
governance, ICT risks, cybersecurity and ISO standards. These activities ensure compliance with legislation, standards and
recommendations of supervisors. Where areas of non-compliance are identified, recommendations are developed with an
agreed pace of implementation.
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Appendix 1
Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement (IRO-2)
Table 122. Disclosure Requirements in ESRS covered by the undertaking’s Sustainability Statement
Disclosure requirements
Page
ESRS 2 General disclosures
135
BP-1 General basis for preparation of sustainability statements
135
BP-2 Disclosures in relation to specific circumstances
157
GOV-1 The role of the administrative, management and supervisory bodies
135
GOV-2 Information provided to and sustainability matters addressed by the undertaking’s administrative, management
and supervisory bodies
135
GOV-3 Integration of sustainability-related performance in incentive schemes
139
GOV-4 Statement on due diligence
140
GOV-5 Risk management and internal controls over sustainability reporting
141
SBM-1 Strategy, business model and value chain
141
SBM-2 Interests and views of stakeholders
146
SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model
154
IRO-1 Description of the processes to identify and assess material impacts, risks and opportunities
150
IRO-2 Disclosure requirements in ESRS covered by the undertaking’s sustainability statement
159
ESRS E1 Climate change
160
E1-1 Transition plan for climate change mitigation
160
ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model
154
ESRS 2 IRO-1 Description of the processes to identify and assess material climate-related impacts, risks and opportunities
150
E1-2 Policies related to climate change mitigation and adaptation
167
E1-3 Actions and resources in relation to climate change policies
170
E1-4 Targets related to climate change mitigation and adaptation
174
E1-5 Energy consumption and mix
175
E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions
175
Disclosure requirements
Page
E1-7 GHG removals and GHG mitigation projects financed through carbon credits
177
E1-8 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
177
ESRS S1 Own workforce
181
ESRS 2 SBM-2
181
ESRS 2 SBM-3
154
S1-1 Policies related to own workforce
184
S1-2 Processes for engaging with own workers and workers’ representatives about impacts
187
S1-3 Processes to remediate negative impacts and channels for own workers to raise concerns
188
S1-4 Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing
material opportunities related to own workforce, and effectiveness of those actions
189
S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks
and opportunities
194
S1-6 Characteristics of the undertaking’s employees
195
S1-7 Characteristics of non-employee workers in the undertaking’s own workforce
196
S1-8 Collective bargaining coverage and social dialogue
197
S1-9 Diversity metrics
197
S1-10 Adequate wages
198
S1-11 Social protection
198
S1-12 Persons with disabilities
198
S1-13 Training and skills development metrics
199
S1-14 Health and safety metrics
199
S1-15 Work-life balance metrics
199
S1-16 Compensation metrics (pay gap and total compensation)
200
S1-17 Incidents, complaints and severe human rights impacts
200
ESRS S4 Consumers and end-users
201
ESRS 2 SBM-2 Interests and views of stakeholders
146
ESRS 2 SBM-3 impacts, risks and opportunities and their interaction with strategy and business model
154
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governance
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226
Disclosure requirements
Page
S4-1 Policies related to consumers and end-users
203
S4-2 Processes for engaging with consumers and end-users about impacts
204
S4-3 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
205
S4-4 Taking action on material impacts on consumers and end-users, and approaches to managing material risks and
pursuing material opportunities related to consumers and end- users, and effectiveness of those actions
207
S4-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks
and opportunities
211
ESRS G1 Business conduct
212
ESRS 2 GOV-1 The role of the administrative, supervisory and management bodies
135
ESRS 2 IRO-1 Description of the processes to identify and assess material impacts, risks and opportunities
150
G1-1 Corporate culture and business conduct policies and corporate culture
213
G1-3 Prevention and detection of corruption and bribery
217
G1-4 Confirmed incidents of corruption or bribery
218
Cybersecurity
222
ESRS 2 IRO-1 Description of the processes to identify and assess material climate-related impacts, risks and opportunities
223
Market integrity and financial security
219
Table 123. List of datapoints in cross-cutting and topical standards that derive from other EU legislation
Disclosure Requirement and related datapoint
Appendix B – ESRS 2 (SFDR +
Pillar 3
+ Benchmark
+ CL)*
Page / Not applicable /
Phase-in / Not material
ESRS 2 GOV-1 Board's gender diversity paragraph 21 (d)
SFDR Annex I, Commission
Delegated Regulation (CDR)
(EU)
2020/1816, Annex II
276
ESRS 2 GOV-1 Percentage of board members who are independent
paragraph 21 (e)
CDR (EU)
2020/1816, Annex II
258
ESRS 2 GOV-4 Statement on due diligence paragraph 30
SFDR Annex I
140
ESRS 2 SBM-1 Involvement in activities related to fossil fuel
activities paragraph 40 (d) i
Not applicable
Not applicable
ESRS 2 SBM-1 Involvement in activities related to chemical
production paragraph 40 (d) ii
Not applicable
Not applicable
ESRS 2 SBM-1 Involvement in activities related to controversial
weapons paragraph 40 (d) iii
Not applicable
Not applicable
ESRS 2 SBM-1 Involvement in activities related to cultivation and
production of tobacco paragraph 40 (d) iv
Not applicable
Not applicable
ESRS E1-1 Transition plan to reach climate neutrality by 2050
paragraph 14
Regulation (EU) 2021/1119
Article 2 (1)
160
ESRS E1-1 Undertakings excluded from Paris-aligned Benchmarks
paragraph 16 (g)
CDR (EU) 2020/1818, Article 6
160
ESRS E1-4 GHG emission reduction targets paragraph 34
SFDR Annex I, Commission
Delegated Regulation (CDR)
(EU)
2020/1816, Article 449a
174
ESRS E1-5 Energy consumption from fossil sources disaggregated
by sources (only high climate impact sectors) paragraph 38
Not material
Not material
ESRS E1-5 Energy consumption and mix paragraph 37
SFDR Annex I
175
ESRS E1-5 Energy intensity associated with activities in high
climate impact sectors paragraphs 40 to 43
Not material
Not material
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions
paragraph 44
SFDR Annex I, CDR (EU)
2020/1818, Article 5(1), 6 and
8(1)
175
ESRS E1-6 Gross GHG emissions intensity paragraphs 53 to 55
SFDR Annex I, CDR (EU)
2020/1818, Article 8 (1)
175
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227
Disclosure Requirement and related datapoint
Appendix B – ESRS 2 (SFDR +
Pillar 3
+ Benchmark
+ CL)*
Page / Not applicable /
Phase-in / Not material
ESRS E1-7 GHG removals and carbon credits paragraph 56
Regulation (EU) 2021/1119
Article 2 (1)
177
ESRS E1-9 Exposure of the benchmark portfolio to climate-related
physical risks paragraph 66
Phase-in application
Phase-in application
ESRS E1-9 Disaggregation of monetary amounts by acute and
chronic physical risk paragraph 66 (a)
ESRS E1-9 Location of significant assets at material physical risk
paragraph 66 (c)
Phase-in application
Phase-in application
ESRS E1-9 Breakdown of the carrying value of its real estate
assets by energy-efficiency classes paragraph 67 (c)
Phase-in application
Phase-in application
ESRS E1-9 Degree of exposure of the portfolio to climate- related
opportunities paragraph 69
Phase-in application
Phase-in application
ESRS E2-4 Amount of each pollutant listed in Annex II of the E-
PRTR Regulation (European Pollutant Release and Transfer
Register) emitted to air, water and soil, paragraph 28
Not material
Not material
ESRS E3-1 Water and marine resources paragraph 9
Not material
Not material
ESRS E3-1 Dedicated policy paragraph 13
Not material
Not material
ESRS E3-1 Sustainable oceans and seas paragraph 14
Not material
Not material
ESRS E3-4 Total water recycled and reused paragraph 28 (c)
Not material
Not material
ESRS E3-4 Total water consumption in m3 per net revenue on
own operations paragraph 29
Not material
Not material
ESRS 2 – SBM-3 – E4 paragraph 16 (a) i
Not material
Not material
ESRS 2 – SBM-3 – E4 paragraph 16 (b)
Not material
Not material
ESRS 2 – SBM-3 E4 paragraph 16 (c)
Not material
Not material
ESRS E4-2 Sustainable land / agriculture practices or policies
paragraph 24 (b)
Not material
Not material
ESRS E4-2 Sustainable oceans / seas practices or policies
paragraph 24 (c)
Not material
Not material
ESRS E4-2 Policies to address deforestation paragraph 24 (d)
Not material
Not material
ESRS E5-5 Non-recycled waste paragraph 37 (d)
Not material
Not material
ESRS E5-5 Hazardous waste and radioactive waste paragraph 39
Not material
Not material
ESRS 2- SBM3 - S1 Risk of incidents of forced labour paragraph 14
(f)
Not material
Not material
Disclosure Requirement and related datapoint
Appendix B – ESRS 2 (SFDR +
Pillar 3
+ Benchmark
+ CL)*
Page / Not applicable /
Phase-in / Not material
ESRS 2- SBM3 - S1 Risk of incidents of child labour paragraph 14
(g)
Not material
Not material
ESRS S1-1 Human rights policy commitments paragraph 20
SFRD Annex I,
184
ESRS S1-1 Due diligence policies on issues addressed by the
fundamental International Labor Organisation Conventions 1 to 8,
paragraph 21
CDR (EU) 2020/1816, Annex II,
184
ESRS S1-1 processes and measures for preventing trafficking in
human beings paragraph 22
SFRD Annex I
184
ESRS S1-1 workplace accident prevention policy or management
system paragraph 23
SFRD Annex I
184
ESRS S1-3 grievance/complaints handling mechanisms paragraph
32 (c)
SFRD Annex I
188
ESRS S1-14 Number of fatalities and number and rate of work-
related accidents paragraph 88 (b) and (c)
CDR (EU)
2020/1816, Annex II
199
ESRS S1-14 Number of days lost to injuries, accidents, fatalities or
illness paragraph 88 (e)
SFRD Annex I
199
ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a)
CDR (EU)
2020/1816, Annex II
200
ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b)
SFRD Annex I
200
ESRS S1-17 Incidents of discrimination paragraph 103 (a)
SFRD Annex I
200
ESRS S1-17 Non-respect of UNGPs on Business and Human Rights
and OECD paragraph 104 (a)
CDR (EU)
2020/1816, Annex II
200
ESRS 2- SBM3 – S2 Significant risk of child labour or forced labour
in the value chain paragraph 11 (b)
Not material
Not material
ESRS S2-1 Human rights policy commitments paragraph 17
Not material
Not material
ESRS S2-1 Policies related to value chain workers paragraph 18
Not material
Not material
ESRS S2-1 Non-respect of UNGPs on Business and Human Rights
principles and OECD guidelines paragraph 19
Not material
Not material
ESRS S2-1 Due diligence policies on issues addressed by the
fundamental International Labor Organisation Conventions 1 to 8,
paragraph 19
Not material
Not material
ESRS S2-4 Human rights issues and incidents connected to its
upstream and downstream value chain paragraph 36
Not material
Not material
About us
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Implementation
Financial results
Risks and
opportunities
Corporate
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228
Disclosure Requirement and related datapoint
Appendix B – ESRS 2 (SFDR +
Pillar 3
+ Benchmark
+ CL)*
Page / Not applicable /
Phase-in / Not material
ESRS S3-1 Human rights policy commitments paragraph 16
Not material
Not material
ESRS S3-1 non-respect of UNGPs on Business and Human Rights,
ILO principles or and OECD guidelines paragraph 17
Not material
Not material
ESRS S3-4 Human rights issues and incidents paragraph 36
Not material
Not material
ESRS S4-1 Policies related to consumers and end-users paragraph
16
SFRD Annex I
203
ESRS S4-1 Non-respect of UNGPs on Business and Human Rights
and OECD guidelines paragraph 17
SFRD, CDR (EU) 2020/1816,
Annex II
CDR (EU) 2020/1818,
203
Disclosure Requirement and related datapoint
Appendix B – ESRS 2 (SFDR +
Pillar 3
+ Benchmark
+ CL)*
Page / Not applicable /
Phase-in / Not material
ESRS S4-4 Human rights issues and incidents paragraph 35
SFRD Annex I,
207
ESRS G1-1 United Nations Convention against Corruption
paragraph 10 (b)
SFRD Annex I,
213
ESRS G1-1 Protection of whistle- blowers paragraph 10 (d)
SFRD Annex I,
213
ESRS G1-4 Fines for violation of anti- corruption and anti-bribery
laws paragraph 24 (a)
SFRD Annex I, CDR (EU)
2020/1816, Annex II)
218
ESRS G1-4 Standards of anti- corruption and anti- bribery
paragraph 24 (b)
SFRD Annex I,
218
* Reference to the Financial Services Sector Sustainability Disclosure Regulation, Pillar 3, the Benchmarks Regulation and the European Climate Law
Appendix 2
Other taxonomic tables as of 31 December 2025
.
Table 124. Assets for the calculation of GAR – based on turnover KPIs
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
56,965,988
28,582,632
1,471,865
1,470,118
1,744
0
4
0
0
897,726
5
542,104
0
0
0
0
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
56,965,988
28,582,632
1,471,865
1,470,118
1,744
0
4
0
0
897,726
5
542,104
0
0
0
0
3
Financial undertakings
2,690,430
1,420,365
186,148
186,145
3
0
0
0
0
0
2
171,604
0
0
0
0
4
Loans and advances
2,690,430
1,420,365
186,148
186,145
3
0
0
0
0
0
2
171,604
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
Non-financial undertakings
9,706,530
2,507,209
387,991
386,247
1,740
0
4
0
0
0
3
370,500
0
0
0
8
Loans and advances
9,706,530
2,507,209
387,991
386,247
1,740
0
4
0
0
0
3
370,500
0
0
0
9
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
Households
44,538,279
24,655,058
897,726
897,726
0
0
897,726
0
0
0
0
0
12
of which loans collateralised by residential immovable
property
20,060,500
19,880,740
897,726
897,726
0
0
897,726
0
0
0
0
0
13
of which building renovation loans
803,293
803,293
0
0
0
0
0
0
0
0
0
0
14
of which motor vehicle loans
4,263,684
3,971,025
0
0
0
0
0
0
0
0
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229
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
15
Local governments financing
30,750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
16
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
0
0
17
Other local government financing
30,750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19
Exposures included on a voluntary basis (3)
0
0
0
0
0
0
0
0
0
0
0
0
0
20
Total GAR assets
56,965,988
0
0
0
0
21
Assets not covered for GAR calculation
126,085,388
22
Central governments and Supranational issuers
50,444,677
23
Central banks exposure
9,882,448
24
Trading book
2,172,644
25
Undertakings and entities not subject to CSRD
45,340,124
26
SMEs and NFCs (other than SMEs) not subject to CSRD
disclosure obligations
35,088,140
27
Loans and advances
34,892,330
28
of which loans collateralised by commercial immovable
property
17,040,733
29
of which building renovation loans
66,658
30
Debt securities
77,401
31
Equity instruments
118,409
32
Non-EU country counterparties not subject to NFRD
disclosure obligations
694,949
33
Loans and advances
671,593
34
Debt securities
0
35
Equity instruments
23,356
36
Derivatives
532,366
37
On demand interbank loans
11,098,306
38
Cash and cash-related assets
2,541,539
39
Other categories of assets (e.g. Goodwill, commodities etc.)
4,073,284
40
Total assets
183,051,376
Off-balance sheet exposures - Undertakings subject to CSRD disclosure obligations
41
Financial guarantees
n/a
n/a
n/a
n/a
n/a
n/a
n/a,
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
42
Assets under management
6,239,338
368,841
39,033
38,468
511
0
52
2
0
0
155
20,238
0
0
0
0
43
Of which debt securities
5,363,583
245,024
15,096
14,851
243
0
0
1
0
0
53
1,683
0
0
0
0
44
Of which equity instruments
875,755
123,817
23,938
23,617
267
0
52
1
0
0
102
18,555
0
0
0
0
(1) In accordance with Article 7(8)(a) and (b) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 4(1a) of Commission Delegated Regulation (UE) 2026/73; (3) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
230
Table 125. Assets for the calculation of GAR – based on CapEx KPIs
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
56,965,988
28,922,788
2,023,346
2,023,041
18
0
12
0
274
897,726
274
932,961
0
0
0
0
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
56,965,988
28,922,788
2,023,346
2,023,041
18
0
12
0
274
897,726
274
932,961
0
0
0
0
3
Financial undertakings
2,690,430
1,434,738
429,276
429,264
8
0
0
0
5
0
5
357,511
0
0
0
0
4
Loans and advances
2,690,430
1,434,738
429,276
429,264
8
0
0
0
5
0
5
357,511
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
Non-financial undertakings
9,706,530
2,832,992
696,343
696,051
10
0
12
0
269
0
269
575,450
0
0
0
8
Loans and advances
9,706,530
2,832,992
696,343
696,051
10
0
12
0
269
0
269
575,450
0
0
0
9
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
Households
44,538,279
24,655,058
897,726
897,726
0
0
897,726
0
0
0
0
0
12
of which loans collateralised by residential immovable
property
20,060,500
19,880,740
897,726
897,726
0
0
897,726
0
0
0
0
0
13
of which building renovation loans
803,293
803,293
0
0
0
0
0
0
0
0
0
0
14
of which motor vehicle loans
4,263,684
3,971,025
0
0
0
0
0
0
0
0
15
Local governments financing
30,750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
16
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
0
0
17
Other local government financing
30,750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19
Exposures included on a voluntary basis (3)
0
0
0
0
0
0
0
0
0
0
0
0
0
20
Total GAR assets
56,965,988
0
0
0
0
21
Assets not covered for GAR calculation
126,085,388
22
Central governments and Supranational issuers
50,444,677
23
Central banks exposure
9,882,448
24
Trading book
2,172,644
25
Undertakings and entities not subject to CSRD
45,340,124
26
SMEs and NFCs (other than SMEs) not subject to CSRD
disclosure obligations
35,088,140
27
Loans and advances
34,892,330
28
of which loans collateralised by commercial immovable
property
17,040,733
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Financial results
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opportunities
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governance
Management Board Report on the Activity of the BNP Paribas Bank Polska S.A. Group in 2025
231
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
29
of which building renovation loans
66,658
30
Debt securities
77,401
31
Equity instruments
118,409
32
Non-EU country counterparties not subject to NFRD
disclosure obligations
694,949
33
Loans and advances
671,593
34
Debt securities
0
35
Equity instruments
23,356
36
Derivatives
532,366
37
On demand interbank loans
11,098,306
38
Cash and cash-related assets
2,541,539
39
Other categories of assets (e.g. Goodwill, commodities etc.)
4,073,284
40
Total assets
183,051,376
Off-balance sheet exposures - Undertakings subject to CSRD disclosure obligations
41
Financial guarantees
n/a
n/a
n/a
n/a
n/a
n/a
n/a,
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
42
Assets under management
6,239,338
507,440
66,953
64,651
1,997
0
300
0
4
0
4,712
24,842
0
0
0
0
43
Of which debt securities
5,363,583
283,674
25,637
25,185
451
0
0
0
0
0
1,602
3,923
0
0
0
0
44
Of which equity instruments
875,755
223,766
41,316
39,466
1,546
0
300
0
4
0
3,110
20,919
0
0
0
0
(1) In accordance with Article 7(8)(a) and (b) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 4(1a) of Commission Delegated Regulation (UE) 2026/73; (3) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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232
Table 126. Assets for the calculation of the GAR in relation to flows – based on turnover.
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
13,089,017
4,832,331
562,834
562,834
0
0
0
0
0
471,335
0
90,785
0
0
0
0
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
13,089,017
4,832,331
562,834
562,834
0
0
0
0
0
471,335
0
90,785
0
0
0
0
3
Financial undertakings
40,011
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
Loans and advances
40,011
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
Non-financial undertakings
1,687,295
249,440
91,499
91,499
0
0
0
0
0
0
0
90,785
0
0
0
8
Loans and advances
1,687,295
249,440
91,499
91,499
0
0
0
0
0
0
0
90,785
0
0
0
9
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
Households
11,352,307
4,582,891
471,335
471,335
0
0
471,335
0
0
0
0
0
12
of which loans collateralised by residential immovable
property
2,597,255
2,589,614
471,335
471,335
0
0
471,335
0
0
0
0
0
13
of which building renovation loans
103,004
103,004
0
0
0
0
0
0
0
0
0
0
14
of which motor vehicle loans
1,890,273
1,890,273
0
0
0
0
0
0
0
0
15
Local governments financing
9,403
0
0
0
0
0
0
0
0
0
0
0
0
0
0
16
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
0
0
17
Other local government financing
9,403
0
0
0
0
0
0
0
0
0
0
0
0
0
0
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19
Exposures included on a voluntary basis (3)
0
0
0
0
0
0
0
0
0
0
0
0
0
20
Total GAR assets
13,089,017
0
0
0
0
21
Assets not covered for GAR calculation
26,959,456
22
Central governments and Supranational issuers
13,511,338
23
Central banks exposure
2,198,779
24
Trading book
534,259
25
Undertakings and entities not subject to CSRD
5,952,579
26
SMEs and NFCs (other than SMEs) not subject to CSRD
disclosure obligations
4,841,326
27
Loans and advances
4,824,532
28
of which loans collateralised by commercial immovable
property
1,950,848
29
of which building renovation loans
57,941
30
Debt securities
16,794
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233
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
31
Equity instruments
0
32
Non-EU country counterparties not subject to NFRD
disclosure obligations
636,338
33
Loans and advances
636,338
34
Debt securities
0
35
Equity instruments
0
36
Derivatives
222,817
37
On demand interbank loans
4,190,546
38
Cash and cash-related assets
158,725
39
Other categories of assets (e.g. Goodwill, commodities etc.)
190,414
40
Total assets
40,048,472
Off-balance sheet exposures - Undertakings subject to CSRD disclosure obligations
41
Financial guarantees
n/a
n/a
n/a
n/a
n/a
n/a
n/a,
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
42
Assets under management
1,413,905
101,416
7,723
11,382
-3,713
0
52
2
0
0
-18
5,021
0
0
0
0
43
Of which debt securities
1,121,480
53,638
2,702
5,138
-2,438
0
0
1
0
0
-51
-1,906
0
0
0
0
44
Of which equity instruments
292,425
47,778
5,022
6,244
-1,276
0
52
1
0
0
34
6,926
0
0
0
0
(1) In accordance with Article 7(8)(a) and (b) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 4(1a) of Commission Delegated Regulation (UE) 2026/73; (3) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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234
Table 127. Assets for the calculation of the GAR in relation to flows – based on capital expenditure (CapEx)
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and denominator
13,089,017
4,824,229
541,068
541,068
0
0
0
0
0
471,335
0
69,607
0
0
0
0
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
13,089,017
4,824,229
541,068
541,068
0
0
0
0
0
471,335
0
69,607
0
0
0
0
3
Financial undertakings
40,011
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
Loans and advances
40,011
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
Non-financial undertakings
1,687,295
241,338
69,733
69,733
0
0
0
0
0
0
0
69,607
0
0
0
8
Loans and advances
1,687,295
241,338
69,733
69,733
0
0
0
0
0
0
0
69,607
0
0
0
9
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
Households
11,352,307
4,582,891
471,335
471,335
0
0
471,335
0
0
0
0
0
12
of which loans collateralised by residential immovable
property
2,597,255
2,589,614
471,335
471,335
0
0
471,335
0
0
0
0
0
13
of which building renovation loans
103,004
103,004
0
0
0
0
0
0
0
0
0
0
14
of which motor vehicle loans
1,890,273
1,890,273
0
0
0
0
0
0
0
0
15
Local governments financing
9,403
0
0
0
0
0
0
0
0
0
0
0
0
0
0
16
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
0
0
17
Other local government financing
9,403
0
0
0
0
0
0
0
0
0
0
0
0
0
0
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
0
0
19
Exposures included on a voluntary basis (3)
0
0
0
0
0
0
0
0
0
0
0
0
0
20
Total GAR assets
13,089,017
0
0
0
0
21
Assets not covered for GAR calculation
26,959,456
22
Central governments and Supranational issuers
13,511,338
23
Central banks exposure
2,198,779
24
Trading book
534,259
25
Undertakings and entities not subject to CSRD
5,952,579
26
SMEs and NFCs (other than SMEs) not subject to CSRD
disclosure obligations
4,841,326
27
Loans and advances
4,824,532
28
of which loans collateralised by commercial immovable
property
1,950,848
29
of which building renovation loans
57,941
30
Debt securities
16,794
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235
31.12.2025
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
PLN'000
Total [gross]
carrying amount
Of which
Taxonomy-
eligible
Of which
Taxonomy-
aligned
Non-assessed
exposures
Breakdown per environmental objective
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which financing non-
material activities of
counterparties (1)
Of which exposures financing
counterparties reporting in
accordance with Article 7(9)
Of which not assessed
considered non-material
by the credit institution
(2)
Climate
Change
Mitigation
(CCM)
Climate
Change
Adaptation
(CCA)
Water and
marine
resources
(WTR)
Circular
economy (CE)
Pollution
(PPC)
Biodiversity
and
Ecosystems
(BIO)
31
Equity instruments
0
32
Non-EU country counterparties not subject to NFRD
disclosure obligations
636,338
33
Loans and advances
636,338
34
Debt securities
0
35
Equity instruments
0
36
Derivatives
222,817
37
On demand interbank loans
4,190,546
38
Cash and cash-related assets
158,725
39
Other categories of assets (e.g. Goodwill, commodities etc.)
190,414
40
Total assets
40,048,472
Off-balance sheet exposures - Undertakings subject to CSRD disclosure obligations
41
Financial guarantees
n/a
n/a
n/a
n/a
n/a
n/a
n/a,
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
42
Assets under management
1,413,905
191,483
1,101
530
266
0
300
0
4
0
2,269
9,591
0
0
0
0
43
Of which debt securities
1,121,480
64,616
-11,004
-11,229
226
0
0
0
0
0
1,053
1,446
0
0
0
0
44
Of which equity instruments
292,425
126,866
12,105
11,760
41
0
300
0
4
0
1,216
8,144
0
0
0
0
(1) In accordance with Article 7(8)(a) and (b) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 4(1a) of Commission Delegated Regulation (UE) 2026/73; (3) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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236
Table 128. GAR sector information - based on turnover KPIs
a
b
c
d
e
f
g
h
i
j
31.12.2025
Breakdown by sector - NACE 4 digits level (PLN'000)
Total [Gross] carrying amount
Of which Taxonomy eligible
Of which Taxonomy aligned
Climate Change Mitigation
(CCM)
Climate Change
Adaptation (CCA)
Water and marine
resources (WTR)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems
(BIO)
1
77.11 - Rental and leasing of cars and light motor vehicles
1,993,336
1,387,142
123,557
123,557
0
0
0
0
0
2
61.20 - Telecommunication reselling activities and
intermediation service activities for telecommunication
1,134,944
0
0
0
0
0
0
0
0
3
60.39 - Other content distribution activities
560,491
0
0
0
0
0
0
0
0
4
35.11 - Production of electricity from non-renewable sources
380,211
0
0
0
0
0
0
0
0
5
46.32 - Wholesale of meat, meat products, fish and fish products
284,520
0
0
0
0
0
0
0
0
6
61.10 - Wired, wireless, and satellite telecommunication
activities
280,673
0
0
0
0
0
0
0
0
7
46.64 - Wholesale of other machinery and equipment
269,099
0
0
0
0
0
0
0
0
8
24.42 - Aluminium production
210,674
67,416
50,773
50,773
0
0
0
0
0
9
28.92 - Manufacture of machinery for mining, quarrying and
construction
203,121
66,547
66,547
66,547
0
0
0
0
0
10
86.92 - Patient transportation by ambulance
171,207
0
0
0
0
0
0
0
0
11
Nuclear activities (1)
763,673
371
371
12
Fossil gas activities (2)
770,066
123
0
13
Of which non-assessed exposures (3)
0
(1) Referred to in Sections 4.26, 4.27 and 4.28 of Annexes I and II to Delegated Regulation (EU) 2021/2139; (2) Referred to in Sections 4.29, 4.30 and 4.31 of Annexes I and II to Delegated Regulation (EU) 2021/2139.; (3) In accordance with Article 7(8) of Commission Delegated Regulation (UE) 2026/73.
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237
Table 129. GAR sector information – based on capital expenditure (CapEx)
a
b
c
d
e
f
g
h
i
j
31.12.2025
Breakdown by sector - NACE 4 digits level (PLN'000)
Total [Gross] carrying amount
Of which Taxonomy eligible
Of which Taxonomy aligned
Climate Change Mitigation
(CCM)
Climate Change
Adaptation (CCA)
Water and marine
resources (WTR)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems
(BIO)
1
77.11 - Rental and leasing of cars and light motor vehicles
1,993,336
1,496,921
416,039
416,039
0
0
0
0
0
2
61.20 - Telecommunication reselling activities and
intermediation service activities for telecommunication
1,134,944
0
0
0
0
0
0
0
0
3
60.39 - Other content distribution activities
560,491
0
0
0
0
0
0
0
0
4
35.11 - Production of electricity from non-renewable sources
380,211
0
0
0
0
0
0
0
0
5
46.32 - Wholesale of meat, meat products, fish and fish products
284,520
0
0
0
0
0
0
0
0
6
61.10 - Wired, wireless, and satellite telecommunication
activities
280,673
0
0
0
0
0
0
0
0
7
46.64 - Wholesale of other machinery and equipment
269,099
0
0
0
0
0
0
0
0
8
24.42 - Aluminium production
210,674
47,612
46,138
46,138
0
0
0
0
0
9
28.92 - Manufacture of machinery for mining, quarrying and
construction
203,121
112,400
112,400
112,400
0
0
0
0
0
10
86.92 - Patient transportation by ambulance
171,207
0
0
0
0
0
0
0
0
11
Nuclear activities (1)
763,111
428
428
12
Fossil gas activities (2)
1,063,040
296
0
13
Of which non-assessed exposures (3)
0
(1) Referred to in Sections 4.26, 4.27 and 4.28 of Annexes I and II to Delegated Regulation (EU) 2021/2139; (2) Referred to in Sections 4.29, 4.30 and 4.31 of Annexes I and II to Delegated Regulation (EU) 2021/2139.; (3) In accordance with Article 7(8) of Commission Delegated Regulation (UE) 2026/73.
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238
Table 130. GAR KPI stock – based on turnover KPIs
31.12.2025
% (compared to corresponding total covered assets in the denominator)
a
b
c
d
e
f
g
h
i
j
k
l
m
Taxonomy-eligible
Proportion of Taxonomy
aligned in Taxonomy
eligible
Non- assessed exposures
(1)
Taxonomy- aligned
Breakdown per environmental objective
Of which Use of Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine resources
(WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and
denominator
50.17%
2.58%
2.58%
0.00%
0.00%
0.00%
0.00%
0.00%
1.58%
0.00%
0.95%
5.15%
0.00%
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
50.17%
2.58%
2.58%
0.00%
0.00%
0.00%
0.00%
0.00%
1.58%
0.00%
0.95%
5.15%
0.00%
3
Financial undertakings
52.79%
6.92%
6.92%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6.38%
13.11%
0.00%
4
Loans and advances
52.79%
6.92%
6.92%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6.38%
13.11%
0.00%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Non-financial undertakings
25.83%
4.00%
3.98%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3.82%
15.48%
0.00%
8
Loans and advances
25.83%
4.00%
3.98%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3.82%
15.48%
0.00%
9
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Households
55.36%
2.02%
2.02%
0.00%
0.00%
2.02%
0.00%
0.00%
3.64%
0.00%
12
of which loans collateralised by residential immovable
property
99.10%
4.48%
4.48%
0.00%
0.00%
4.48%
0.00%
0.00%
4.52%
0.00%
13
of which building renovation loans
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
of which motor vehicle loans
93.14%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Exposures included on a voluntary basis (2)
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
GAR - Total GAR assets
50.17%
2.58%
2.58%
0.00%
0.00%
0.00%
0.00%
0.00%
1.58%
0.00%
0.95%
5.15%
0.00%
(1) In accordance with Article 7(8) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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239
Table 131. GAR KPI stock – based on capital expenditure (CapEx)
31.12.2025
% (compared to corresponding total covered assets in the denominator)
a
b
c
d
e
f
g
h
i
j
k
l
m
Taxonomy-eligible
Proportion of Taxonomy
aligned in Taxonomy
eligible
Non- assessed exposures
(1)
Taxonomy- aligned
Breakdown per environmental objective
Of which Use of Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine resources
(WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and
denominator
50.77%
3.55%
3.55%
0.00%
0.00%
0.00%
0.00%
0.00%
1.58%
0.00%
1.64%
7.00%
0.00%
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
50.77%
3.55%
3.55%
0.00%
0.00%
0.00%
0.00%
0.00%
1.58%
0.00%
1.64%
7.00%
0.00%
3
Financial undertakings
53.33%
15.96%
15.96%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13.29%
29.92%
0.00%
4
Loans and advances
53.33%
15.96%
15.96%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13.29%
29.92%
0.00%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Non-financial undertakings
29.19%
7.17%
7.17%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5.93%
24.58%
0.00%
8
Loans and advances
29.19%
7.17%
7.17%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5.93%
24.58%
0.00%
9
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Households
55.36%
2.02%
2.02%
0.00%
0.00%
2.02%
0.00%
0.00%
3.64%
0.00%
12
of which loans collateralised by residential immovable
property
99.10%
4.48%
4.48%
0.00%
0.00%
4.48%
0.00%
0.00%
4.52%
0.00%
13
of which building renovation loans
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
of which motor vehicle loans
93.14%
0.00%
0.00%
0
0.00%
0.00%
0.00%
0.00%
0.00%
15
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Exposures included on a voluntary basis (2)
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
GAR - Total GAR assets
50.77%
3.55%
3.55%
0.00%
0.00%
0.00%
0.00%
0.00%
1.58%
0.00%
1.64%
7.00%
0.00%
(1) In accordance with Article 7(8) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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240
Table 132. GAR KPI flow – based on turnover KPIs
31.12.2025
% (compared to corresponding total covered assets in the denominator)
a
b
c
d
e
f
g
h
i
j
k
l
m
Taxonomy-eligible
Proportion of Taxonomy
aligned in Taxonomy
eligible
Non- assessed exposures
(1)
Taxonomy- aligned
Breakdown per environmental objective
Of which Use of Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine resources
(WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and
denominator
36.92%
4.30%
4.30%
0.00%
0.00%
0.00%
0.00%
0.00%
3.60%
0.00%
0.69%
11.65%
0.00%
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
36.92%
4.30%
4.30%
0.00%
0.00%
0.00%
0.00%
0.00%
3.60%
0.00%
0.69%
11.65%
0.00%
3
Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Non-financial undertakings
14.78%
5.42%
5.42%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5.38%
36.68%
0.00%
8
Loans and advances
14.78%
5.42%
5.42%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5.38%
36.68%
0.00%
9
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Households
40.37%
4.15%
4.15%
0.00%
0.00%
4.15%
0.00%
0.00%
10.28%
0.00%
12
of which loans collateralised by residential immovable
property
99.71%
18.15%
18.15%
0.00%
0.00%
18.15%
0.00%
0.00%
18.20%
0.00%
13
of which building renovation loans
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
of which motor vehicle loans
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Exposures included on a voluntary basis (2)
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
GAR - Total GAR assets
36.92%
4.30%
4.30%
0.00%
0.00%
0.00%
0.00%
0.00%
3.60%
0.00%
0.69%
11.65%
0.00%
(1) In accordance with Article 7(8) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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241
Table 133. GAR KPI flow – based on CapEx KPIs
31.12.2025
% (compared to corresponding total covered assets in the denominator)
a
b
c
d
e
f
g
h
i
j
k
l
m
Taxonomy-eligible
Proportion of Taxonomy
aligned in Taxonomy
eligible
Non- assessed exposures
(1)
Taxonomy- aligned
Breakdown per environmental objective
Of which Use of Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and
marine resources
(WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity
and
Ecosystems
(BIO)
1
GAR - Covered assets in both numerator and
denominator
36.86%
4.13%
4.13%
0.00%
0.00%
0.00%
0.00%
0.00%
3.60%
0.00%
0.53%
11.22%
0.00%
2
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
36.86%
4.13%
4.13%
0.00%
0.00%
0.00%
0.00%
0.00%
3.60%
0.00%
0.53%
11.22%
0.00%
3
Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Non-financial undertakings
14.30%
4.13%
4.13%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4.13%
28.89%
0.00%
8
Loans and advances
14.30%
4.13%
4.13%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4.13%
28.89%
0.00%
9
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Households
40.37%
4.15%
4.15%
0.00%
0.00%
4.15%
0.00%
0.00%
10.28%
0.00%
12
of which loans collateralised by residential immovable
property
99.71%
18.15%
18.15%
0.00%
0.00%
18.15%
0.00%
0.00%
18.20%
0.00%
13
of which building renovation loans
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
of which motor vehicle loans
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Exposures included on a voluntary basis (2)
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
GAR - Total GAR assets
36.86%
4.13%
4.13%
0.00%
0.00%
0.00%
0.00%
0.00%
3.60%
0.00%
0.53%
11.22%
0.00%
(1) In accordance with Article 7(8) of Commission Delegated Regulation (UE) 2026/73; (2) In accordance with Article 7(3) of Commission Delegated Regulation (UE) 2026/73;
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242
Table 134. KPI off-balance sheet exposures - based on turnover KPIs (stock)
31.12.2025
% (compared to corresponding total off-balance sheet assets)
a
b
c
d
e
f
g
h
i
j
k
l
Taxonomy eligible
Non- assessed exposures (1)
Taxonomy aligned
Breakdown per environmental objective
Of which Use of
Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and marine
resources (WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
2
Assets under management (AuM KPI)
5.91%
0.63%
0.62%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.32%
0.00%
Table 135. KPI off-balance sheet exposures - based on CapEx KPIs (stock)
31.12.2025
% (compared to corresponding total off-balance sheet assets)
a
b
c
d
e
f
g
h
i
j
k
l
Taxonomy eligible
Non- assessed exposures (1)
Taxonomy aligned
Breakdown per environmental objective
Of which Use of
Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and marine
resources (WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
2
Assets under management (AuM KPI)
8.13%
1.07%
1.04%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.08%
0.40%
0.00%
Table 136. KPI off-balance sheet exposures - based on turnover KPIs (flow)
31.12.2025
% (compared to corresponding total off-balance sheet assets)
a
b
c
d
e
f
g
h
i
j
k
l
Taxonomy eligible
Non- assessed exposures (1)
Taxonomy aligned
Breakdown per environmental objective
Of which Use of
Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and marine
resources (WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
2
Assets under management (AuM KPI)
7.17%
0.55%
0.81%
-0.26%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.36%
0.00%
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Table 137. KPI off-balance sheet exposures - based on CapEx KPIs (flow)
31.12.2025
% (compared to corresponding total off-balance sheet assets)
a
b
c
d
e
f
g
h
i
j
k
l
Taxonomy eligible
Non- assessed exposures (1)
Taxonomy aligned
Breakdown per environmental objective
Of which Use of
Proceeds
Of which transitional
Of which enabling
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Water and marine
resources (WTR)
Circular economy
(CE)
Pollution (PPC)
Biodiversity and
Ecosystems (BIO)
1
Financial guarantees (FinGuar KPI)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
2
Assets under management (AuM KPI)
13.54%
0.08%
0.04%
0.02%
0.00%
0.02%
0.00%
0.00%
0.00%
0.16%
0.68%
0.00%
(1) In accordance with Article 7(8) of Commission Delegated Regulation (UE) 2026/73.
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Disclaimer
This Sustainability Statement has been prepared in accordance with the requirements of the CSRD (and its transposition
into Polish law) and the European Sustainability Reporting Standards (ESRS) applicable on the date of publication of this
statement, as well as Commission Delegated Regulation (EU) 2025/1416 of 10 November 2025, which defers the application
of selected disclosure requirements. Changes to sustainability reporting obligations were initiated by the European
Commission as part of the “omnibus package” aimed at simplification.
Given the persisting uncertainty regarding the future shape of applicable regulations, the Group has adopted a prudent
approach and made every effort to reflect the specific nature of its operations and to provide the most reliable and
adequate information possible.
This document includes only the information that the Group considers material in terms of both the impact of the Group’s
activities on people and the environment and/or the impact of sustainability matters on the Group. It presents the
methodological choices that formed the basis of the Group’s double materiality assessment of environmental, social and
governance matters. Some information collected by the Group has not been included in this statement due to its lower
materiality, although it may still carry a certain degree of relevance.
Use of assumptions and estimates
Where certain information, particularly relating to the Group’s value chain, is not yet widely available or does not meet
sufficient reliability standards, the preparation of this statement is partly based on reasonable assumptions and estimates,
in line with CSRD requirements. Some of these assumptions or estimates may involve a high degree of measurement
uncertainty. They have been presented to the extent that they provide useful and meaningful insights. In such cases, the
narrative description includes the methods and definitions applied, as well as any related limitations and uncertainties.
To ensure high quality disclosures, the Group has, where possible, relied on definitions derived from European regulations
and recognised standards. Where this was not feasible, information has been prepared in good faith, based on internal
definitions and estimates.
Information, data, metrics and methodologies used to describe climate change continue to evolve. Climate-related metrics
are complex and rely on numerous assumptions regarding climate policy, technology and other uncertain or unknown
factors. Any change in these variables may render the underlying assumptions, and therefore the resulting climate metrics
and data, inaccurate. Consequently, climate-related information included in the sustainability statement, whether historical
or forward-looking, carries inherent uncertainty and may be less relevant for decision-making than historical financial
data.
Forward-looking statements
In accordance with the CSRD, this statement contains forward-looking information, including projections and estimates
based on current views and assumptions regarding future events. The Group cannot provide any assurance that these
projections or estimates will be achieved. They are subject to inherent risks and uncertainties, some of which are beyond
the Group’s control, relating in particular to the Group itself, its subsidiaries and investments, the development of its
business, industry trends, future investments and acquisitions, as well as changes in economic, social, ecological and
environmental conditions and applicable regulations.
Due to these risks and uncertainties, forward-looking statements should not be regarded as a representation or guarantee
by the Group or any other person that the Group will achieve its objectives, plans, intentions or metrics within a specified
timeframe or at all.
Uncertainty inherent in climate-related information
Any forward-looking statements contained in this statement refer only to the date on which they were made. The Group
does not undertake to publish updates or revisions to such statements unless required by applicable law.
With respect to greenhouse gas emissions, there is no full standardisation or comparability of estimation and calculation
methods due to the diversity of available frameworks and methodologies. As a result, there remains a risk of over- or
under-estimation of indicators.
Scope 3 emissions, particularly those related to financed Customers, are characterised by high measurement uncertainty.
By definition, these emissions arise from the activities of the Group’s Customers and, unlike the Group’s direct emissions,
depend on external factors beyond the Group’s control.
Third-party information
Some statistical information and other data included in this statement have been obtained from external sources. The
Group accepts no liability for such information and makes no representations or warranties regarding its accuracy,
precision or completeness.
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Corporate
governance
246 Compliance with corporate governance principles in 2025
253 Shares and shareholders
255 Statutory bodies of the Bank
274 Remuneration of the Management Board and the Supervisory Board
276 Diversity policy
278 Internal control system (including control and risk management system for
the preparation of financial reports)
279 Information about the auditor
Management Board’s Statement of compliance
with corporate governance principles
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Compliance with corporate governance principles in 2025
Legal and regulatory basis of corporate governance
Corporate governance defines the Bank’s governance system, the organisation of the Bank, the powers, duties and
responsibilities and the interrelationship between the Supervisory Board, the Management Board and the Bank’s key
function holders, as well as the relationship with shareholders and customers. In addition, it defines the functioning of
internal supervision and key internal systems and functions. It ensures effective governance, efficient supervision, respect
for shareholders’ rights and transparent communication of the company with the market.
The corporate governance rules applied at BNP Paribas Bank Polska S.A. result from the provisions of the law (in particular
the Code of Commercial Companies, the Banking Law and the regulations governing the functioning of the capital market)
and the recommendations set out in the documents: "Best Practice for WSE Listed Companies", "Corporate Governance
Principles for Supervised Institutions", as well as Recommendation Z issued by the Polish Financial Supervision Authority
regarding internal governance rules in banks.
In addition, the Bank is guided by internal regulations including the Bank’s Articles of Association, the BNP Paribas Group
Code of Conduct, adopted in the latest version by Supervisory Board Resolution 45/2025 on 28 May 2025, and internal
policies that reflect the regulatory requirements of corporate governance.
Pursuant to § 72(7)(5) of the Regulation of the Minister of Finance dated 6 June 2025 on current and periodic information
disclosed by issuers of securities and conditions for recognising as equivalent information required by the laws of a non-
member state (consolidated text, Journal of Laws of 2025, item 755), the Management Board of BNP Paribas Bank Polska
S.A. presents the following information regarding compliance with corporate governance principles in 2025.
The applicable set of corporate governance principles which the Bank is subject to
Corporate Governance Principles for Supervised Institutions
The Bank is subject to the "Corporate Governance Principles for Supervised Institutions" issued by the Polish Financial
Supervision Authority on 22 July 2014. This document sets out the internal and external relations of supervised institutions,
including relations with shareholders and customers, their organisation, the functioning of internal supervision and key
internal systems and functions, the functioning of statutory bodies and the principles of their interaction. These principles
are available on the website of the Polish Financial Supervision Authority at:
https://www.knf.gov.pl/dla_rynku/regulacje_i_praktyka/zasady_ladu_korporacyjnego.
The "Corporate Governance Principles for Supervised Institutions" were adopted by the Bank’s Management Board and
Supervisory Board in December 2014 and by the General Meeting in February 2015. The Bank’s position on the compliance
with the "Corporate Governance Principles for Supervised Institutions" was updated in 2022 and expressed in a Resolution
of the Bank’s Management Board dated 17 February 2022, subsequently confirmed by the Supervisory Board on 2 March
2022 and adopted by the General Meeting on 27 June 2022. It is posted on the Bank’s website:
https://www.bnpparibas.pl/relacje-inwestorskie/lad-korporacyjny/zasady-ladu-korporacyjnego-knf.
The Bank’s annual statement of compliance with the Corporate Governance Principles for Supervised Institutions is also
included in the Supervisory Board’s Activity Reports together with the assessments indicated in Principle 2.11 of the Code of
Best Practice for WSE Listed Companies 2021 and the assessment of the Bank’s compliance with the Corporate Governance
Principles for Supervised Institutions issued by the Polish Financial Supervision Authority.
The section below presents a review of compliance with the "Corporate Governance Principles for Supervised Institutions"
by topic according to the chapters of the Principles.
Principles set out in Chapter 1. "Organisation and organisational structure”
As regards the principles set out in this chapter, the Bank pays particular attention to the implementation of the principles
related to the adaptation of the organisational structure to the needs arising from the implementation of the strategic
objectives, as well as to maintaining its transparency and accessibility. Also important from the point of view of the Bank’s
values is the functioning of the whistleblowing procedure for anonymous reporting of irregularities to the Bank’s bodies.
1. The Bank’s organisation makes it possible to achieve long-term goals among others by combining strategic planning with
an analysis of the external environment, risk factors, macroeconomic forecasts and an analysis of internal factors and the
Bank’s situation, including its individual areas. Strategic objectives take into account the nature and scale of the Bank’s
activities, action plans and business and financial targets both at the level of the Bank and in the individual areas.
Organisational changes in the Bank are subordinate to the Bank’s strategy and are an important tool for achieving strategy
targets. The simplification of the management structure makes it possible to increase sales potential, improve information
flow, manage processes and their quality more strongly and consistently, and increases employee engagement and
development opportunities.
2. The Bank’s relevant internal regulations govern management and control, internal reporting systems, the flow and
protection of information and the circulation of documents. Changes in the external and internal environment are
constantly monitored and analysed at the Bank so that, among others, through organisational changes the Bank can
respond flexibly to them, ensuring that the Bank is organised in a transparent manner, taking into account the size and
profile of the risk and the nature and scale of its activities, and ensuring the achievement of the set objectives of its
operations, the effective management of the Bank, the appropriate response to changing external conditions or sudden and
unexpected events, and the effective flow and protection of information.
3. The organisational rules reflect the organisational structure of the Bank. The Bank’s organisational structure is part of
the Bank’s Organisational Rules, the Head Office’s organisational structure is an appendix to the Head Office Rules, and the
BNP Paribas Bank Polska S.A. declares that it has adopted and
complies with all "Corporate Governance Principles for Supervised
Institutions" issued by the Polish Financial Supervision Authority.
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organisational charts of the units are an integral part of the rules of these units. The organisational structure is posted on
the Bank’s website: https://www.bnpparibas.pl/relacje-inwestorskie/lad-korporacyjny/struktura-organizacyjna.
4. The internal rules, in particular the "Rules of Procedure for the Process of Organisational Change", ensure that the
organisational structure is defined in such a way that there is no doubt as to the tasks and responsibilities of the respective
organisational units, field units and posts or groups of posts, and in particular that there is no overlap of duties and
responsibilities between organisational units, field units and posts or groups of posts.
5. All strategic objectives are set out in the Bank’s GObeyond Strategy 2022-2025. 2025 was the last year of implementation
of the GObeyond Strategy. As of 2026, the Bank is implementing a new strategy approved by the Bank’s Supervisory Board
on 10 December 2025 for a 2026-2030 “Accelerate 2030whose, a public version is available on the Bank’s website at the
following address: https://www.bnpparibas.pl/relacje-inwestorskie/o-banku/strategia-banku.
6. The "Principles for the development, monitoring of the implementation and updating of the Bank’s strategy" clearly
describe the process for responding to situations where it is necessary to deviate from or it is not possible to achieve the
adopted strategic objectives. In addition, the Bank has detailed rules for managing emergency and crisis situations.
7. The "Employee recruitment policy at BNP Paribas Bank Polska S.A." and the "Policy for assessing the suitability of
members of the Management Board and employees holding key functions in the Bank" ensure that persons suitable for the
tasks defined in the Organisational Rules are appointed to all positions.
8. The Bank’s employees have access to the necessary regulations, made available on the intranet pages by the Internal
Communications Team and in the IntraLex internal regulations database.
9. The Bank has a "Whistleblowing Policy". A whistleblower may report a suspected breach without fear of retaliation.
10. The Business Continuity Planning System (BCPS) implemented and in operation at the Bank covers the areas in which
the most important risks have been defined that may have a direct impact on the uninterrupted functioning of the Bank’s
critical processes. Appropriate actions are defined for these areas. In 2022, the Business Continuity Planning System was
audited for compliance with ISO 22301:2019. The Certificate obtained certifies the compliance of the implemented and
functioning Business Continuity Planning System with the requirements of ISO 22301.
Principles set out in Chapter 2. "Relationship with shareholders of the supervised institution”
As regards the principles set out in this chapter, the Bank ensures, in particular, an adequate flow of information between
the supervised institution and the shareholders and, in accordance with the principles adopted for application, provides a
basis for the shareholders’ actions.
1. The Bank’s primary tool for communicating with shareholders is the Bank’s website (investor relations sub-site):
https://www.bnpparibas.pl/relacje-inwestorskie (English version: https://www.bnpparibas.pl/investor-relations). The other
most frequently used tools of communication with analysts and investors are investor conferences (organised, among
others, after the publication of quarterly financial results and thematic conferences), participation in conferences organised
by capital market entities, meetings and one-on-one teleconferences. One of the most important objectives enshrined in
the "Information Policy of BNP Paribas Bank Polska S.A." is to ensure equal access to information. In the case of decisions to
be taken by the decision-making body (General Meeting), ensuring adequate access to information to shareholders is
implemented (in addition to the actions and tools described above) through publication via current reports and the Bank’s
website of the draft resolutions and documents to be discussed at the General Meeting, relevant to the resolutions to be
taken, which have not been previously made public (including justifications to draft resolutions).
2. The interaction of shareholders and the rules of operation and the procedure of convening the General Meeting (GM) are
governed by the Bank’s Articles of Association and the General Meeting Rules. The Rules of participation in the General
Meeting of BNP Paribas Bank Polska S.A. using electronic means of communication provide the basis for participation and
voting at the General Meeting using electronic means of communication.
3. The Bank is obliged by the Banking Law to maintain the equity of the supervised institution at an appropriate level. The
Bank’s strategic shareholder has made an investor commitment to the Polish Financial Supervision Authority to provide
financial support when necessary to maintain an adequate level of capital and liquidity, including when the Bank’s security
requires it.
4. The principles and objectives of the Bank’s dividend policy set out in the "Capital Management Policy at BNP Paribas
Bank Polska S.A.", adopted by the Supervisory Board and updated in 2025, provide among others that: the general objective
of the Bank’s dividend policy is to make stable dividend payments over a long period of time in compliance with the
principle of prudent management of the Bank and in line with the financial capacity of the Bank and the Group, determined
based on the adopted criteria; the dividend policy takes into account factors related to the Bank’s and the Group’s activity,
in particular, the requirements and recommendations of the Supervisory Authorities with respect to capital adequacy. In
particular, the Policy takes into account the positions issued by the Polish Financial Supervision Authority on the dividend
policy of financial institutions, as well as the situation in the financial market, particularly in the context of the changing
macroeconomic environment. The Policy complies with the requirements of Recommendation Z issued by the Polish
Financial Supervision Authority.
Principles set out in Chapter 3. "Managing body”
With regard to the principles set out in this chapter, the Bank attaches particular importance to the application of
principles involving the safe and stable management of the Bank.
1. The security of the organisation is embedded in the strategy pursued by the managing body. The indicators of the
organisation’s security regarding the level of capital or liquidity are included within the #Stronger pillar of the GObeyond
strategy for 2022-2025 an in the new strategy “Accelerate 2030” for 2026-2030 in the Streamline pillar. In the long term,
security is ensured through a policy of sustainable and high-quality growth, at the expense of its dynamics. This aims to
limit the cost of credit risk, but also to minimise environmental, social or reputational risks that could generate deferred
costs, affecting long-term stability and predictability. The members of the management body give assurance of the proper
performance of the duties entrusted to them and, in particular, of their ability to manage the Bank’s affairs in a prudent and
stable manner. The objective of the Management Board is to ensure that the Bank is managed effectively and prudently.
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2. The Management Board is responsible for the overall management of the Bank, including the making and
implementation of decisions having as their object matters of importance for the functioning of the Bank, the selection of
objectives, ways and means of action, including the organisation of the Bank and its activities, the management of day-to-
day operations, as well as the proper management of risks related to outsourced activities, including the activities referred
to in Articles 5 and 6 of the Banking Law, the performance of which has been entrusted to external entities pursuant to
Articles 6a-6d of the Banking Law, and the planning and control of the results achieved. Bearing in mind that the common
objective of the Management Board and the Supervisory Board is to ensure the effective and prudent management of the
Bank, the Management Board is in constant discussion with the Supervisory Board.
3. The division of powers of the Management Board is described in the Resolution on the internal division of powers in the
Management Board of BNP Paribas Bank Polska S.A. and is reflected in the organisational structure.
4. Resolutions of the Management Board are adopted on all matters which require the collegial action of the Management
Board pursuant to the Bank’s Articles of Association, generally applicable laws, supervisory recommendations and separate
internal regulations of the Bank. Meetings of the Bank’s Management Board are held in Polish or, with the consent of all
members of the Management Board present at the meeting, in English. A member of the Management Board who does not
speak the language in which the meeting is held may be assisted by an interpreter.
5.The policy for assessing the suitability of members of the Bank’s bodies includes questionnaires for assessing a member
of the Management Board also in terms of independence and absence of conflicts of interest as well as declarations that
the function performed is the main area of professional activity of the member of the Management Board. This principle is
adhered to and monitored, among others, during the periodic assessment of the individual and collective suitability of
members of the Bank’s Management Board.
Principles set out in Chapter 4. "Supervisory body”
With regard to the principles set out in this chapter, the Bank pays attention in particular to the principles relating to the
exercise of day-to-day oversight responsibilities by the Supervisory Board.
1. Supervisory Board meetings are convened as and when required, but at least once in each quarter of the financial year.
In 2025, there were 19 meetings of the Supervisory Board and 12 meetings of the Audit Committee. Supervisory Board
meetings are held in Polish or, with the consent of all Supervisory Board members present at the meeting, in English.
2. In order to perform its duties, i.e. exercise constant supervision over the Bank’s activities in all areas of its operations, the
Supervisory Board may, in particular: examine all documents of the Bank, review the state of the Bank’s assets, demand
from the Management Board, proxies, persons employed in the Bank on the basis of an employment contract or performing
certain activities for the Bank on a regular basis on the basis of a contract for specific work, a contract of mandate or
another contract of a similar nature to prepare or submit any information, documents, reports or explanations concerning
the Bank, in particular its activities or assets; the subject of the demand may also be information, reports or explanations in
the possession of an obliged body or person concerning the Bank’s subsidiaries and affiliated companies.
3. The Supervisory Board provides information on the effectiveness of the supervision exercised, the manner in which the
information requested from the Management Board is provided and its quality. The Supervisory Board reports on the
appointment of an advisor to examine a selected area of the Bank’s activities. The information is included in the Annual
Report of the Supervisory Board, which is submitted to the General Meeting.
Principles set out in Chapter 5. "Remuneration policy”
With regard to the principles set out in this chapter, the Bank, among others, pays attention to the principles related to the
remuneration of persons with a significant impact on the risk profile.
1. Pursuant to the Remuneration Policy for the Supervisory Board Members of BNP Paribas Bank Polska S.A., the amount of
remuneration of the Supervisory Board members is determined by the General Meeting. Remuneration of the members of
the Supervisory Board is determined adequately to the function performed, as well as adequately to the scale of activity,
complexity of the organisational structure and complexity of the Bank’s activity.
2. Remuneration of members of the Management Board or persons holding key functions is governed by the "Remuneration
Policy for Persons with a Significant Impact on the Risk Profile BNP Paribas Bank Polska S.A.", which has been introduced
with a view to the need for prudent, stable and effective management of the Bank’s risk, capital and liquidity and with a
particular focus on the long-term well-being of the Bank, the interests of the Bank’s shareholders, investors and
stakeholders, and the welfare of the Bank’s customers.
3. Pursuant to the "Remuneration Policy for Persons with a Significant Impact on the Risk Profile of BNP Paribas Bank
Polska S.A." the amount of variable remuneration is determined on the basis of the performance of the Bank as a whole, the
performance of the organisational unit and individual performance, and is subject to change in line with changes in such
performance. The Bank’s performance taken to determine the amount of performance-based variable remuneration takes
into account: income, operating expenses, the Bank’s cost of risk, tax charges, cost-to-income ratio and return on equity,
cost of capital and liquidity risk over the long term. The assessment of performance is related to the degree to which the
Bank’s budget is met.
Principles set out in Chapter 6. "Information policy”
The principles set out in this chapter are implemented at the Bank primarily in accordance with the Information Policy of
BNP Paribas Bank Polska SA.
1. The Information Policy BNP Paribas Bank Polska S.A. governs responsibility for contacts with particular stakeholder
groups. It stipulates that the Bank, as a public company and a supervised institution, when providing information, is guided
by the principles of corporate governance, in compliance with the applicable laws, including the requirements of the
Banking Law, the Code of Commercial Companies, the Public Offering Act and the Trading in Financial Instruments Act, and,
in particular, the Bank observes the principles of banking and professional secrecy and the principles of preventing the use
and disclosure of confidential information. According to the Policy, the tasks of the Investor Relations Office are to ensure
that the Bank’s information obligations as a company listed on the Warsaw Stock Exchange (Giełda Papierów
Wartościowych w Warszawie S.A.) are duly and timely fulfilled. An extract from the Information Policy is published on the
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Bank’s website, in the Investor Relations section: https://www.bnpparibas.pl/relacje-inwestorskie/lad-
korporacyjny/polityka-informacyjna.
Principles set out in Chapter 7. "Promotional activities and customer relations”
With regard to the principles set out in this chapter, in addition to the principles related to advertising communications, the
Bank pays particular attention to the principles describing the process of offering financial products or services and the
process of dealing with complaints.
1. The Bank has policies, procedures and instructions in place to ensure that the information provided by employees is
reliable, clear and understandable to customers. This principle is implemented by ensuring that employees adequately
implement the adopted training paths and professional preparation necessary for their work, through the development of
employees’ competences in accordance with the development programmes in force at the Bank (induction training courses,
individual development plans, mandatory training courses) and ensuring that employees are adequately prepared by
implementing training programmes on the products offered (product training courses), as well as ensuring that employees
are adequately prepared and certified as required by specific legislation, through the implementation of training courses
that certify and confirm knowledge (professional training courses for insurance distribution, training courses for employees
providing information on investment services and products). In addition, the implementation of this principle is supported
by the development of operational instructions and sales procedures that take into account the implementation of steps of
providing complete and reliable information on the Bank’s products and services, the provision of an accessible and up-to-
date knowledge base on individual products and sales processes, and the inclusion, in the processes of creating new
products, of an obligation to carry out training to familiarise employees with the nature of the newly introduced product.
2. Information on the complaint handling process is included in the General Terms and Conditions or in the contractual
templates that the Bank enters into with customers when establishing a relationship. Publicly available information is also
included on the Bank’s website at https://www.bnpparibas.pl/repozytorium/reklamacje
3. The Bank also has internal rules developed and in force describing the operation of the complaint handling process
(including participating units) and the position of the Bank’s Customer Ombudsman.
4. The Bank has implemented internal rules for the preparation of marketing communications to ensure its compliance with
the adopted principles, including the "Rules for the creation of marketing materials at BNP Paribas Bank Polska S.A.". and
the "Principles for acceptance of marketing materials and other communications to customers".
Principles set out in Chapter 8. "Key internal systems and functions"
With regard to the principles set out in this chapter, the Bank fully complies with the regulations and market standards in
force in this area, in particular giving importance to the functioning of the internal control system.
1. The Bank’s internal control system is based on three lines of defence model and is adapted to the organisational
structure. The Bank’s internal control system relies on a set of control mechanisms ensuring the achievement of the
objectives of the internal control system set out in Recommendation H (i.e. the effectiveness and efficiency of the Bank’s
operations, the reliability of financial reporting, compliance with the Bank’s risk management principles, compliance of the
Bank’s operations with laws, internal regulations and market standards). The internal control system is governed by the
"Principles of Internal Control". In addition, the Bank has developed and adopted a "Compliance Risk Management Policy",
defining the key areas of compliance risk, as well as defining the responsibilities of the Bank’s employees in managing
compliance risk.
2. The Bank has an Internal Control Committee, whose main purpose is to support the Management Board in ensuring the
proper functioning of the operational risk management system and the internal control system. The Committee brings
together key representatives of the three lines of defence. An Audit Committee has been established within the Supervisory
Board. Among its duties, it is responsible for performing supervisory activities over the activities of the Internal Audit
Division.
3. The Bank annually selects the essential processes based on the criteria adopted by the Bank and documents a
description of the link between the general objectives and the specific objectives of the internal control system identified
within them and the essential processes and key controls, as well as the independent monitoring of compliance with these
controls.
4. As part of its risk management system, the Bank has a fully harmonised operational and IT operating architecture. The
Bank consistently develops and adapts the credit risk management system to changing requirements by developing and
implementing internal regulations, processes, tools and systems. The Bank works on an ongoing basis to increase the
efficiency and tooling of processes and applications used in the risk area. The Bank implements all internal audit, auditor
and supervisor recommendations without delay.
5. The Bank’s risk management system includes: the organisational structure, specifying the responsibilities and tasks of
the bodies, committees and organisational units of the Bank’s Head Office/the Bank’s organisational units participating in
the risk management system; and the policies and procedures setting out the detailed principles of risk identification,
measurement, acceptance, control, monitoring and reporting; as well as the tools: the IT system, data warehouses,
databases and IT applications supporting the risk management process.
6. Risk management at the Bank is carried out on the basis of the Bank’s policies and other internal regulations on the
identification, measurement, acceptance, control, monitoring and reporting of risks, approved by the relevant decision-
makers, within the scope of their competence. Credit policies and procedures are reviewed periodically to adapt them to
changes in the Bank’s risk profile and the economic environment in which the Bank operates. The Bank’s internal risk
management regulations take into account the regulatory requirements for the banking sector and the standards
applicable in the BNP Paribas Group.
7. In accordance with the requirements set out in Article 9c(2)(2) of the Banking Law of 29 August 1997, the Bank has
established and maintains a compliance function to identify, assess, control and monitor the risk of non-compliance of the
Bank’s activities with laws, internal regulations and market standards and to present reports in this respect (compliance).
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250
8. The responsibility of the Bank’s Management Board for ensuring an effective compliance system and the principles of
organisation, scope of responsibility and mechanisms ensuring the independence and effectiveness of the compliance
function (Compliance Monitoring Division) are set out in the Regulation of the Minister of Finance, Funds and Regional
Policy of 10 June 2021 on the risk management system and internal control system and remuneration policy in banks and
Recommendation H of the Polish Financial Supervision Authority concerning the internal control system in banks, which
have been appropriately implemented in the Bank’s internal regulations, in particular in the Rules on the operation of the
Compliance Monitoring Division and the Compliance Policy at BNP Paribas Bank Polska SA.
9. The internal control system includes an internal audit function as the third line of defence to conduct an independent
and objective examination and evaluation of the adequacy and effectiveness of the risk management system and the
internal control system.
10. The Supervisory Board and the Management Board of the Bank ensure that the Internal Audit Division has a status that
guarantees autonomy, independence, impartiality and the budget and powers necessary to perform its tasks.
11. The Internal Audit Division operates on the basis of the International Standards for the Professional Practice of Internal
Auditing and the Code of Ethics as set out by The Institute of Internal Auditors (IIA), the standards developed by The
Information Systems Audit and Control Association (ISACA) and the guidelines set out by the supervisory authorities.
Principles set out in Chapter 9. "Exercise of rights from assets acquired at the customer’s risk”
The principles set out in this chapter are implemented by BNP Paribas Bank Polska Brokerage Office based, among others,
on internal policies and procedures, in particular ensuring the protection of customers’ interests, including on the basis of
the provisions of the "Policy for acting in the best interest of the customers of BNP Paribas Bank Polska S.A. regarding
investment services and trading in financial instruments at the Brokerage Office" and the "Rules for the provision of
portfolio management services comprising one or more financial instruments by the Brokerage Office of BNP Paribas Bank
Polska S.A. for Private Banking Customers".
Best Practice for WSE Listed Companies
The corporate governance rules of the "Best Practice for WSE Listed Companies 2021" ("Best Practice", "DPSN 2021"),
adopted by the Warsaw Stock Exchange Supervisory Board by Resolution No. 13/1834/2021 of 29 March 2021, came into
force on 1 July 2021.
The content of the Best Practice for WSE Listed Companies 2021 is available on the WSE’s website at:
https://www.gpw.pl/dobre-praktyki.
The Bank’s Management Board, by Resolution 49/BZ/42/2021 of 30 July 2021, adopted for application the set of principles
under the "Best Practice for WSE Listed Companies 2021". Subsequently, the Extraordinary General Meeting of the Bank
adopted for application the principles contained in the "Best Practice for WSE Listed Companies 2021" by Resolution No. 3
of 4 January 2022.
As a listed company, the Bank is subject to the obligation to include in its annual report a statement of compliance with the
corporate governance principles pursuant to the provisions of § 72(7)(5) of the Regulation of the Minister of Finance of 6
June 2025 on current and periodic information disclosed by issuers of securities and conditions for recognising as
equivalent information required by the laws of a non-member state.
In addition, pursuant to § 29(3) of the WSE Rules and in accordance with the principles set out in the relevant resolutions
of the WSE Management Board, the Bank is required to provide the Exchange, via the WSE Reporting System (EBI until
2025, currently WSE Data), with reports on compliance with the corporate governance principles.
Information on compliance with the "Best Practice for WSE Listed Companies" including all EBI reports (currently WSE Data
reports) is available on the Bank’s Investor Relations website (https://www.bnpparibas.pl/relacje-inwestorskie/lad-
korporacyjny/dobre-praktyki-spolek-notowanych-na-gpw).
In order to allow investors and analysts to view companies’ statements in various combinations and variants, a Best
Practice Scanner has also been made available on the Stock Exchange’s website (Główny Rynek GPW – Skaner Dobrych
Praktyk).
Pursuant to the obligations arising from the provisions of the Warsaw Stock Exchange Rules and the standards resulting
from the content of the corporate governance principles: "Best Practices for WSE Listed Companies 2021", below is a
description of the implementation of selected principles most relevant to the Bank’s mission, the values by which the Bank
is guided in its activities and of significant importance to shareholders and Customers.
1. INFORMATION POLICY AND COMMUNICATION WITH INVESTORS
1. The Management Board and the Corporate Communications Department are responsible for shaping and implementing
the Bank’s information policy. The Press Officer and employees of the PR Team are responsible for cooperation and
representing the Bank in its contacts with the media and opinion makers. In addition to the members of the Management
Board, only the Press Officer and employees of the PR Team are authorised to officially present the Bank’s position in the
media. The Investor Relations Office is responsible for relations with shareholders, investors and other capital market
participants, and the Bank’s website (investor relations section) is the primary communication tool:
https://www.bnpparibas.pl/relacje-inwestorskie (English version: https://www.bnpparibas.pl/investor-relations).
2. The operating strategy of BNP Paribas Bank Polska S.A. in 2025 was the GObeyond Strategy for 2022-2025, adopted by
the Management Board and the Supervisory Board in March 2022. The main objective of this strategy was to continue the
The status of compliance with the "Best Practice for WSE Listed
Companies 2021" at the Bank is subject to constant review. As at the date
of publication of this Report, the Bank complies with all the principles set
out in the "Best Practice for WSE Listed Companies 2021".
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251
dynamic development of the Bank as an institution that operates efficiently, with committed employees and satisfied
customers, while being a leader in activities that support sustainable development.
3. The new strategy of the BNP Paribas Bank Polska S.A. Group for 2026-2030 “Accelerate 2030” was approved by the
Supervisory Board of the Bank on 10 December 2025. The Bank plans further growth in retail and corporate banking
segments. The Bank will focus on technology innovation, especially based on AI, as well as the cost discipline. The Bank
remains strongly committed to its values: a close combination of economic, social and environmental objectives is a key
part of the strategy. These objectives are defined in the IMPACT pillar (one of three pillars of the Bank’s new strategy). The
plan is to sell PLN 25 billion new sustainability-linked loans.
Under the new strategy, the Bank plans to finance a broad range of investments in energy transition and decarbonisation in
all key customer segments, with a focus on energy efficiency in the industry and real estate, the development of renewable
energy sources and low-carbon transportation. The Bank will continue to focus on ESG risk management, reduction of the
carbon footprint of the loan portfolio and continued decarbonisation of own operations. In the agro-food sector, where the
Bank remains the financing leader, the priority is to support sustainable transition of the entire value chain, in particular by
leveraging regenerative agriculture practices. With this approach, the Bank will remain the first choice partner of
professional farmers, especially in financing their energy transition with renewable energy sources, such as agrivoltaics,
biogas and biomethane.
A presentation of the Bank’s “Accelerate 2030” Strategy is available on the Bank’s website:
https://www.bnpparibas.pl/relacje-inwestorskie/o-banku/strategia-banku. It takes into account the financial and non-
financial targets planned to be achieved over the strategy horizon. Strategy progress will be presented on the Bank’s
website, including periodic reports (including the Management Board’s Activity Report).
4. A description of the implementation of the strategy is part of the annual reports, investor presentations and materials
published on the Bank’s website.
5. Oversight of ESG (E – environmental, S – social, G – governance) factors, including the implementation of strategic
sustainability objectives, is exercised by the Management Board headed by the CEO. The Management Board approves the
direction and scope of activities, and gives its opinion on and supervises the integration of sustainability activities.
Sustainability tasks are carried out by the Sustainability and Agrobusiness Area, which acts as the coordinator of ESG
activities in the organisation. The Executive Director of the Area reports directly to the CEO. In addition, the Executive
Director of the Area heads the informal structure of the Sustainability Community, acting as Chief Sustainability Officer.
6. With regard to climate change risk, as part of the review of the risk identification process, ESG risk was assessed as
material to the Bank and was introduced into the Risk Management Strategy.
7. Implementing market best practice in 2020, BNP Paribas Bank Polska S.A. measured the pay gap for the first time. After
analysing the results, systemic and dedicated actions and recommendations were taken to reduce the level of the pay gap,
including as part of the annual remuneration review process. The pay equity indicator is measured according to the Bank’s
internal methodology taking into account total pay based on homogeneous groups of employees (created by area of
employment and grade level). The indicator is published in the annual Management Board Report and on the Bank’s annual
report website. Under the GObeyond Strategy 2022-2025, the Bank planned a further reduction of the GPG ratio to below
4%. At the end of 2025, the pay gap, as expressed by the Gender Pay Gap indicator, was 3.7%. This means that men’s pay
was 3.7% higher than that of women in comparable positions. The indicator is a weighted average of the size of the
different employee groups.
2. MANAGEMENT BOARD AND SUPERVISORY BOARD
1. The Supervisory Board exercises ongoing oversight of the Bank’s activities across all areas of its operations. The
Supervisory Board of BNP Paribas Bank Polska S.A. operates on the basis of the provisions of the Banking Law, the
Commercial Companies Code, as well as the Bank’s Articles of Association and the Rules of the Supervisory Board. The
Articles of Association and the Rules are available on the Bank’s website.
2. The Management Board is the Bank’s managing and executive body, operating in accordance with applicable legal
regulations, the Bank’s Articles of Association and the Rules of the Management Board.
3. The Bank has a diversity policy, which formally forms part of the policy for assessing the suitability of the members of
the Supervisory Board of BNP Paribas Bank Polska S.A. and, in the case of the members of the Management Board, forms
part of the policy for assessing the suitability of the members of the Management Board and Persons holding key functions
at BNP Paribas Bank Polska S.A., which was adopted by the Supervisory Board on 8 December 2022.
4. The application of criteria to ensure diversity in the Bank’s bodies is a legally binding requirement under specific
regulations as well as the EBA (European Banking Authority) Guidelines applicable to banks. The Bank implements the
diversity policy in practice, including with regard to ensuring an adequate representation of women in the Bank’s bodies.
The Bank has taken a strategic decision reflected in the Diversity Policy that by 2025 it will ensure the participation of 30%
women in the Management Board and Supervisory Board, counted separately. As at the end of 2025, the proportion of
women on the Supervisory Board is 50% and the proportion of women on the Management Board is 37.5%. Compliance with
the principle of diversity is monitored not only at the level of the Bank’s bodies, but also at the level of managerial
positions. At the end of 2025, the share of women in Senior Managerial Positions (managing director, executive director,
tribe leader) was 42%.
5. Detailed information on the statutory bodies of the Bank and the members of the Management Board and the
Supervisory Board is presented later in this report under "Statutory bodies of the Bank".
3. INTERNAL SYSTEMS AND FUNCTIONS
1. The Bank has implemented an internal control system adapted to the organisational structure and based on a model of
three lines of defence. The Bank has an internal control system with individual internal control elements of a permanent
and periodic nature. As part of the internal control system, the Bank identifies the risks associated with each operation,
transaction, product and service. The Bank’s internal control system is based on a set of control mechanisms that ensure
the achievement of the internal control system objectives defined in Recommendation H (i.e., the effectiveness and
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252
efficiency of the Bank’s operations, the reliability of financial reporting, compliance with the Bank’s risk management
principles, and the Bank’s compliance with legal regulations, internal rules and market standards).
2. The compliance unit within the internal control system is appropriately positioned and treated as a key element
(alongside the control function) in ensuring compliance within the Bank. Within the internal control system, the internal
audit unit acts as the third line of defence and is responsible, among other tasks, for assessing the adequacy and
effectiveness of the management system, in particular the risk management system and the internal control system,
through audit tasks carried out as part of the audit process defined by the Bank.
3. The internal control system is governed by the Internal Control Rules. In addition, the Bank has developed and adopted a
Compliance Policy, which defines the key areas associated with compliance risk as well as the responsibilities of Bank
employees in managing this risk.
4. The Bank’s risk management system includes:
• an organisational structure defining the responsibilities and tasks of the bodies, committees and organisational units of
the Bank’s Head Office/Bank units involved in the risk-management system,
• policies and procedures specifying detailed principles for identifying, measuring, accepting, controlling, monitoring and
reporting risk,
• tools such as the IT system, data warehouses, databases and IT applications supporting the risk management process.
4. GENERAL MEETING AND RELATIONS WITH SHAREHOLDERS
1. The Bank enables shareholders to participate and vote at the General Meeting by means of electronic communication (e-
General Meeting). The Bank conducts real-time transmission of the General Meeting via the Internet and allows direct
participation of media representatives. Recordings of the proceedings are posted on the Bank’s website – Investor
Relations/General Meetings section.
2. The Bank responds to inquiries from shareholders within deadlines that comply with the applicable legal standards.
3. On 15 April 2025, the Annual General Meeting of the Bank adopted a resolution on the payment of dividends from the net
profit made in 2024. Based on this resolution, the Bank paid a dividend of PLN 1,162,340,659.26, i.e. PLN 7.86 per share. The
dividend covered all shares issued by the Bank, i.e. 147,880,491 shares. The dividend record date was set for 22 April 2025
and the dividend payment date for 9 May 2025.
4. Detailed information on the activity of the General Meeting in 2025 is presented under "Statutory bodies of the Bank".
5. CONFLICTS OF INTEREST AND RELATED PARTY TRANSACTIONS
1. Members of the Management Board and of the Supervisory Board avoid any activity that could lead to a conflict of
interest. In the event of a potential conflict of interest, e.g. during voting on a resolution of the Bank’s Management Board
or Supervisory Board, a member of the body does not take part in the voting (this is recorded in the minutes each time).
6. RENUMERATION
1. The remuneration paid to persons with a significant impact on the Bank’s risk profile is adequate, i.e. it reflects their
contribution to the achievement of the Bank’s objectives, their workload and the best market practice of rewarding persons
in similar positions, as adopted on the Polish market, and takes into account the appropriate ratio of fixed remuneration to
variable remuneration.
2. The remuneration of the members of the Supervisory Board is determined in accordance with their functions, as well as
in accordance with the scale of operations, the complexity of the organisational structure and the degree of complexity of
the Bank’s activities.
3. In order for the Bank to be able to attract, retain and motivate highly qualified individuals serving as members of the
Management Board, the Remuneration Policy also takes into account market practice. This means that it may be changed
in a situation where market practice differs from the principles adopted by BNP Paribas Bank Polska S.A.
4. The Bank does not operate a management stock option programme understood as an optional (subject to the decision of
the eligible person) right to acquire shares at a predetermined price, the expiry of a certain period of time and the
fulfilment of certain conditions. The Bank currently operates an incentive programme implemented in accordance with
Article 9ca(1) of the Banking Law and the Regulation of the Minister of Finance, Funds and Regional Policy of 8 June 2021 on
the risk management system and internal control system and remuneration policy in banks, under which part of the
variable remuneration is paid in the form of warrants convertible into Bank shares. This is an incentive scheme in which
the Bank pays variable remuneration (annual bonus) to executives by determining the number of shares using their market
value, and shares are taken up at their nominal value.
The Bank’s Management Board declares that the Bank and its bodies
complied in 2025 with the corporate governance principles set out in
the "Corporate Governance Principles for Supervised Institutions" and
the standards set out in the "Best Practice for WSE Listed Companies".
No non-compliance with the corporate governance principles reported
by the Bank was identified in the period covered by this report.
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Financial results
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opportunities
Corporate
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253
Shares and shareholders
Shareholding structure
The table below shows the Bank’s shareholding structure as at 31 December 2025, including shareholders who held at
least 5% of the total number of votes at the General Meeting.
Table 138. Shareholding structure as at 31 December 2025
shareholder
number of shares
% of share capital
number of votes at the
General Meeting
% of the total number
of votes at the General
Meeting
BNP Paribas, total:
110,910,367
75.00%
110,910,367
75.00%
BNP Paribas
directly
75,420,141
51.00%
75,420,141
51.00%
BNP Paribas
Fortis SA/NV directly
35,490,226
24.00%
35,490,226
24.00%
Other
36,970,124
25.00%
36,970,124
25.00%
Total
147,880,491
100.00%
147,880,491
100.00%
As of 8 April 2024, the Bank’s share capital amounts to PLN 147,880,491. The capital consists of PLN 147,880,491 shares
with a nominal value of PLN 1 each, including:
• A series - 15,088,100 shares,
• B series - 7,807,300 shares,
• C series - 247,329 shares,
• D series - 3,220,932 shares,
• E series - 10,640,643 shares,
• F series - 6,132,460 shares,
• G series - 8,000,000 shares,
• H series - 5,002,000 shares,
• I series - 28,099,554 shares,
• J series - 2,500,000 shares,
• K series - 10,800,000 shares,
• L series - 49,880,600 shares,
• M series - 322,859 shares,
• N series - 138,714 shares.
Four series B shares are preference shares. The preference includes the right to receive payment of the full nominal
amount per share in the event of liquidation of the Bank after satisfaction of creditors, in priority to payments attributable
to ordinary shares, which payments, in view of the exercise of the preference, may not cover the nominal amount of these
shares.
The total number of votes attached to all the Bank’s shares is 147,880,491. The number of votes resulting from the Series
M Shares allocated in 2025 is 20,223 votes and from the Series N Shares is 60,398 votes.
Changes in shareholder structure in 2025
Table 139. Shareholding structure as at 31 December 2024
shareholder
number of shares
% of share capital
number of votes at the
General Meeting
% of the total number of
votes at the General
Meeting
BNP Paribas, total:
120,124,392
81.28%
120,124,392
81.28%
BNP Paribas
directly
84,634,166
57.26%
84,634,166
57.26%
BNP Paribas
Fortis SA/NV directly
35,490,226
24.01%
35,490,226
24.01%
Other
27,675,478
18.72%
27,675,478
18.72%
Total
147,799,870
100.00%
147,799,870
100.00%
• On 7 April 2025, the Bank’s share capital was increased from PLN 147,799,870 to PLN 147,820,093 as a result of the
acquisition of 20,223 series M shares of the Bank in exercise of rights from previously acquired series A5 subscription
warrants.
• On 8 April 2025, the Bank’s share capital was increased from PLN 147,820,093 to PLN 147,880,491 as a result of the
acquisition of 60,398 series N shares of the Bank in exercise of rights from previously acquired series B2 subscription
warrants.
• On 16 December 2025, as a result of the settlement of block trades concluded on 12 December 2025 in connection with
the completion of the accelerated book building for 9,214,025 shares of the Bank, the share of BNP Paribas SA in the total
number of votes at the Bank’s general meeting decreased by approximately 6.23%.
BNP Paribas SA directly holds 75,420,141 shares in the Bank representing (as at 31 December 2025) approximately 51.00%
of the total number of shares and votes in the Bank, and together with other entities of the BNP Paribas SA Group controls
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254
a total of 110,910,367 shares in the Bank representing (as at 31 December 2025) approximately 75.00% of the total number
of shares and votes in the Bank.
Detailed information on the acquisition of the series M and N shares and the accelerated book building are presented in the
section: Abut us, Key corporate events.
BNP Paribas’ intention regarding the liquidity of the Bank’s shares
BNP Paribas SA’s intention to increase the number of the Bank’s free float shares to at least 25% was fulfilled in December
2025 with the sale of 9,214,025 Bank shares by BNP Paribas S.A. The details of the transaction are presented in the section:
Abut us, Key corporate events.
Bank shares held by members of the Management Board and members of the Supervisory Board
A summary of the Bank’s shares and share entitlements held by the members of the Bank’s Management Board and
Supervisory Board as at the date of the report for 2025 (5 March 2026) and the Financial Statements for the third quarter
of 2025 (6 November 2025) is presented below.
Table 140. Number of shares and subscription warrants held by members of the Bank’s Management Board and
Supervisory Board
Member of the Bank’s
Management Board
shares
6.11.2025
subscription
warrants
1
6.11.2025
sale/purchase
of shares
shares
5.03.2026
subscription
warrants
1
5.03.2026
Przemysław Gdański
47,646
2
8,203
-14,146
33,500
2
8,203
André Boulanger
3
-
5,163
-
-
5,163
Małgorzata Dąbrowska
-
1,208
-
-
1,208
Wojciech Kembłowski
-
3,590
-
-
3,590
Piotr Konieczny
455
1,571
-
455
1,571
Magdalena Nowicka
2,392
2,632
-
2,392
2,632
Volodymyr Radin
1,364
2,333
-
1,364
2,333
Agnieszka Wolska
4
6,538
2,905
-
6,538
2,905
Natalie Yacoubian
5
-
-
-
-
-
Member of the Bank’s
Supervisory Board
shares
6.11.2025
subscription
warrants
1
6.11.2025
sale/purchase
of shares
shares
5.03.2026
subscription
warrants
1
5.03.2026
Jean-Charles Aranda
-
770
-
-
770
1) subscription warrants taken up on 24.03.2025: series A6 – one series A6 warrant entitles to take up one series M ordinary bearer share of BNP Paribas Bank Polska S.A., at the issue price of PLN 1.00 per
share and B3 series – one series B3 warrant entitles to take up one series N ordinary bearer share of BNP Paribas Bank Polska S.A., at the issue price of PLN 1.00 per share
2) registered pledge was established on 18,000 shares of the Bank held by Przemysław Gdański, at a price of PLN 111.50 per share
3) André Boulanger resigned as a member of the Bank’s Management Board as of 31 December 2025; the share holding balance as at 31 December 2025 is presented at the date of the 2025 Report (5
March 2026)
4) Agnieszka Wolska resigned as a member of the Bank’s Management Board as of 2 January 2026; the share and subscription warrant holding balance as at 2 January 2026 is presented at the date of the
2025 Report (5 March 2026)
5) Natalie Yacoubian has been a member of the Bank’s Management Board as of 1 January 2026
The other members of the Supervisory Board did not declare their shareholding/entitlements in the Bank as at 5 March
2026, which has not changed since the submission of the Q3 2025 Financial Statements (6 November 2025).
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255
Statutory bodies of the Bank
General Meeting
The manner of operation of the General Meeting and its basic powers are set out in the generally applicable provisions of
the Code of Commercial Companies and Partnerships and the Banking Law, as well as the Bank’s internal documents – the
Bank’s Articles of Association and the Rules of the General Meeting of BNP Paribas Bank Polska S.A., taking into account the
provisions of the "Code of Best Practice for WSE Listed Companies" and the "Corporate Governance Principles for
Supervised Institutions". The above corporate documents are available on the Bank’s website
https://www.bnpparibas.pl/relacje-inwestorskie/lad-korporacyjny/dokumenty-banku
General Meetings are held as annual and extraordinary General Meetings. Annual General Meetings are held once a year,
no later than within 6 months after the end of each financial year. Extraordinary General Meetings are convened as
necessary by the Bank’s Management Board on its own initiative or at the request of the Supervisory Board, or at the
request of a shareholder or shareholders representing a total of at least 5% of the share capital.
The General Meeting decides on matters which, in accordance with the law and the Bank’s internal regulations, are
reserved to the competence of the General Meeting. In particular, the General Meeting decides on the following matters:
• considering and approving the report of the Management Board on the Bank’s activities and the financial statements for
the previous financial year,
• examining and approving the report of the Management Board on the activities of the Banking Group and the
consolidated financial statements of the Banking Group for the past financial year,
• adopting a resolution on the distribution of profit or coverage of loss,
• granting discharge to the members of the Bank’s bodies for the performance of their duties,
• amending the Bank’s Articles of Association,
• appointment and dismissal of members of the Supervisory Board – one of the criteria of the suitability assessment is the
verification of possible conflicts of interest. The General Meeting receives a report with a summary of the assessment,
which includes the necessary information on the results of the suitability assessment, including information on conflicts
of interest. The document is available to the public,
• setting the principles for remuneration and amount of remuneration of the members of the Supervisory Board,
• increase or reduction of the Bank’s share capital,
• issuing convertible bonds and bonds with pre-emptive rights to acquire the Bank’s shares, as well as subscription
warrants,
• redemption of shares and specification of detailed conditions for such redemption,
• merger or liquidation of the Bank, the appointment of liquidators and the manner in which liquidation is to be carried out.
The Company convenes the General Meeting by means of an announcement published on the Bank’s website
https://www.bnpparibas.pl/relacje-inwestorskie/walne-zgromadzenie – at least 26 days before the date of the General
Meeting. Together with the Notice convening the General Meeting, draft resolutions (with the Supervisory Board’s opinion),
justifications to resolutions and other materials submitted to the General Meeting are made available on the Bank’s
website. The dates on which the above materials are made available to the public enable the participants of the General
Meeting to familiarise themselves with them in detail.
Shareholders may attend the General Meeting and exercise their voting rights in person or by proxy. The Bank also enables
shareholders to participate in the General Meeting by means of electronic communication, ensuring two-way
communication in real time, and to exercise their voting rights during the meeting in person or by proxy.
Voting takes place by means of an electronic voting and counting system that ensures that votes are cast in the number of
shares held. Each share confers the right to one vote. In the event of a secret ballot, the system ensures confidentiality.
Voting rights are exercised by shareholders in person or by proxy.
The Bank also allows media representatives to attend the General Meeting.
The General Meeting is broadcast in real time over the Internet and the recording of the broadcast is posted on the Bank’s
website under the tab dedicated to the relevant General Meeting. Information on the planned transmission of the General
Meeting is announced at the time of publication of the Notice convening the General Meeting.
The Annual General Meeting of the Bank was held on 15 April 2025, which, in addition to resolutions of a procedural
nature:
• approved the annual reports and statements submitted by the Management Board and the Supervisory Board, as required
by law, including the Financial Statements, the Management Board Report on the Bank’s activities (including the
Sustainability Report of the BNP Paribas Bank Polska S.A. Group for 2024),
• decided on distribution of the profit from 2024 in the amount of PLN 2,320,798 thousand, of which PLN 1,162,341
thousand was allocated to dividend payments, PLN 658,457 thousand to reserves, and the remaining amount was left as
retained earnings,
• discharged the members of the Management Board and Supervisory Board for the performance of their duties in 2024,
• adopted a resolution on periodic assessment of the individual and collective suitability of the members of the Supervisory
Board,
• adopted a resolution on assessment of the adequacy of the Bank’s internal regulations concerning the functioning of the
Supervisory Board and the effectiveness of its operations,
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• adopted a resolution approving the report submitted by the Supervisory Board of the Bank on the independent evaluation
of the functioning of the remuneration policy at BNP Paribas Bank Polska S.A. in 2024,
• adopted a resolution approving an opinion on the report of the Supervisory Board on remuneration of the members of the
Supervisory Board and the Management Board of BNP Paribas Bank Polska S.A. in 2024,
• adopted resolutions approving the individual assessment of suitability of a candidate for member of the Supervisory
Board of BNP Paribas Bank Polska S.A. and on changes to the Supervisory Board of BNP Paribas Bank Polska S.A.,
• adopted a resolution on the collective assessment of suitability of the Supervisory Board of BNP Paribas Bank Polska S.A.
in connection with changes to the Supervisory Board,
• adopted a resolution on determination of remuneration of members of the Supervisory Board of BNP Paribas Bank Polska
S.A.,
• adopted resolutions on amendments to the Bank’s Articles of Association and on approval of the consolidated text of the
Articles of Association of BNP Paribas Bank Polska S.A.,
• adopted a resolution on the use of reserves capital of BNP Paribas Bank Polska S.A.
An Extraordinary General Meeting of the Bank was held on 27 November 2025, which, in addition to resolutions of a
procedural nature:
• adopted a resolution on amendments to the Articles of Association of BNP Paribas Bank Polska S.A.,
• adopted a resolutions on approval of the consolidated text of the Articles of Association of BNP Paribas Bank Polska S.A.
The text of the resolutions adopted by the General Meeting is available on the BNP Paribas Bank Polska S.A. website at:
https://www.bnpparibas.pl/relacje-inwestorskie/walne-zgromadzenie and https://www.bnpparibas.pl/relacje-
inwestorskie/walne-zgromadzenie/archiwum-walnych-zgromadzen-banku-bnp-paribas
Essential rights of shareholders and how to exercise them
The rights of shareholders are set out in the Rules of the Bank’s General Meeting and derive from the provisions of the
Commercial Companies Code. The following are the most important shareholder rights:
• each shareholder is entitled to a share of the profit shown in the audited financial statements and allocated by the
General Meeting for distribution to the shareholders,
• each shareholder has the right to participate in the General Meeting and exercise his/her voting rights in person or by
proxy,
• each shareholder may participate in the General Meeting using electronic means of communication (he/she may speak at
the General Meeting and exercise his/her voting rights during the General Meeting either in person or through an
attorney). Detailed rules of participation in the Bank’s General Meeting using electronic means of communication are set
out in the "Rules of participation in the General Meeting of BNP Paribas Bank Polska S.A. using electronic means of
communication",
• each shareholder or shareholders representing jointly at least 5% of the Bank’s share capital may demand that an
Extraordinary General Meeting be convened, as well as that certain items be put on the agenda of the General Meeting,
• shareholders representing at least half of the Bank’s share capital or at least half of the total voting rights in the Bank
may convene an Extraordinary General Meeting. The shareholders appoint the Chairperson of this meeting,
• each shareholder has access to the list of shareholders. He or she may inspect the list of shareholders at the Bank’s
registered office, request a copy of the list or request that the list of shareholders be sent to him or her by e-mail,
• each shareholder has the right to receive copies of motions relating to items on the agenda of the General Meeting within
one week before the date of the General Meeting and to request information from the Bank’s Management Board relating
to items on the agenda of the General Meeting, subject to the exceptions set out in the Commercial Companies Code,
• each shareholder has the right to inspect the book of minutes of the General Meeting and to request copies of the
resolutions certified by the Bank’s Management Board,
• each shareholder has the right to demand a secret ballot,
• each shareholder has the right to object to a resolution being adopted and to challenge resolutions of the General
Meeting in the cases and subject to the exceptions set out in the Commercial Companies Code (action to repeal a
resolution or action to declare a resolution invalid),
• each shareholder has the right to ask questions and request information from the Management Board regarding matters
on the agenda of the General Meeting in the cases and subject to the exceptions set out in the Commercial Companies
Code.
Procedure for amending the Bank’s Articles of Association
Any amendment to the Bank’s Articles of Association requires a resolution of the General Meeting and an entry in the
Register of Entrepreneurs of the National Court Register. An amendment to the Bank’s Articles of Association also requires a
permit from the Polish Financial Supervision Authority, as provided for in Article 34(2) of the Act of 29 August 1997 –
Banking Law (consolidated text Journal of Laws of 2016, item 1988, as amended). Motions of the Bank’s Management Board
regarding amendments to the Bank’s Articles of Association, as well as other matters submitted by the Bank’s Management
Board for consideration by the General Meeting, should be subject to prior opinion of the Bank’s Supervisory Board.
In matters concerning amendments to the Bank’s Articles of Association, including in particular changes to the Bank’s
business name, its registered office, its business profile (as referred to in § 5(2) of the Bank’s Articles of Association),
increase or decrease of the Bank’s share capital, issue of convertible bonds and bonds with the pre-emptive right to acquire
the Bank’s shares, as well as subscription warrants, and liquidation or dissolution of the Bank, sale of the whole or part of
the banking enterprise, the resolutions of the General Meeting are adopted by a majority of three-fourths of the votes cast.
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A resolution on merger of the Bank with another Bank or credit institution requires a resolution of the General Meeting
adopted by a majority of 2/3 of votes (§ 13(2) of the Bank’s Articles of Association).
Pursuant to the provisions of § 20(1)(1)(m) of the Bank’s Articles of Association, immediately after the General Meeting
adopts resolutions introducing amendments to the Bank’s Articles of Association, the Supervisory Board determines the
consolidated text of the Bank’s Articles of Association and is responsible for introducing other amendments of editorial
nature, as specified in the resolutions of the General Meeting.
Amendments made to the Bank’s Articles of Association in 2025
1. Pursuant to Resolution 36 of the AGM of 15 April 2025, the Bank’s Articles of Association were amended as follows:
• In the existing § 5 para. 3 item 16), the following phrase shall be deleted:
“provide services in respect of transport of cash values”
• In the existing § 5 para. 3 item 19), the following phrase shall be deleted:
“trade in fiscal marks and numismatic values”
• The existing § 5 para. 3 item 20) shall read as follows:
“issue electronic identification means within the meaning of the Act on Trust Services and Electronic Identification”
• In the existing § 6 item 2), the following phrase shall be deleted:
“contract credits and cash loans”
• In the existing § 6 item 5), the following phrase shall be deleted:
“implement, on its own or in cooperation with other entities, other business undertakings both in Poland and abroad”
• In the existing § 6 item 6), the following phrase shall be deleted:
“use distinguishing trademarks to mark offered services”
• In the existing § 6 item 7), the following phrase shall be deleted:
“provide training services”
• The existing § 12 para. 1 item 1) shall read as follows:
“examine and approve the report of the Management Board of the Bank on the Bank’s operations, including sustainability
reporting and financial statements for the previous financial year,”
• The existing § 12 para. 1 item 2) shall read as follows:
“examine and approve the activity report of the Management Board of the Bank on the Bank’s group, including
sustainability reporting and consolidated financial statements of the group for the previous financial year,”
• The existing § 20 para. 1 item 1 sec. g) shall read as follows:
“appointment of an audit firm to audit the Bank’s financial statements, consolidated financial statements of the Group
and the attestation of sustainable development reporting,”
• The existing § 20 para. 1 item 1) sec. j) shall read as follows:
“giving consent to conducting operations the purpose of which is to contract a liability or dispose of assets with the total
value in relation to one entity exceeding 10% of shareholders’ equity, with the exception of banking operations referred to
in § 5 para. 2, operations referred to in § 6 para. 1 item 3, and contracting lombard loans,”
• The existing § 20 para. 1 item 2) sec. a) shall read as follows:
“evaluation of the report of the Management Board of the Bank on the Bank’s operations, including sustainability
reporting and the Bank’s financial statements for the previous financial year, as regards their compliance with books of
accounts and documents, as well as the facts, evaluation of the motions of the Management Board of the Bank concerning
the profit distribution or loss coverage,”
• The existing § 20 para. 1 item 2) sec. b) shall read as follows:
“evaluation of the report on operations, including sustainability reporting and financial statements for the previous
financial year for the Bank group, as regards their compliance with books of accounts and documents, as well as the
facts,”
• The existing § 20 para. 6 shall read as follows:
“The majority of the Audit Committee members fulfil conditions of independence stipulated in the Act on Statutory
Auditors, Audit Firms and Public Oversight, and at least one of them has qualifications knowledge and skills in accounting
or auditing of financial statements or attestation of sustainability reporting. The above independence requirement is
deemed satisfied if the terms and conditions set forth in this paragraph are fulfilled by persons specified in § 16 para. 4.”
• The existing § 22 para. 2 item 2a) shall read as follows:
“acceptance of the report on the activity of the Bank, including sustainability reporting, Bank’s financial statements and
report on the activity of the Group, including sustainability reporting and consolidated financial statements of the Group,”
• The existing § 22 para. 3 shall read as follows:
“The resolution of the Management Board mentioned in para. 2 item 12 is not required in the event of providing bank
services determined in § 6 item 3), plus taking out lombard loans.”
• The existing § 28 shall read as follows:
“The bank’s own funds are the sum of Common Equity Tier I capital, Additional Tier I capital and Tier II capital.”
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• The existing § 32 shall read as follows:
"1. Additional capital is established from net profit deductions in a financial year and a surplus obtained at issuing shares
above their nominal value, remaining after covering the costs of issuance, from additional capital payments made by
shareholders in exchange for assigning special rights to their existing shares without increasing the share capital.
2. Reserve capital is established from net profit deductions in a financial year, earmarked for covering the balance sheet
loss and other purposes or expenditures.
3. The general risk fund is earmarked for unidentified risk related to banking operations and is established from net profit
deductions in the amount resolved by the General Meeting.
4. Special purpose funds may be established from net profit deductions on the basis of resolutions of the General Meeting.
The General Meeting, when establishing a special purpose fund, determines its purpose.
5. The General Meeting decides on the use of the supplementary and reserve capitals, and a part of the supplementary
capital in the amount of one-third of the share capital may be used only to cover balance sheet losses.
6. The following are allocated to cover the balance sheet loss:
1) Reserve capital,
2) Supplementary capital,
3) General risk fund for unidentified risk related to banking operations,
4) Special purpose funds indicated in para. 4, if they are established.”
2. Pursuant to Resolution 3 of the EGM of 27 November 2025, the Bank’s Articles of Association were amended as follows:
• The existing § 28 shall read as follows:
“1. The bank’s own funds in a prudential sense are the sum of Common Equity Tier I capital, Additional Tier I capital and
Tier II capital.
2. The bank’s own funds in an accounting sense include:
1) share capital (paid-up and registered),
2) reserve capital,
3) revaluation capital,
4) AT1 capital bonds,
5) general risk fund for unidentified risk of banking operations,
6) valuation adjustment fund,
7) undistributed profits from previous years,
8) profit in the process of approval and net profit of the current reporting period, calculated in accordance with
applicable accounting standards,
9) specific funds, if established.”
• The existing § 33 shall read as follows:
“1. The internal regulations of the Bank are issued by:
1) Bank bodies in the form of resolutions,
2) Members of the Management Board in the form of circular letters or other internal legal acts, and
3) Persons holding positions specified in the methodology of internal legislation, in the form of circular letters or
other internal legal acts.
2. The detailed principles and methods of issuing internal regulations within the Bank and also scope and types of such
regulations, are defined in the internal legislative methodology resolution of the Management Board of the Bank.”
Supervisory Board
Principles of operation of the Supervisory Board
The Supervisory Board of BNP Paribas Bank Polska S.A. operates under the provisions of the Banking Law, the Code of
Commercial Companies as well as the Bank’s Articles of Association and the Rules of the Supervisory Board. The Articles of
Association and the Rules are available on the Bank’s website: https://www.bnpparibas.pl/relacje-inwestorskie/lad-
korporacyjny/dokumenty-banku.
The Supervisory Board is appointed by the General Meeting for a joint term of five years. As of 31 December 2025, the
Supervisory Board consists of 12 members. At least half of the members of the Supervisory Board have good knowledge of
the Banking market in Poland, i.e. speak Polish and have relevant experience on the Polish market. The mandates of
Supervisory Board members expire at the end of their term of office on the date of the General Meeting which approves the
financial statements for the last full year in which they held office. The mandate of a member of the Supervisory Board
appointed before the expiry of a given term of office of the Supervisory Board expires at the same time as the mandates of
the other members of the Supervisory Board. The expiry of the mandate of a member of the Supervisory Board also occurs
as a result of resignation, dismissal and death.
The Supervisory Board exercises constant supervision over the Bank’s activities in all aspects of its operation. In particular,
it evaluates the Management Board Reports on the activities of the Bank and the Bank Group and the Financial Statements
of the Bank and the Bank Group for the previous financial year. It verifies that they are consistent with the books,
documents and facts. It assesses the Management Board’s proposals for the distribution of profit or coverage of loss. It
supervises the implementation of the internal control system and assesses its adequacy and effectiveness.
The Supervisory Board prepares and presents to the Annual General Meeting an annual report on its activities, including a
summary of the activities of the Supervisory Board Committees. In addition, the Supervisory Board presents the Annual
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General Meeting with a report on the results of the evaluation of the audit of the financial statements (separate and
consolidated financial statements, including the Management Board’s proposal for profit distribution), the Management
Board’s report on the Group’s activities and the evaluation of the report on non-financial information. In addition to
evaluating the adequacy and effectiveness of the internal control system, the Supervisory Board assesses the risk
management system, compliance assurance and the internal audit function. It also assesses compliance with the principles
of corporate governance, the functioning of the remuneration policy and the suitability policy on the appointment of
members of the Management Board and the Supervisory Board, and the reasonableness of the sponsorship and charitable
policy.
Resolutions of the Supervisory Board are effectively adopted if all members of the Supervisory Board have been notified of
the meeting and at least half of the members of the Supervisory Board are present at the meeting, including its
Chairperson or Vice-Chairperson. Resolutions of the Supervisory Board are adopted by a simple majority of votes in an open
vote. At the request of a member of the Supervisory Board, the Chairperson of the Supervisory Board orders a secret ballot.
The Supervisory Board may also adopt resolutions in writing, without convening a meeting or by means of direct
communication at a distance, in particular by means of telephone, audiovisual and electronic communication.
The Bank’s Articles of Association (§ 16(4)) stipulate that at least two members of the Supervisory Board should meet the
independence criteria. Independent members of the Supervisory Board should not be related to the Bank, the Bank’s
shareholders or employees in a way that could materially influence or give rise to a reasonable presumption of materially
influencing the independent member’s ability to make impartial decisions.
As of 1 January 2025, five members of the Supervisory Board met these criteria: Lucyna Stańczak-Wuczyńska, Monika
Kaczorek, Małgorzata Chruściak, Jacques Rinino, and Mariusz Warych.
As at 31 December 2025, following changes to the composition of the Supervisory Board made in 2025, five members of the
Supervisory Board met these criteria: Lucyna Stańczak-Wuczyńska, Monika Kaczorek, Małgorzata Chruściak, Bożena
Leśniewska, and Jacques Rinino. The composition of the Bank’s Supervisory Board and its committees is adequate in terms
of numbers and in line with diversity and suitability criteria, both individually and as a whole body, which contributes to
the effective exercise of ongoing supervision by the Supervisory Board. Conducting periodic individual and collective
assessments of the suitability of the members of the Supervisory Board ensures that the composition of the Supervisory
Board is maintained in such a way as to guarantee an optimum level of qualifications, knowledge and professional
experience, thereby ensuring an appropriate level of collegial supervision of the Bank.
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Table 141. Composition of the Bank’s Supervisory Board and Supervisory Board Committees as at 31 December 2025, including information on the independence of the members
COMMITTEES OF THE SUPERVISORY BOARD
No.
Name
Function on the Supervisory Board
Audit Committee
Risk Committee
Remuneration Committee
Nominations Committee
1.
Lucyna Stańczak-Wuczyńska
Chairperson, independent member
member
member
Chairperson
Chairperson
2.
Francois Benaroya
Vice-Chairperson
member
member
member
3.
Jean Charles Aranda
member
member
4.
Małgorzata Chruściak
independent member
member
member
member
5.
Sophie Heller
member
6.
Monika Kaczorek
independent member
Chairperson
7.
Bożena Leśniewska*
independent member
8.
Vincent Metz
member
9.
Piotr Mietkowski
member
10.
Khatleen Pauwels
member
11.
Jacques Rinino
independent member
member
Chairperson
12.
Mariusz Warych
member
member
membe
* on 15 April 2025, the Annual General Meeting of the Bank appointed Bożena Leśniewska as an independent member of the Supervisory Board of the Bank as of 15 April 2025
Table 142. Composition of the Bank’s Supervisory Board and Supervisory Board Committees as at 31 December 2024, including information on the independence of the members
COMMITTEES OF THE SUPERVISORY BOARD
No.
Name
Function on the Supervisory Board
Audit Committee
Risk Committee
Remuneration Committee
Nominations Committee
1.
Lucyna Stańczak-Wuczyńska
Chairperson, independent member
member
member
Chairperson
Chairperson
2.
Francois Benaroya
Vice-Chairperson
member
member
member
member
3.
Jean-Charles Aranda
member
member
4.
Małgorzata Chruściak
independent member
member
member
member
5.
Sophie Heller
member
6.
Monika Kaczorek*
member
member
7.
Vincent Metz
member
8.
Piotr Mietkowski
member
9.
Khatleen Pauwels
member
10.
Jacques Rinino
independent member
Chairperson
11.
Mariusz Warych
independent member
Chairperson
member
* on 2 July 2024, the Extraordinary General Meeting of the Bank appointed Monika Kaczorek as an independent member of the Supervisory Board of the Bank as of 3 July 2024
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Changes in the composition of the Bank’s Supervisory Board in 2025:
• on 15 April 2025, the Annual General Meeting of the Bank appointed Ms Bożena Leśniewska as Independent Member of
the Bank’s Supervisory Board as of 15 April 2025 until the end of the current five-year joint term of office of the members
of the Supervisory Board,
• on 28 April 2025, Mr Mariusz Warych announced his resignation as Chairperson of the Audit Committee of the Supervisory
Board as of 28 June 2025,
• on 6 May 2025, Mr Francois Benaroya announced his resignation as Member of the Audit Committee of the Supervisory
Board as of 28 June 2025,
• on 7 May 2025, the Supervisory Board appointed Ms Monika Kaczorek as Chairperson of the Audit Committee of the
Supervisory Board and Mr Jacques Rinino as Member of the Audit Committee of the Supervisory Board as of 28 June 2025.
The competences and professional experience of the members of the Bank’s Supervisory Board are presented on the Bank’s
website https://www.bnpparibas.pl/o-banku/rada.
In 2025, the members of the Bank’s Supervisory Board devoted an appropriate amount of time to the performance of their
duties. The Bank’s Supervisory Board held 19 meetings in 2025, of which 15 were in writing. The Bank’s Supervisory Board
adopted 85 resolutions. The attendance rate of the Supervisory Board members at meetings was 96.4%.
In 2025, the Supervisory Board fulfilled its duties, which derive from the law and the Bank’s Articles of Association. These
duties are set out in the "Framework Work Plan of the Supervisory Board and the Committees operating at the Supervisory
Board for 2025". In addition, the Supervisory Board received current information on the most important developments and
decisions of the Management Board, so that it had adequate knowledge of the Bank’s position, the macroeconomic situation
and the market environment. In this way, it was able to assess how these factors affected the Bank’s performance and
development plans.
Table 143. Individual activity of Supervisory Board members in 2025*
Lucyna
Stańczak-
Wuczyńska
Francois
Benaroya
Khatleen
Pauwels
Małgorzata
Chruściak
Bożena
Leśniewska
Vincent
Metz
19/19
19/19
19/19
18/19
13/14
19/19
Piotr
Mietkowski
Mariusz
Warych
Monika
Kaczorek
Jean-Charles
Aranda
Sophie
Heller
Jacques
Rinino
18/19
19/19
19/19
18/19
16/19
18/19
* attendance at meetings/number of meetings
Members of the Supervisory Board
Pursuant to the Policy for the assessment of the suitability of the members of the Supervisory Board of BNP Paribas Bank
Polska S.A. in force at the Bank, developed on the basis of the guidelines of the European Banking Authority of 21 March
2018 on the assessment of the suitability of management board members and of key function holders (EBA/GL/2021/06)
and the Methodology of the Polish Financial Supervision Authority for the assessment of the suitability of the members of
the bodies of supervised entities (published on 27 January 2020), as well as the Banking Law and other legal acts regulating
the aforementioned issues, the members of the Supervisory Board are subject to individual suitability assessment (initial
and periodic) and collective suitability assessment – the Supervisory Board as a whole.
Individual and collective suitability assessments are carried out at least once a year and in situations indicated in the
Bank’s Policy, such as when candidates for the Supervisory Board members are put forward (prior to the appointment of
the person concerned), when the composition of the Supervisory Board changes or when there is a significant change in the
Bank’s business model. The Nominations Committee carries out an assessment of the individual and collective suitability of
the Supervisory Board and the results of the suitability assessment are presented by the Supervisory Board to the General
Meeting.
The members of the Supervisory Board have diverse expertise, a high level of qualifications, competence and professional
experience. They ensure an appropriate level of collegial supervision of all areas of the Bank’s activities and guarantee a
broad and comprehensive representation of views in assessing the work of the Bank’s Management Board and the
functioning of the Bank. The Chairperson of the supervisory body is not a member of the management team.
1. Lucyna Stańczak-Wuczyńska – Chairperson of the Supervisory Board (Independent Member)
She is a graduate of economics at the Warsaw School of Economics and of postgraduate Advanced
European Studies programme at the College of Europe in Bruges. Since the beginning of her nearly 30-year
professional career, Lucyna Stańczak-Wuczyńska has been involved in banking. Between 1992 and 1995,
she worked at IBP Bank S.A. in the area of corporate banking. Then, between 1995 and 1997, she worked at
Credit Lyonnais Bank Polska, in the area of corporate finance. In 1997, she took the position of Vice-President at ABN Amro
Bank Polska in the Structured Finance Department. From 2000 to 2020, she was associated with the European Bank for
Reconstruction and Development (EBRD). Initially, as Senior Banker, she was responsible for investments in the energy and
infrastructure sectors. From 2008 as Country Director of the EBRD in Poland. From 2014, she was Regional Director of EU-
Banks, Financial Institution, Central and Southern Europe region with a portfolio of equity and debt investments in banks
and financial institutions exceeding EUR 4 billion. In her professional career, Lucyna Stańczak-Wuczyńska has held a
number of corporate governance positions, was a member and observer of Supervisory Boards and a member of audit and
risk committees at, among others, Polkomtel Sp. z o.o., Alior Bank S.A., Polskie Inwestycje Rozwojowe, Erste Bank in
Hungary, and was a member of the Advisory Board in Private Equity funds. Since December 2020, she has been a member
of the Bank’s Supervisory Board, then Vice-Chairperson and now Chairperson of the Supervisory Board. In 2022, she was
appointed to the Supervisory Board of Banca Transylvania, the largest bank in Romania in terms of assets. Sustainability
and Green Economy Transition topics have always been an important area of interest in her professional work. She has
been involved in project financing related to renewable energy, energy efficiency, low carbon, sustainable finance, green
bond investing, SLB and ESG topics in the area of corporate governance and reporting.
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2. Francois Benaroya – Vice-Chairperson of the Supervisory Board
Graduate of the École Polytechnique and the École Nationale de la Statistique et de l’Administration
Economique in Paris. He also holds a master’s degree in economics from Tilburg University (Netherlands).
He is also a graduate of the Kennedy School of Government at Harvard University. He started his career
in 1994 at the Ministry of Finance in France as deputy director of the Emerging Markets Department. He
then served as Economic Counsellor for Russia and the Commonwealth of Independent States at the
French Embassy in Moscow. From 1999 to 2001, he was Director of the International Trade Analysis Department at the
Ministry of Economy, Finance and Industry in France. Subsequently, he was Deputy Director of the Cabinet of the Minister
for European Affairs. He has been with the BNP Paribas Group since 2004, when he became Deputy Head of Corporate
Banking Development. From 2007 to 2011, he worked for Ukrsibbank, a Ukrainian bank in the BNP Paribas Group, as Deputy
Head of the Retail Banking Division, and then as Head of this Division and Vice-President of the Bank’s Management Board.
Subsequently, he was Head of Retail Banking of the International Retail Banking business line of the BNP Paribas Group. In
2014, he became Managing Director for the integration of BNP Paribas Bank Polska and Bank BGŻ. From April 2015, he was
Vice-President of the Management Board of BNP Paribas Bank Polska S.A. He was initially responsible for the Integration
Area and, from September 2015, for the Retail and Business Banking Area. Since September 2017, he has been part of the
IRB management of the BNP Paribas Group (current name Europe Mediterranean BNP Paribas), where he is responsible for
the area of Central and Eastern Europe and Turkey. In addition, he is Chairperson of the Supervisory Board of Ukrsibbank, a
member of the Supervisory Board of TEB AS and a member of the Supervisory Board of BMCI Morocco. Since 2018, he has
been a member of the Supervisory Board of BNP Paribas Bank Polska S.A. and currently Vice-Chairperson. In 2025, he took
part in a number of training courses covering sustainability.
3. Jean-Charles Aranda – Member of the Supervisory Board
Graduate of the University of Bordeaux, France, where he obtained a Master’s degree in Internal Audit and
Management Control with distinction. Certified Accountant. He started his career in 1998 at KPMG in Paris,
where he was in charge of the banking financial audit area as a manager. From 2004 to 2009, he was Head
of Mission in the Central Accounting Team of the Inspectorate General of BNP Paribas. His tasks included
setting up a new audit team dedicated to financial audits. In 2009, he became Chief Financial Officer of
BNP Paribas El Djazaïr in Algeria and then, from 2013, Chief Operating Officer of the Bank. From August 2016 to April 2017,
he was Executive Director of the Management Accounting and Capital Management Department at BNP Paribas Bank
Polska S.A. From 2017 to 2023, he was Vice Chairperson of the Supervisory Board of BNP Paribas Towarzystwo Funduszy
Inwestycyjnych S.A. He was a member of the Audit Committee participating, among others, in relations with the auditor,
evaluation of the financial statements of funds and sustainability reporting of the TFI. From April 2017 to July 2023, he was
a member of the Management Board, then Vice-President of the Management Board of BNP Paribas Bank Polska S.A.,
responsible for the Finance Area.
4. Małgorzata Chruściak – Independent Member of the Supervisory Board
Graduate of the Faculty of Law and Administration at the University of Warsaw and postgraduate studies in
coaching and mentoring at SWPS and the Psychoeducation Laboratory. She is a lawyer with over 20 years
of experience in supporting business, which she gained, among others, as a partner and head of the
banking practice while working at the largest international law firms in Warsaw: White & Case, CMS
Cameron McKenna and EY Law. She is recognised as a leading legal expert and recommended in the most
prestigious legal rankings: Chambers Europe, IFRL and Legal 500, and works with the European Financial Congress (EFC).
She is a practising business coach and mentor and is a member of the European Mentoring and Coaching Council and a
member of the Association of Restructuring Practitioners. In 2020, she founded her own company "Mentoring for lawyers"
combining legal practice and coaching/mentoring. She took part in the EY Corporate Reporting Forum 2024 and
#ESGONBOARDS focusing on selected ESG factors for supervisory board members. In 2025, she participated among others
in the Supervisory Board Forum which discussed cybersecurity and ESG.
5. Sophie Heller – Member of the Supervisory Board
She graduated from ESSEC Business School, where she received her MBA. She started her professional
career in 1988 as a consultant at Bain & Company. She founded Points Ciel, where she worked as
marketing director from 1992 to 1997. From 1997 to 1998, she was CEO of Consodata and, from 2000 to
2003, she was vice-president of marketing and e-business at Jakala. From 2003 to 2006, she was Chief
Marketing Officer at Equilon, BNP Paribas Group’s innovative consumer lending company, and then, from
2006 to 2009, she was Chief Marketing Officer at Mediatis, a multi-channel direct sales organisation. From 2009 to 2016,
she worked at ING Direct, first as Vice-President Marketing and Communications and then as General Manager of ING
Direct. In 2016, she became COO of Retail Banking and Services at BNP Paribas Group. She has extensive experience in
financial services (management, digitisation, innovation) and entrepreneurship. She took part in the following sustainability
events: LfC Cambridge High Intensity Session on Positive Impact Business, LfC Shape the Future – Mastering Sustainable
Finance – A Cambridge Senior Executive Program.
6. Monika Kaczorek – Independent Member of the Supervisory Board
Graduate of Applied Linguistics at the University of Warsaw. She also completed postgraduate studies in
Market Analysis and Marketing at the Warsaw School of Economics and postgraduate studies in Business
Psychology at the Leon Koźmiński Academy. She qualified as a chartered accountant in 2001. From 1994 to
2020, she worked for Mazars, an international audit and advisory network. In 2005, she became Partner
and Vice-President of the Management Board of Mazars Audit. She led the audit practice and was a leader
in quality and risk management (internal audit, risk management and quality control of the Mazars network in Poland). She
Lucyna Stańczak-Wuczyńska is also Chair of the Programme Council of
Chapter Zero Poland (part of the Climate Governance Initiative). It is a
programme to develop the competencies of supervisory and management
bodies of companies. It was created by the World Economic Forum. The
aim of the Polish version is to raise awareness of the consequences of
climate change for companies and the impact of business on the climate.
Chapter Zero Poland was launched in May 2021 on the initiative of the
Responsible Business Forum in substantive partnership with Deloitte
Poland.
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263
managed numerous teams auditing separate and consolidated financial statements, including financial institutions, listed
entities, as well as performing other assurance and advisory services. She was a member of the Mazars International IFRS
Committee and of the Mazars Group quality control teams. She has many years of experience in the audit of separate and
consolidated financial statements, coordination of assurance and advisory engagements and supervision of strategic
international projects such as mergers, acquisitions, due diligence, public listing. In addition, Monika Kaczorek was a
member of the National Council of Statutory Auditors from 2015 to 2023, including serving as vice-president of the National
Council of Statutory Auditors from 2019 to 2023. Since 2021, she has served as an independent member of the Supervisory
Board, and since 2023 as Chairperson of the Audit Committee of the insurance company TUiR Unum Życie S.A. She is a
member of the Council of the Reporting Standards Foundation of the Association of Listed Companies and a member of the
Chapter of the Best Annual Report Competition. She is also involved in leading projects and trainings related to ESEF, ESG
and optimising the presentation of listed companies’ financial statements to ensure compliance with IFRS and usability for
stakeholders. She leads training courses for auditors and ESG reporting officers. She is authorised to provide assurance of
sustainability reporting. She took part in conferences and webinars on sustainable finance, emission management and DEI
held by Chapter Zero Poland, the Association of Independent Members of Supervisory Boards and the Polish Chamber of
Statutory Auditors.
7. Bożena Leśniewska – Independent Member of the Supervisory Board
She holds an MA in Polish philology from the Jagiellonian University of Kraków. She completed several
post-graduate programmes including the Leadership Psychology Academy at the Business School of the
Warsaw University of Technology, ESG at Collegium Civitas, and business programmes at the University
of Lyon and Cranfield University, Advanced Management at INSEAD and Strategic Leadership for
Executives at HEC, Paris. For most of her 30+ years professional career, she has been involved in the
telecom industry. She joined DHL International Ltd. in 1992. From 1996, she was responsible for sales at Polkomtel S.A. She
joined Orange Polska at PTK Centertel in 2006 as Deputy Director for Business Market Sales and then Director for Business
Client Sales. From 2008, she was Director for Business Clients and then Sales Director at PTK Centertel and
Telekomunikacja Polska SA responsible for the sales strategy and commercial performance. She completed the integration
of B2C and B2B sales structures and created one of the biggest and most diverse sales networks in Poland. She was then
responsible for digital transition at Orange Polska. Since 2017, as Vice-President of the Management Board of Orange
Polska, she is responsible for the business market and for the subsidiaries Integrated Solutions, BlueSoft and Craftware. She
is a member of the Responsible Leadership Board of the Responsible Business Forum, the Think Tank Strategic Board, the
Orange Foundation Board. She is a member and former President of the LiderShe association, an active mentor in
mentoring programmes including the Vital Voices Foundation and the Perspektywy Foundation, and the co-founder of
Europe’s first women’s university programme, the Kozminski University Women Leadership Academy. She completed a
post-graduate programme in sustainability, the Green Academy at Collegium Civitas. She is a certified mentor holding an
EMCC advanced level certificate. In 2025, she completed the Exponential Leadership Program Singularity University Poland.
8. Vincent Metz – Member of the Supervisory Board
Graduate in economics from the University of Paris – École Polytechnique and the École Normale
Supérieure de Lyon. He started his career in 1993 at Compagnie Bancaire, which was renamed Paribas in
1997. At that time, he was director of financial models in the Planning and Development Department.
From 1999, he was associated with the CETELEM Group, where he held a number of positions. He was
Director of External Development, Director of CRM and Global B2C Analysis in the Sales Department, Director of Planning
and Development in the Finance Department. In 2009, he became Director of Product Marketing in the Sales and Marketing
Department at BNP Paribas Personal Finance. During his career he served, among others, as Director of Marketing Analysis
and Steering in the Sales and Marketing Department, Deputy Director of the Key Partners Department, and Deputy CEO of
the PF Inside Area. He is currently Managing Director of Latin America and PF Inside Area and a member of the Executive
Committee of BNP Paribas Personal Finance. He oversees BNP Paribas Personal Finance in six countries. He is an expert in
managing development projects – external development, partner relationships. He specialises in financial services and has
experience in sales and marketing, including finance and risk. As Chairperson of the Board of Directors of BNP Paribas South
Africa Ltd, he was active in the Small Enterprise Foundation (SEF, South Africa’s biggest microfinancing institution for
women) working for the poor and aiming to create an environment supporting those suffering exclusion from financial
services. He completed the programme designed for BNP Paribas: Cambridge Judge Business School Executive Education
(Mastering Sustainable Finance).
9. Piotr Mietkowski – Member of the Supervisory Board
Graduate in economics from the University of Paris Dauphine. He completed postgraduate studies in
International Economic Relations at the Institute of Political Science in Paris. He started his career as an
economist, focusing on emerging markets and European affairs. He then worked in the Business
Development Department of BNP Paribas and in the Corporate Finance Department, where he was
responsible for Central and Eastern Europe. He is currently Managing Director of Investment Banking in the BNP Paribas
Group for Central and Eastern Europe, Greece, Turkey and Israel. He took part in many training programmes covering
sustainability, including Excellence in Sustainable Finance Transactions, ESG Risks, Inclusive Leadership.
10. Khatleen Pauwels – Member of the Supervisory Board
She obtained a degree in commercial engineering from the EHSAL Business School in Brussels in 2000. She
started her career at Siemens IT Services, where she was responsible for the creation of the e-commerce
portfolio. She then continued at Siemens Business Services, where she was project manager, sales
portfolio manager and director of tendering. She also led the IT team for Outsourcing and Pre-Sales. From
2007, she was associated with Fortis Bank. She then worked at BNP Paribas Fortis, where she held a
number of positions. From 2010, she was head of the IT Resource Management and Strategic Sourcing Team. From 2013,
she led more than a dozen process improvement initiatives in Distribution Channels and CRM, before becoming Director of
Distribution Channels and CRM in the E2E Operations Area in 2015. In 2018, she took over the leadership of the Operations
Department, which led the Retail and Business Customer Service. Since January 2020, she has been Managing Director of
the E2E Operations Area (Customer Service Centre) and a member of the Executive Committee of BNP Paribas Fortis. In
2024, she was certified in the programme “Shaping the Future: Sustainable Finance” at Cambridge Judge Business School
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Executive Education. In connection with her new role as Vice-President for Compliance (as of June 2024), she has been
certified in compliance.
11. Jacques Rinino – Independent Member of the Supervisory Board
Jacques Rinino completed his second degree (MA) in economics at the Pantheon Sorbonne University of
Paris. In 1976, he joined Banque PARIBAS (now BNP Paribas) where he held a number of positions. From
1992 to 1997, he was Group Head of Commercial Banking and Private Banking at BNP Paribas China and
Hong Kong. From 1998 to 2001, he was Head of Corporate Banking Risk for Europe, Mediterranean, Middle
East and Africa at BNP Paribas Head Office and, from 2001 to 2014, he was Head of Risk at BNP Paribas
IRB responsible for Risk in Retail Banking in Europe and Mediterranean and Retail Banking in the United
States (Bank of the West – First Hawaiian Bank). He supervised risk in leasing (BNP Paribas Leasing
Solutions), ARVAL and BNP Paribas Personal Finance and was a member of Global Risk Management EXCO. From 2011 to
2013, he was a member of the Board of BNP Paribas Lease Group. From 2014 to 2016, he was a senior advisor to BNP
Paribas International Retail Banking (IRB) executives on the development of corporate strategy for retail banking in Europe
and Asia. From 2014 to 2020, he was a member of the Board of TEB AS Bank (Turkey), then Chairperson of the Audit
Committee and the Risk Committee of the bank. From 2020 to 2021, he was Chairperson of the Board of TEB ShA, a
subsidiary of TEB in Kosovo, and from 2021 to January 2023, an independent member of the Board and Chairperson of the
Risk Committee at BICICI, a BNP Paribas company in Côte d’Ivoire. In addition, he has been Chairperson of BORGNIS
CONSEIL, a financial and corporate services consultancy, since 2016. For more than 15 years, he has been a member of the
management board of an organisation for people with disabilities (Delos Apei 78).
12. Mariusz Warych – Member of the Supervisory Board
Graduated in Economics from the Faculty of Economics and Foreign Trade at the University of Łódź. He
obtained a diploma in Finance and Accounting at the Hogeschool van Utrecht in the Netherlands.
Between 1997 and 1998, he participated in the Association of Chartered Certified Accountants (ACCA)
programme. He is a certified internal auditor with qualifications of Certified Internal Auditor (CIA). From
1996 to 2002, he worked as an external auditor at Ernst & Young in New York, Toronto, Vancouver,
London and Warsaw. From 2003 to 2004, he was CFO at Citileasing Sp. z o.o. and Handlowy-Leasing S.A.;
from 2004 to 2008, he was regional coordinator for Central Europe at KBC GROUP N.V. From 2008 to
2011, he was director of internal audit for Central, Eastern Europe and Russia at AVIVA. From 2011 to
2012, he was Director of Enterprise Risk Management at Deloitte Advisory and a member of the Supervisory Board and
Audit Committee at Jastrzębska Spółka Węglowa S.A. He was a financial advisor to the Canadian Polish Congress in
Vancouver, where he also hosted a programme on NOFA Polish Radio. Since 2009, he has chaired the Audit Heads Club in
Poland. He sits on the supervisory board and is Chairperson of the audit committee at UKRSIBBANK in Ukraine and Signal
Iduna Polska. He is a specialist in: management, supervision and assessment of the effectiveness of business operations,
identification and resolution of financial and operational weaknesses, management of risks related to the achievement of
strategic business objectives, internal audit, business training and independent membership of supervisory boards and
audit committees. He has been a member of the Supervisory Board of BNP Paribas Bank Polska S.A. since June 2013. In
2024, he completed a series of training courses at the Association of Listed Companies focusing on ESG and sustainability
reporting.
Committees of the Supervisory Board
The Supervisory Board sets up internal Committees, which consist of members of the Supervisory Board. The Committees
have a consultative and advisory function for the Supervisory Board and are intended to improve its work. For this purpose,
the Committees prepare opinions, recommendations and proposals for decisions on applications received by the
Supervisory Board in a working procedure. The scope and procedure of the Committees are defined in their bylaws, which
are introduced by the Supervisory Board in the form of a resolution.
Committees of the Bank’s Supervisory Board:
• Audit Committee
• Risk Committee
• Remuneration Committee
• Nominations Committee
The composition of the Supervisory Board and the composition of the Committees of the Bank’s Supervisory Board as at 31
December 2025 and as at 31 December 2024 is presented in Tables 141 and 142 together with information on the
independence of the members.
Audit Committee
The Audit Committee supports the Supervisory Board in monitoring the integrity of financial information, the effectiveness
of the internal control system and the monitoring of the performance of auditing activities. It is responsible for ensuring the
effectiveness of the Bank’s internal audit function and therefore oversees the activities of the Internal Audit Division. It
ensures the flow of information and ensures good cooperation between the external auditor (statutory auditor), internal
audit and the Supervisory Board. The Audit Committee prepares annual reports on its activities. These include a risk
assessment of the areas it oversees and evaluation of the effects of its activities. In addition, the Audit Committee
supervises the activities of the auditor and periodically evaluates its work. The Audit Committee has been established by
the Supervisory Board in accordance with the legal provisions concerning the appointment, composition and functioning of
the Audit Committee, as well as the independence of its members and the fact that they possess the appropriate knowledge
and skills, knowledge of accounting and auditing principles.
Composition of the Audit Committee
The Audit Committee consists of five members, three of whom are independent members of the Supervisory Board. They
meet the independence criteria referred to in the Regulation of the Minister of Finance on the Audit Committee and § 16(4)
of the Bank’s Articles of Association, as well as in the Act on Statutory Auditors, Audit Firms and Public Supervision. The
competence of the Committee members, to the extent necessary for the proper fulfilment of their functions, is analysed in
detail and confirmed in the suitability assessment process.
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Following the resignations made on 28 June 2025 by Mariusz Warych as Chairperson of the Audit Committee and Francois
Benaroya as member of the Audit Committee, the Supervisory Board decided on 7 May 2025 to appoint Monika Kaczorek as
Chairperson of the Audit Committee and Jacques Rinino as member of the Audit Committee as of 28 June 2025.
Composition of the Audit Committee as at 31 December 2025:
• Monika Kaczorek – Chairperson of the Committee (independent member)
• Jean-Charles Aranda – member of the Committee
• Jacques Rinino – member of the Committee (independent member)
• Mariusz Warych – member of the Committee
• Lucyna Stańczak-Wuczyńska – member of the Committee (independent member)
All members of the Audit Committee have adequate knowledge, competence and many years of experience in the financial
and accounting areas:
• Monika Kaczorek – Chairperson of the Committee, member of the Committee since 15 July 2024 – is a graduate of Applied
Linguistics at the University of Warsaw. She was qualified as a statutory auditor in 2001. She has long-standing
experience in auditing separate and consolidated financial statements, coordination of assurance and advisory
assignments, and supervision of strategic international projects such as mergers, acquisitions, due diligence, introduction
of companies to public trading gained, among others, in the international audit and advisory network Mazars, where she
also served as Partner and Vice-President of the Management Board of Mazars Audit. She was a member of the National
Council of Statutory Auditors, where she also served as Vice-President of the National Council of Statutory Auditors. She is
a member of the Council of the Reporting Standards Foundation of the Association of Listed Companies and a member of
the Chapter of the Best Annual Report Competition.
• Lucyna Stańczak-Wuczyńska – education in economics and 30 years of experience in banking and finance, gained while
working in the banking sector, in commercial banking and the EBRD. She has held a number of corporate governance
roles, was a member of supervisory boards (or observer) and a member of audit and risk committees (e.g. Alior Bank). She
has gained industry knowledge and skills from managing (as Director of the EU Banks Team at EBRD in London) for many
years the portfolio (debt and equity) of a significant group of banks in 12 EU countries, Central and Southern Europe.
• Jean-Charles Aranda – economic education with specialisation in Internal Audit and Management Control. Chartered
Accountant. He gained experience at KPMG in Paris, where he was in charge of the banking financial audit area as a
manager. For many years, he was Head of Mission in the Central Accounting Team of the Inspectorate General of BNP
Paribas, where he created a new audit team dedicated to financial audits. He was Chief Financial Officer and Chief
Operating Officer of BNP Paribas El Djazaïr in Algeria. Since 2017, he has been associated with BNP Paribas Bank Polska
S.A., initially working as Executive Director of the Management Accounting and Capital Management Department and then
as Vice-President of the Management Board, responsible for the Finance Area. He also served as Vice Chairperson of the
Supervisory Board of BNP Paribas Towarzystwo Funduszy Inwestycyjnych S.A.
• Mariusz Warych – competence in accounting, auditing and internal auditing, confirmed by his CIA diploma. Participant of
the ACCA Coursework programme. Many years of experience as an independent member of supervisory boards and audit
committees (JSW, Selena FM, Ukrsibbank Ukraine). External auditor at Ernst & Young – auditing banks in Poland, UK,
Canada and USA. Evaluated the functioning of Audit Committees. Chairperson of the Audit Heads Club in Poland. Gained
knowledge and skills as CFO at Citi Group – in leasing companies, as well as regional coordinator at KBC Group –
overseeing KBC Group’s activities in Poland.
• Jacques Rinino – graduate of the Pantheon Sorbonne University of Paris, economist, with the BNP Paribas Group since
1976. He has held a number of management positions in the Group’s global structure throughout his career, including as
Group Head of Commercial Banking and Private Banking at BNP Paribas China and Hong Kong, Head of Corporate Banking
Risk for Europe, Mediterranean, Middle East and Africa at BNP Paribas Head Office, Head of Risk at BNP Paribas IRB
responsible for Risk in Retail Banking in Europe and Mediterranean and Retail Banking in the United States (Bank of the
West – First Hawaiian Bank). He supervised risk in leasing (BNP Paribas Leasing Solutions), ARVAL and BNP Paribas
Personal Finance and was a member of Global Risk Management EXCO. Long-time member of Supervisory Boards, Audit
Committees and Risk Committees of subsidiaries in the international BNP Paribas Group
Detailed information on the background and professional experience of the Committee members is provided in the
Supervisory Board section and on the Bank’s website https://www.bnpparibas.pl/o-banku/rada
Permanent members of the Audit Committee also attend the meetings:
• Member of the Management Board who oversees the Finance Area,
• Member of the Management Board who oversees the Risk Area,
• Managing Director of the Internal Audit Division,
• Managing Director of the Compliance Monitoring Division.
Meetings of the Audit Committee
The Audit Committee meets at least four times a year or more frequently as required by its tasks, including each time
before the publication of the Bank’s results and financial reports. In 2025, 12 Audit Committee meetings were held, six of
them by written procedure
The Committee discussed among others the following:
• financial statements for 2024,
• Management Board report on the activity of the BNP Paribas Bank Polska S.A. Group in 2024 (including the Management
Board report on the activity of BNP Paribas Bank Polska S.A. in 2024 and the Sustainability Report of the BNP Paribas Bank
Polska S.A. Group for 2024),
• quarterly and half-yearly reports on financial performance in 2025,
• information on the capital adequacy of the BNP Paribas Bank Polska S.A. Group,
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• provision of additional services by the audit firm,
• audit plan for the financial statements,
• the action plans of the Internal Audit Division and the Compliance Division,
• annual and periodic reports on the activities of the Internal Audit and Compliance Divisions,
• annual report on the evaluation of the adequacy and effectiveness of the internal control system,
• periodic reports on the status of the monitored audit recommendations and on the implementation of the PFSA
recommendations,
• SREP results,
• annual and periodic reports on complaints and applications handled at the Bank,
• a report on compliance with ethical principles and the results of a review of breaches of internal regulations or applicable
law by employees or units of the company,
• information on the Bank’s compliance with the "Best Practice for WSE Listed Companies 2021" and the financial
information communication process in 2024,
• annual reports on the operation of the compliance oversight system in the Brokerage Office and the Custody Services
Department,
• results of the review of the accounting and reporting process and the management accounting system,
• annual report on the activities of the Bank’s Audit Committee to the Supervisory Board.
In addition, the Committee periodically evaluated the performance of the external auditor. The Committee discussed and
reviewed updated regulations in the areas of accounting, auditing and compliance and recommended them to the
Supervisory Board for adoption.
In 2025, all members of the Audit Committee actively participated in the Committee’s meetings and showed a high
commitment to the proper performance of their duties. The overall attendance of Committee members at meetings was
100%. The number and duration of meetings, as well as access to resources, were sufficient to enable the Audit Committee
to fully discharge its responsibilities.
Oversight by the Audit Committee of the selection of the audit firm
The Audit Committee supervises the activities of the auditor. It makes recommendations to the Supervisory Board on the
appointment or termination of the services of the auditor. It monitors compliance with the principle of the auditor’s
independence and objectivity and the rules of information exchange. In addition, the Committee periodically evaluates the
performance of the external auditor.
The cooperation with the auditor follows the "Policy on the selection of the audit firm at BNP Paribas Bank Polska S.A.", the
"Procedure for selecting the audit firm at BNP Paribas Bank Polska S.A.", and the "Policy on the provision of permitted non-
audit services at BNP Paribas Bank Polska S.A. by the audit firm, by affiliates of the audit firm and by members of the audit
firm’s network", which set out such rules to ensure that the selection of the audit firm is carried out correctly and in
accordance with the applicable legislation, maintaining the independence of the audit firm and the key auditor, ensuring
the application of transparent and non-discriminatory evaluation criteria for the selection of the audit firm during the
tender process, and ensuring that the principles of appropriate rotation of audit firms and the key auditor are maintained,
including waiting periods.
The main objective of the "Policy on the provision of permitted non-audit services at BNP Paribas Bank Polska S.A. by the
audit firm, by affiliates of the audit firm and by members of the audit firm’s network" is to analyse the compliance of the
additional service with legal regulations, as well as to control and monitor the independence of the key auditor and the
audit firm. The policy allows for the provision of permitted services, to the extent not related to the Bank’s tax policy,
following an analysis of independence and approval of their provision.
The "Policy on the selection of the audit firm at BNP Paribas Bank Polska S.A." and the "Procedure for selecting the audit
firm at BNP Paribas Bank Polska S.A." were updated in September 2025. The key amendments to the Policy and the
Procedure follow from the Act of 6 December 2024 amending the Act on Statutory Auditors, Audit Firms and Public
Supervision and certain other Acts and include an update of the definitions and a modification of the regulatory text, and
the addition of provisions on sustainability reporting assurance.
The "Policy on the provision of permitted non-audit services at BNP Paribas Bank Polska S.A. by the audit firm, by affiliates
of the audit firm and by members of the audit firm’s network" was updated in December 2025. The amendments follow
from the Act of 6 December 2024 amending the Act on Statutory Auditors, Audit Firms and Public Supervision and certain
other Acts and clarify the applicable principles, and otherwise follow from modifications to the organisational structure of
the Bank.
The Supervisory Board, based on the recommendations of the Audit Committee, adopted the following resolutions regarding
the selection of the audit firm:
• On 15 September 2023, Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością sp.k. was selected—by
resolution of the Supervisory Board—to audit and review the separate financial statements of BNP Paribas Bank Polska
S.A. and the consolidated financial statements of the BNP Paribas Bank Polska S.A. Group, including reporting packages,
for the years 2024–2025.
• On 22 September 2025, Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością sp.k. was selected to
provide assurance services on the Bank’s and the Group’s sustainability reporting for 2025.
• On 10 December 2025, Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością sp.k. was selected to audit
and review the financial statements and to provide assurance services on sustainability reporting for the years 2026–
2029.
The audit firm Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością sp.k. provided the following authorised
non-audit services to the Bank in 2025 regarding assurance in relation to:
• Statement of remuneration of the Supervisory Board and the Management Board for 2024,
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• compliance of qualitative and quantitative information on the capital adequacy of the Bank’s Group as at 30 June 2025
and 31 December 2024 in accordance with the CRR.
• an external audit of Input Data for the following benchmarks: WIBID/WIBOR (for the period from 17 June 2023 to 16 June
2025) and WIRON (for the period from 13 August 2023 to 12 August 2025).
Risk Committee
The Risk Committee supports the Supervisory Board in overseeing the area of risk management. The Committee gives its
opinion on the Bank’s overall current and future risk appetite. It gives its opinion on the risk management strategy for the
Bank’s activities and on the information submitted by the Management Board on the implementation of this strategy.
Together with the Supervisory Board, it oversees the implementation of the risk management strategy in the Bank’s
activities by senior management. The Risk Committee verifies that the prices of liabilities and assets offered to customers
fully reflect the Bank’s business model and its risk strategy. In the event that these prices do not adequately reflect the
risks, in line with the risk management model and strategy, the Committee proposes to the Bank’s Management Board such
solutions that the prices of liabilities and assets are appropriate to the risks.
Each year, the Committee presents an annual report on its activities to the Supervisory Board.
Composition of the Risk Committee
The Committee consists of at least three persons appointed from among the members of the Supervisory Board.
Composition of the Risk Committee as at 31 December 2025:
• Jacques Rinino – Chairperson of the Committee (independent member)
• Francois Benaroya – Member of the Committee
• Małgorzata Chruściak – Member of the Committee (independent member)
• Mariusz Warych – Member of the Committee
• Lucyna Stańczak-Wuczyńska – Member of the Committee (independent member)
Three members of the Risk Committee, together with the Committee Chairperson, meet the criteria for independence in
accordance with the "Act on Statutory Auditors, Audit Firms and Public Supervision".
Meetings of the Risk Committee
The Risk Committee meets at least four times a year. The dates of the meetings are set by the Chairperson of the
Committee. In 2025, the Risk Committee held four meetings and one vote in writing. During the meetings, the Risk
Committee discussed periodic reports on:
• credit risk,
• integrated risks,
• market and liquidity risks, recovery plan metrics, risk appetite metrics, risks of investments undertaken as part of the
Investment Strategy, ESG risks,
• operational risk, internal control and fraud prevention,
• ALMT risks,
• legal risks,
• the current situation regarding the CHF mortgage portfolio.
In addition, the Committee gave opinions and recommended resolutions to the Supervisory Board, which included:
• risk appetite at BNP Paribas Bank Polska S.A.,
• BNP Paribas Bank Polska S.A.’s capital plan for 2026-2030,
• the BNP Paribas Bank Polska S.A. capital contingency plan,
• Capital Management Policy at BNP Paribas Bank Polska S.A.,
• operational risk management and internal control strategy at BNP Paribas Bank Polska S.A.,
• updated Rules of the Risk Committee,
• BNP Paribas Bank Polska S.A. Recovery Plan,
• Risk Management Strategy at BNP Paribas Bank Polska S.A.,
• Policies for the estimation of internal capital at BNP Paribas Bank Polska S.A.,
• Information on the implementation of the retail exposure management policy to the extent required under PFSA’s
Recommendation T,
• Information on the implementation of the mortgage-backed exposure management policy to the extent required under
PFSA’s Recommendation S,
• Information on the implementation of the concentration risk management policy to the extent required under PFSA’s
Recommendation C,
• Report on the Bank’s internal capital adequacy assessment process review (ICAAP),
• Report on the ILAAP review,
• Information on the effectiveness of risk model management,
• Review of the operational risk strategy for 2025 and assumptions of the operational risk strategy for 2026,
• Update of the Stress Test Programme Methodology and the Stress Test Result Report,
• Review of the Non-performing Exposure Management Policy and its requirements,
• Monitoring of the pricing policy,
• Information on the performance of outsourcing contracts.
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The Committee discussed the following matters:
• Geopolitical risk – ECB’s supervisory priorities,
• Information on the results of the PFSA inspection of concentration risk and unauthorised transactions: recommendations,
action plan, impact on SREP,
• Result of the review of the impact of customs (direct and indirect) on the loan portfolio,
• Information on the share of mortgage loan production with DTI above 35% at disbursement and during loan lifetime,
• Information on progress of the decarbonisation strategy and data collection and targets for emission reductions. Analysis
of 2-3 other banks’ greenhouse gas emissions and GAR compared to the Bank,
• Update on the benchmark reform,
• Information on NBI of the Equity Investment Office’s investment portfolio,
• Information on the status and action plan on low quality data,
• Information on data leak reporting to the Supervisory Board,
• RWA of the corporate and securities portfolios.
In 2025, the Committee paid particular attention to the following issues:
• legal risks in particular related to litigation concerning foreign currency/CHF denominated loans, the Bank’s activities as
depositary and the sanction of free credit and WIBOR,
• situation of the CHF mortgage portfolio and progress of voluntary settlements,
• risk of unauthorised transactions,
• ESG risks and the decarbonisation and emission reduction strategy for the Bank’s portfolio,
• concentration risk,
• impact of CRR3 on the Bank, capital requirements and RWAs.
The number of Committee members attending each Risk Committee meeting allowed all Committee meetings to run
properly in 2025. The attendance rate of the Committee members was 100%.
Remuneration Committee
The Remuneration Committee supports the Supervisory Board in its oversight responsibilities in the area of human
resources management. It monitors and supervises key processes, in particular with regard to human resources policy,
employee professional development and remuneration policy. The Committee’s remit includes, among others: analysing the
performance of the members of the Management Board and proposing recommendations to the Supervisory Board in this
regard, as well as recommending key performance indicators to the Supervisory Board for the members of the Management
Board. In addition, the Committee gives its opinion and monitors succession plans for key positions in the Bank, monitors
the level and structure of the remuneration of key position holders in the Bank. Each year, the Committee provides the
Supervisory Board with an update on the Bank’s employment and remuneration structure and an annual report on its
activities.
Composition of the Remuneration Committee
The Committee consists of at least three members appointed from among the members of the Supervisory Board.
Composition of the Remuneration Committee as at 31 December 2025:
• Lucyna Stańczak-Wuczyńska – Chairperson of the Committee (independent member)
• Francois Benaroya – Member of the Committee
• Małgorzata Chruściak – Member of the Committee (independent member)
Two members, including the Chairperson, meet the criteria for independence in accordance with the "Act on Statutory
Auditors, Audit Firms and Public Supervision".
Meetings of the Remuneration Committee
Meetings of the Remuneration Committee are held at least twice a year or as often as necessary for the effective fulfilment
of the Committee’s tasks and mission. The dates of the meetings are set by the Chairperson of the Committee. In 2025, the
Remuneration Committee held eight meetings, one of which was in writing.
During the meetings, the Committee discussed:
• annual objectives of the members of the Bank’s Management Board and the assessment of the achievement of these
objectives,
• principles for the remuneration and variable remuneration of the members of the Management Board and those in charge
of audit and compliance,
• the Bank’s employment and remuneration report for 2024,
• issued a recommendation on changes to the terms of remuneration of a Member of the Management Board,
• issued an opinion on the Report on the remuneration of the members of the Management Board and the Supervisory
Board of BNP Paribas Bank Polska S.A. for 2024,
• issued an opinion on the evaluation of the application of the Remuneration Policy at the Bank,
• issued an opinion on the pricing conditions for credit products to certain members of the Management Board,
• issued an opinion on the amendments to the Rules of the Remuneration Committee,
• discussed the Reports on the remuneration of the members of the Management Board and the Supervisory Board of BNP
Paribas Bank Polska S.A. for 2024,
• prepared and discussed the annual report on the Remuneration Committee’s activities for the Supervisory Board,
• issued an opinion on proposed amendments to the Policy on remuneration of Employees of BNP Paribas Bank Polska S.A.,
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• discusses the terms of the issue of series A6 subscription warrants issued under Resolution 5 of the Extraordinary General
Meeting of 31 January 2020 (as amended) and the terms of the issue of series B3 subscription warrants issued under
Resolution 39 of the Annual General Meeting of 27 June 2022.
Nominations Committee
The Nominations Committee supports the Supervisory Board in assessing the qualifications of candidates for members of
the Bank’s Management Board and Supervisory Board. Together with the Supervisory Board, the Nominations Committee
determines the criteria that are used to select members of the Management Board and Supervisory Board. The criteria take
into account: the knowledge, competence and expected commitment in terms of time commitment required to perform the
function. In addition, the Committee determines the responsibilities of candidates for the Bank’s Management Board. The
Nominations Committee periodically assesses the knowledge, competence and experience of the Bank’s Management Board
as a whole and of the individual members of the Bank’s Management Board at least once a year. It also evaluates the
structure, size, composition and effectiveness of the Bank’s Management Board and then makes recommendations to the
Supervisory Board for any changes in this respect. In addition, the Nominations Committee makes an individual assessment
of the suitability (initial and periodic) of the members of the Supervisory Board and a collective assessment of the
suitability of the Supervisory Board as a whole. The assessment of individual and collective suitability is performed at least
once a year and in situations indicated in the Policy of the Bank for the Assessment of Suitability of the Members of the
Supervisory Board of BNP Paribas Bank Polska S.A., including, among others, in the event of a nomination of candidates for
Supervisory Board members (prior to the appointment of a given person to perform a given function), in the event of
changes in the composition of the Supervisory Board or a material change in the Bank’s business model.
The Nominations Committee reviews and monitors the effectiveness of the Bank’s Suitability Assessment Policy for
members of the Supervisory Board and the Suitability Assessment Policy for members of the Management Board and
employees holding key functions at the Bank. The Nominations Committee periodically reviews the policy and makes
recommendations for changes to the Supervisory Board. In addition, the Committee oversees key processes such as
succession plans, the policy for the appointment and removal of members of the Management Board and members of the
Supervisory Board, and the professional development of employees. It makes recommendations to the Supervisory Board on
the appointment and succession process for key position holders and recommendations to reduce or increase the number
of members of the Bank’s Management Board.
Composition of the Nominations Committee
The Nominations Committee consists of at least three persons appointed from among the members of the Supervisory
Board. The members of the Nominations Committee must have the necessary knowledge, competence and experience to be
able to properly assess the composition of the Management Board and the Supervisory Board and the recommended
candidates for the Management Board and the Supervisory Board. As part of the suitability assessment, which is carried out
on a cyclical basis once a year or in the event of other circumstances resulting in the need for an assessment, an
assessment of their knowledge, skills and professional experience (including in ESG risk management) is carried out. A
detailed criteria matrix is attached as an appendix to the Suitability Assessment Policy for the members of the Supervisory
Board of BNP Paribas Bank Polska SA.
Composition of the Nominations Committee as at 31 December 2025:
• Lucyna Stańczak-Wuczyńska – Chairperson of the Committee (independent member)
• Francois Benaroya – Member of the Committee
• Małgorzata Chruściak – Member of the Committee (independent member)
Two members, including the Chairperson, meet the criteria for independence in accordance with the "Act on Statutory
Auditors, Audit Firms and Public Supervision".
Meetings of the Nominations Committee
Meetings of the Committee are held as often as necessary for the effective fulfilment of the Committee’s mission, but at
least twice a year. The dates of the meetings are set by the Chairperson of the Nominations Committee. In 2025, the
Nominations Committee held eight meetings, including four meetings in writing.
During the meetings, the Committee:
• carried out a periodic assessment of the individual and collective suitability of the members of the Supervisory Board and
the members of the Bank’s Management Board. The Committee confirmed positive assessments of the individual
suitability as well as the collective suitability of the members of the Management Board and the Supervisory Board,
• carried out an assessment of the individual suitability of a candidate for Supervisory Board member of BNP Paribas Bank
Polska S.A. and an additional assessment of the collective suitability of the Supervisory Board of the Bank in the new
composition,
• carried out an assessment of the individual suitability of candidates for Supervisory Board committees and an additional
assessment of the collective suitability of the committees,
• prepared and discussed the annual report on the activities of the Nominations Committee for the Supervisory Board,
• carried out a periodic assessment of the individual and collective suitability of the members of the Management Board of
BNP Paribas Bank Polska S.A. and a periodic assessment of the individual and collective suitability of the members of the
Supervisory Board of BNP Paribas Bank Polska S.A.,
• carried out an assessment of the individual suitability of a candidate for Vice-President of the Management Board of the
Bank and an additional assessment of the collective suitability of the Management Board of BNP Paribas Bank Polska S.A.,
• issued an opinion on the appointment of a candidate for Managing Director of the Internal Audit Division,
• issued an opinion on the discharge of duties to the members of the Management Board of the Bank for the financial year
ended 31 December 2024.
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Management Board of the Bank
Principles of operation of the Management Board
The Bank’s Management Board is the management and executive body that operates on the basis of applicable laws, the
Bank’s Articles of Association and the Rules of the Management Board. As of 1 January 2020, the Bank’s Management Board
has nine members and this is in accordance with the Bank’s Articles of Association. The Supervisory Board decided on 7
December 2023 to set the number of members of the Management Board at eight as of 1 January 2024. The members of the
Management Board – President and Vice-Presidents – are appointed by the Supervisory Board for a joint term of office of
three years. The mandate of the members of the Management Board expires at the end of their term of office, on the date
of the General Meeting approving the financial statements for the last full financial year in which they served as members
of the Management Board. In addition, the Supervisory Board, acting on the basis of the "Policy for the Appointment and
Dismissal of Management Board Members", may dismiss or suspend a Management Board member at any time. The
members of the Management Board must have the knowledge and experience to manage the Bank in a stable and prudent
manner. At least half of the members of the Bank’s Management Board must be persons well acquainted with the banking
market in Poland, i.e. live in Poland permanently, speak Polish and have experience on the Polish market.
The Management Board deals with all matters of the Bank which are not reserved by law and which do not fall within the
competence of other bodies of the Bank. A detailed description of the activities, including the scope of competences of the
Management Board, is set out in § 22(2) of the Bank’s Articles of Association and in the Rules of the Bank’s Management
Board.
List of the most important matters dealt with by the Management Board:
• prepares a draft strategy for the management of the Bank and presents it to the Supervisory Board for approval and
monitors the implementation of the strategy,
• prepares the financial plan and adopts reports on its implementation,
• adopts the reports on the Bank’s activities, the Bank’s financial statements and the Group’s activity reports and
consolidated financial statements,
• defines human resources policy, in particular remuneration rules, structure and profile of employment, social policy rules,
• defines the Bank’s product policy,
• determines the organisational structure of the Bank,
• identifies the areas of management overseen by individual Management Board members,
• establishes a policy for the identification of key functions and the appointment and removal of key function holders,
• sets out ethical principles defining norms and standards of ethical conduct for members of the Bank’s bodies and
employees, as well as for other persons through whom the Bank conducts its business,
• establishes and abolishes the Bank’s committees and determines their respective competences,
• appoints proxies,
• establishes rules for the operation of internal control and internal audit,
• establishes a risk management strategy including policies and procedures for identifying, assessing, controlling and
monitoring risks and reporting on risks,
• decides on the purchase or sale of real estate, a share in real estate or the right of perpetual usufruct, if their value is
lower than PLN 10,000,000 (ten million) but higher than PLN 5,000,000 (five million); however, a resolution of the
Management Board is not required if the purchase or sale of real estate, a share in real estate or the right of perpetual
usufruct is related to the satisfaction of the Bank’s claims against its debtor, securing the Bank’s receivables or a leasing
agreement in which the Bank acts as the financing party, including in particular in the case of acquisition in fulfilment of
the leasing agreement, disposal after the expiry of the leasing term or during the leasing term and disposal after
termination of the leasing agreement concerning a given real property, a share in a real property or the right of perpetual
usufruct, regardless of the value of the real property, the share in a real property or the right of perpetual usufruct,
• decides on the incurrence of a liability or disposition of a right, the aggregate value of which in relation to one entity
exceeds 5% of own funds.
In 2025, in addition to the aforementioned topics, the Bank’s Management Board focused its attention and work on issues
relating to the CHF mortgage portfolio, unauthorised transactions, the change from the WIBOR to the WIRON benchmark,
ESG risk and its impact on the Bank’s business, issues relating to the Cybersecurity area, operational efficiency and issues
relating to ethics and standards of conduct.
The Bank’s Management Board manages the Bank’s affairs and represents the Bank externally. The Bank’s Articles of
Association specify how the Management Board represents the Bank. Pursuant to § 26 of the Bank’s Articles of Association,
declarations of intent on behalf of the Bank may be made by:
• two members of the Management Board who act jointly or one member of the Management Board who acts jointly with a
proxy or attorney acting within the limits of the power of attorney granted,
• two proxies acting jointly,
• attorneys acting alone or jointly within the limits of the powers granted.
Decisions of the Management Board take the form of resolutions and are adopted by an absolute majority of votes cast in
the presence of at least half of the members of the Management Board. Meetings of the Management Board are normally
held once a week or more frequently as required.
The members of the Management Board meet for Management Board meetings at the Bank’s Head Office and also take
decisions by means of direct remote communication.
Management Board meetings in 2025 were held in a hybrid model. The Management Board in 2025 held 63 meetings,
including 8 written votes. The Management Board members passed 151 resolutions.
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Table 144. Composition of the Bank’s Management Board, together with the division of the functional responsibilities of
the individual members, as at 31 December 2025 and as at 31 December 2024
name
function on the
Bank’s Management
Board
supervised area
Przemysław Gdański
CEO
Bank Management, Strategy and Agricultural Markets, Human Resources
Management, Transformation, Sustainability
André Boulanger
Vice-President
CIB
Małgorzata Dąbrowska
Vice-President
Operations and Business Support
Wojciech Kembłowski
Vice-President
Risk
Piotr Konieczny
Vice-President
Finance
Magdalena Nowicka
Vice-President
New Technologies and Cybersecurity
Volodymyr Radin
Vice-President
Personal Finance (PF)
Retail and Business Banking
Agnieszka Wolska
Vice-President
SME and Corporate Banking
The competences and professional experience of the individual members of the Bank’s Management Board are presented
on the Bank’s website at https://www.bnpparibas.pl/o-banku/wladze-banku.
The composition of the Management Board is appropriate in terms of numbers to the structure and area of the Bank’s
activities and complies with the suitability criteria, both individually and as a whole body, which contributes to the effective
management of the Bank.
The appointment of a member of the Management Board is possible if the candidate meets the statutory and regulatory
requirements and has received a positive suitability assessment. In the process of recruiting a candidate for the position of
a member of the Bank’s Management Board, the Supervisory Board is assisted by the Nominations Committee and the
Executive Director of the Human Resources Area. Appointment as a member of the Management Board by the Supervisory
Board is preceded by:
• carrying out the suitability assessment process,
• receiving a recommendation from the Nominations Committee.
Changes to the composition of the Bank’s Management Board in 2025 and after the reporting period:
• on 21 October 2025, Mr Andre Boulanger resigned as Vice-President of the Bank’s Management Board, Head of Corporate
and Institutional Banking (CIB) as of 31 December 2025,
• on 10 December 2025, Ms Natalie Yacoubian was appointed Vice-President of the Bank’s Management Board, Head of
Corporate and Institutional Banking (CIB) as of 1 January 2026,
• on 2 January 2026, Ms Agnieszka Wolska resigned as Vice-President of the Bank’s Management Board as of 2 January
2026.
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Members of the Bank’s Management Board
1. Przemysław Gdański – President of the Management Board
Graduate of the Faculty of Foreign Trade at the University of Gdansk and a one-year programme in
international banking and finance at Loughborough University, UK. He completed the Advanced
Management Program (AMP) at IESE Business School and a number of professional and managerial
development programs at Harvard Business School, London Business School, University of California,
Berkeley – Haas School of Business, Ashridge – Hult International Business School and HEC, among others. He has been
involved in banking for over 28 years. From 1993 to 1995, he worked at IBP Bank SA, then at ABN AMRO Bank in Poland,
Romania and the head office in Amsterdam. From 2002 to 2006, he was managing director, heading the Large Companies
Area at Bank BPH SA. From May to November 2006, CEO and General Manager of Calyon Bank Poland and Calyon Branch in
Poland. In November 2006, he became Vice-President of the Management Board of Bank BPH, where he was responsible for
corporate banking and real estate financing. Subsequently, he was Vice-President of the Management Board of Pekao SA,
responsible for the Corporate Banking, Markets and Investment Banking Division. From 2008 to 2017, he was a member of
the Management Board and Vice-President of mBank, where he was responsible for the Corporate and Investment Banking
Division. Since November 2017, he has been in charge of BNP Paribas Bank Polska S.A. and serves as Territory Head
overseeing BNP Paribas Group companies operating in Poland. She has been a long-time patron of initiatives to promote
diversity, gender equality and to support the activities and promote the professional development of women. In 2018, he
received the special award Male Champion of Change of the Fundacja Sukcesu Pisanego Szminką. He supervises
Sustainability in the Bank.
2. André Boulanger – Vice-President of the Management Board
He graduated with honours from the Université Libre de Bruxelles in Belgium. He started his career in
1986 at Crédit Communal de Belgique (now Belfius Bank), where he worked until 1989. He then became
branch manager of Banque Paribas Belgium in Brussels and later deputy head of the Risk Department at
Banque Paribas Belgium. From 1994 to 1998, he was vice-president of Banque Paribas France, where he
was responsible for commercial banking in the European subsidiaries. From 1998 to 2000, he was managing director of the
Corporate Banking Area at Banque Paribas Belgium. Following the merger of BNP and Paribas in 2000, he became Managing
Director of the Corporate and Investment Banking Area. From 2002, he continued his career at BNP Paribas in France as
managing director of the Acquisition Finance Transactions and Structured Loans Area in the Continental Europe region. In
2005, he became Managing Director of the Corporate Banking Area in Central and Eastern Europe at BNP Paribas in France
and, in 2007, General Manager of the Corporate and Transaction Banking Area. From 2010 to 2014, he became CEO and
Chairperson of the Board at BNP Paribas in the Netherlands. In 2014, he became Managing Director of the Corporate
Banking Operations Area in the Europe region and, in 2015, Managing Director of the EMEA Operations Area. Since 2017, he
was CEO of BNP Paribas JSC and CEO for the Russian Federation area. Since November 2018, he has been Vice-President of
the Management Board of BNP Paribas Bank Polska S.A. responsible for the CIB Area.
3. Małgorzata Dąbrowska – Vice-President of the Management Board
Graduate of the Cracow University of Economics and Executive MBA studies at ESCP Business School in
Paris. She completed a number of specialised training and development programmes certified by foreign
universities – HEC, The University of Texas at Austin, George Washington University. She is an experienced
leader who has successfully implemented complex organisational and technological transformations
including in the process of bank mergers. She has more than 25 years of experience in the banking sector in the areas of
operations, finance, business support, technology and transformation. She started her professional career at Pierwszy
Polsko-Amerykański Bank SA, which was acquired by BNP Paribas in 2010 after successive mergers with Fortis Bank and
Dominet Bank. Her roles included Director of the Project Management Department, Director of IT Programmes, Director of
the Business IT Systems Development Department. During the operational merger of BGŻ BNP Paribas, she was director of
the Systems Migration Department. From 2018 to 2021, she was Managing Director of IT Systems Development for Retail
Customers. In January 2022, she took on the role of Open & Beyond Banking Tribe Leader, and additionally served as
Candidate and Employee Experience Tribe Leader from December 2022 to April 2023. Since 1 January 2024, she has been
Vice-President of the Management Board of BNP Paribas Bank Polska S.A. overseeing the Operations and Business Support
Area. Se completed the Cambridge Senior Executive Programme Mastering Sustainable Finance and a number of additional
training courses related to sustainability.
4. Wojciech Kembłowski – Vice-President of the Management Board
Graduated in economics from the Faculty of Finance and Statistics at the Warsaw School of Economics. He
completed management trainings organised among others by Harvard Business School and executive
trainings prepared by Raiffeisen Bank International AG. At the beginning of his professional career, from
1993 to 1997, he was affiliated with CSBI in the Sygnity group, where he was an analysis manager in the
Financial Department. Subsequently, he worked at Raiffeisen Bank Poland, initially from 1997 to 2000 as a financial analyst
and account manager, and then from 2000 to 2003 as a manager of Risk Management. From 2003 to 2008, he was director
of the Credit Risk Department of Raiffeisen Bank Polska, where he was responsible for the corporate area – corporates and
medium-sized enterprises, financial institutions. From 2008 to 2011, he was director and then managing director of the Credit
Risk Area at Raiffeisen Bank Polska. Since 2011, he was associated with BNP Paribas Bank Polska, where he became a member
of the Management Board and Managing Director of the Risk Area (Chief Risk Officer). Since May 2015, he has been Vice-
President of the Management Board of BNP Paribas Bank Polska S.A. and is responsible for the Risk Area.
Top management makes every effort to broaden its range of
competences in the areas of sustainability, climate change and
climate policy at advanced international training courses (e.g.
Cambridge Institute for Sustainability Leadership) and meetings with
recognised experts and researchers. CEO Przemysław Gdański
graduated in 2021 from the IESE Business School in Madrid in
Sustainability.
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5. Piotr Konieczny – Vice-President of the Management Board
Graduated from the Faculty of Banking and Finance at the University of Szczecin, where he obtained a
Master’s degree in Economics. Subsequently, he obtained a PhD in Banking and Finance at the Warsaw
School of Economics. During his career he has attended numerous courses in management, leadership
and sustainability. He has over 30 years of business experience in risk and finance functions. At the
beginning of his career, he was affiliated with the Department of Econometrics and Statistics at the University of Szczecin.
From 1995 to 1997, he was a market risk controller in the Treasury Department of PBKS S.A., part of the Pekao S.A. Group.
From 1997, he was affiliated with Raiffeisen Bank Polska S.A., holding successive positions as balance sheet risk manager,
director of the Asset and Liability Management Office, managing director of the Risk Management Department. In 2007, he
took up the position of Member of the Management Board responsible for the Risk and Finance Areas (Chief Risk
Officer/Chief Financial Officer), and from 2012, he was Member of the Management Board responsible for Finance (CFO). He
was also a member of the Supervisory Boards of Raiffeisen Towarzystwo Funduszy Inwestycyjnych S.A. and Raiffeisen
Leasing Polska S.A. He continued his career at BNP Paribas Group S.A. as advisor to CFO at BNP Paribas Bank Polska S.A. (in
2018-2019), and from 2019 as a member of the Management Board of Ukrsibbank supervising the Finance Area (CFO).
Since 1 September 2023, he has been Vice-President of the Management Board of BNP Paribas Bank Polska S.A. supervising
the Finance Area which coordinates the preparation of sustainability reporting as of 2024.
6. Magdalena Nowicka – Vice-President of the Management Board
Graduate of the Faculty of Mathematics at the Maria Curie-Skłodowska University in Lublin and MBA
studies at the Warsaw University of Technology. She also completed postgraduate studies in management
and "Information Technology in Business" at the Warsaw School of Economics. For 20 years, she was
affiliated with the ING Group. She started her career at ING Barings in 1997 and then worked in the IT
Division of ING Bank Śląski. She was director of the IT Support Department. From 2006 to 2016, she was president of the
management board of ING Services Polska. At that time, she built ING Tech Poland, ING Group’s technology centre,
providing IT services, including cybersecurity and cloud solutions, to customers in more than 20 countries. In 2017, she
joined Nordea, where she worked as Head of IT Poland. Among other things, she took part in the creation of the Nordea
Horizon Center, a state-of-the-art IT monitoring and operations centre. Subsequently, as Global Head of Technology
Sourcing, she was responsible for implementing the strategy for the use of global IT service centres. Since January 2021,
she has been Vice-President of the Management Board of BNP Paribas Bank Polska S.A. and oversees the New Technologies
and Cybersecurity Area. Magdalena Nowicka is actively involved in projects supporting the development of women in the
world of new technologies. She is a mentor of the “Technologia w spódnicy” programme.
7. Volodymyr Radin – Vice-President of the Management Board
Graduate of the Ukrainian Academy of Banking of the National Bank of Ukraine. In addition, he completed
marketing studies at HEC in Paris and studies in management leadership at the Ukrainian Academy of
Corporate Governance. He has been involved in banking for over 18 years. From 2002 to 2003, he worked
at Bank Aval (Raiffeisen Bank Aval) as Director of the Consumer Finance Department. From 2003 to 2007,
he was Director of the Retail Banking Business Line at Universal Development and Partnership Bank (Foxtrot Group) and
then Deputy Director of the Retail Banking Business Line and Director of Product Management at Kreditprombank from
2007 to 2008. In 2008, he joined the BNP Paribas Group as Sales and Marketing Director and Deputy Director of the
Personal Finance Business Line at Ukrsibbank (BNP Paribas Group). In 2014, he became Director of the Personal Finance
business line and a member of Ukrsibbank’s Board of Directors, and later Vice-Chairperson of the Board of Directors. During
his more than 18 years of professional work in financial institutions, he was involved in numerous projects on the creation,
transformation or comprehensive modernisation of retail banking operations: consumer loans, credit cards, vehicle
financing, mortgages, payments, savings products, debt enforcement, call centre. A degree in finance underpinned his high-
level skills acquired in many areas of banking, such as sales and marketing, financial planning and budgeting, operational
and credit risk management, market analysis, and customer satisfaction management. As of October 2019, he is Vice-
President of the Management Board of BNP Paribas Bank Polska S.A. overseeing the Personal Finance Banking Area. Since 1
January 2024, he also supervises the Retail and Business Banking Area. W związku z rezygnacją złożoną przez wiceprezes
Zarządu – Panią Agnieszkę Wolską – objął również nadzór nad Obszarem Bankowości MŚP i Korporacyjnej. Following the
resignation of Agnieszka Wolska as Vice-President of the Management Board, he also supervises SME and Corporate
Banking.
8. Agnieszka Wolska – Vice-President of the Management Board
Graduated in finance and banking from the Warsaw School of Economics. She has over 20 years of
experience in international listed banks. She started her career in 2003 at Bank BPH in the Structured
Finance Department. In 2006, she became deputy director of the Structured Finance Department. In 2007,
she joined Bank Pekao, where she became deputy director of the Complex Enterprise Solutions Office, and
in 2010, head of the TMT Office. In 2014, she became Director of the Large Enterprises Department at Santander Bank
Polska, then in 2016 she became Director of the Corporate Banking Area, thus joining the ranks of top managers at
Santander Bank Polska who make up the operations management team in Poland. In 2018, she became Director of the
Business Banking and Corporate Banking Area at Santander Bank Polska. During her career, she has attended numerous
courses in finance, management and leadership. She completed the educational programme Sustainability Academy of the
BNP Paribas Group; BNP Paribas’ Sustainable Finance Solutions, Future of ESG. From September 2021 to 2 January 2026,
she was Vice-President of the Management Board of BNP Paribas Bank Polska S.A. and oversaw the SME and Corporate
Banking Area.
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Remuneration of the Management Board and the Supervisory Board
Pursuant to the Remuneration Policy for the members of the Bank’s Supervisory Board, the members of the Supervisory
Board receive only fixed remuneration and its level is set by the Bank’s General Meeting. The General Meeting adopts the
Remuneration Policy in place at the Bank and is responsible for setting the remuneration for the members of the
Supervisory Board (the level of remuneration is approved by a resolution of the General Meeting). At the meeting adopting
the Remuneration Policy, shareholders may submit their comments and opinions for inclusion in the final document. The
Bank does not engage external remuneration consultants.
Pursuant to the Remuneration Policy for Persons with a Significant Impact on the Risk Profile of BNP Paribas Bank Polska
S.A.:
• the remuneration paid to persons with a significant impact on the Bank’s risk profile is adequate, i.e. it reflects their
contribution to the achievement of the Bank’s objectives, their workload and the best market practice of rewarding
persons in similar positions, as adopted on the Polish market, and it takes into account the appropriate ratio of fixed
remuneration to variable remuneration;
• it is possible to award variable remuneration paid on a one-off basis when recruiting individuals to positions identified as
having a significant impact on the Bank’s risk profile (in the first year of employment) where the Bank has a sound and
solid capital base and which is limited to the first year of employment (sign-on bonus);
• severance payments and benefits of a similar nature, insofar as they are paid in an amount resulting from applicable laws
or from a final court judgment or a settlement concluded before the court, are not subject to the principles of deferral and
split as remuneration in the form of shares of the Bank.
Given the Bank’s commitment to the environment to date, as well as the Bank’s efforts to implement the principles of
social responsibility, the Bank ensures that the Remuneration Policy is consistent with the strategy for integrating
sustainability risks into the Bank’s activities. The Remuneration rues do not encourage persons with a significant impact on
the Bank’s risk profile to take excessive risks with regard to sustainability risks and are linked to risk-adjusted performance.
Under the applicable Labour Code, no clawback mechanism is used at the Bank.
The General Meeting adopts the Remuneration Policy for the members of the Supervisory Board of BNP Paribas Bank Polska
S.A. and the Remuneration Policy for persons with a significant impact on the risk profile of BNP Paribas Bank Polska S.A.
(including members of the Bank’s Management Board).
The Bank has a Remuneration Committee whose remit includes:
• monitoring the level and structure of remuneration for persons employed as members of the Bank’s Management Board,
• determining the content of contracts for the performance of the function of a member of the Bank’s Management Board,
• submitting annual information to the Supervisory Board on the Bank’s employment and remuneration structure,
• exploring the possibility of hiring external remuneration consultants whose duties may include providing advice and
support to the Supervisory Board.
The remuneration paid to individual members of the Management Board during the year is as follows:
Table 145. Remuneration paid to members of the Management Board in 2025
PLN’000
Period in office
Basic
salary
Variable
remuneration
paid in the
year
Issued
shares
2
Additional
benefits
Total
1
Name
from
to
Przemysław Gdański
01.01.2025
31.12.2025
3,070
679
669
185
4,603
André Boulanger
01.01.2025
31.12.2025
1,262
453
490
213
2,418
Małgorzata Dąbrowska
01.01.2025
31.12.2025
964
120
0
129
1,213
Wojciech Kembłowski
01.01.2025
31.12.2025
1,490
323
327
144
2,284
Piotr Konieczny
01.01.2025
31.12.2025
1,218
239
47
124
1,628
Magdalena Nowicka
01.01.2025
31.12.2025
1,345
234
219
166
1,964
Volodymyr Radin
01.01.2025
31.12.2025
1,465
218
119
106
1,908
Agnieszka Wolska
01.01.2025
31.12.2025
1,394
263
225
142
2,024
Total
12,208
2,529
2,096
1,209
18,042
1 remuneration and benefits paid to members of the Management Board for the period of their service on the Management Board
2 value of shares determined based on the fair value in accordance with IFRS 2
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Table 146. Remuneration paid to members of the Management Board in 2024
PLN’000
Period in office
Basic
salary
Variable
remuneration
paid in the
year
Issued
shares
2
Additional
benefits
Total
1
Name
from
to
Przemysław Gdański
01.01.2024
31.12.2024
2,959
987
688
173
4,807
André Boulanger
01.01.2024
31.12.2024
1,277
522
425
170
2,394
Małgorzata Dąbrowska
01.01.2024
31.12.2024
840
263
-
115
1,218
Wojciech Kembłowski
01.01.2024
31.12.2024
1,426
397
295
131
2,249
Piotr Konieczny
01.01.2024
31.12.2024
1,190
86
-
90
1,366
Magdalena Nowicka
01.01.2024
31.12.2024
1,306
210
168
33
1,717
Volodymyr Radin
01.01.2024
31.12.2024
1,440
200
103
37
1,780
Agnieszka Wolska
01.01.2024
31.12.2024
1,328
217
176
126
1,847
Total
11,766
2,882
1,855
875
17,378
1 remuneration and benefits paid to members of the Management Board for the period of their service on the Management Board
2 value of shares determined based on the fair value in accordance with IFRS 2
The members of the Management Board entered into employment agreements with BNP Paribas Bank Polska S.A. for an
indefinite period of time. The terms and conditions of the agreements were prepared in accordance with the currently
applicable laws and internal regulations. Furthermore, the members of the Management Board signed non-competition
agreements applicable during their employment relationship with BNP Paribas Bank Polska S.A. In addition, two members
of the Management Board are prohibited from competing for 9 months after the termination of their employment
relationship. The members of the Bank’s Management Board do not receive any remuneration on account of their functions
in the authorities of subsidiaries of the BNP Paribas Bank Polska S.A. Group.
In accordance with their individual employment agreements, members of the Management Board are entitled to life
insurance and a medical care package. In addition, fringe benefits to which members of the Management Board are entitled
(based on individual employment agreements) include:
• housing allowance specified in the employment agreement,
• coverage or reimbursement of costs incurred in connection with the posting in Poland,
• covering the costs of private travel to the posting country for the Management Board member and family members living
in Poland (at a specified frequency),
• covering the costs of children’s schooling in Poland,
• a one-off allowance related to a change of workplace.
• BNP Paribas Bank Polska S.A. does not have any pension or benefit obligations of a similar nature towards its former
management and supervisory personnel.
Remuneration paid to individual members of the Supervisory Board during the year is presented in the tables below:
Table 147. Remuneration paid to members of the Supervisory Board in 2025
PLN’000
Period in office
Remuneration for work
in the Supervisory
Board
1
Deferred variable remuneration due
to previous membership in the
Management Board
Name
od
do
Cash part
Issued
shares
2
Lucyna Stańczak-Wuczyńska
01.01.2025
31.12.2025
590
-
-
François Benaroya
01.01.2025
31.12.2025
-
-
-
Jean-Charles Aranda
01.01.2025
31.12.2025
-
49
148
Małgorzata Chruściak
01.01.2025
31.12.2025
296
-
-
Sophie Heller
01.01.2025
31.12.2025
-
-
-
Monika Kaczorek
01.01.2025
31.12.2025
309
-
-
Bożena Leśniewska
15.04.2025
31.12.2025
120
-
-
Vincent Metz
01.01.2025
31.12.2025
-
-
-
Piotr Mietkowski
01.01.2025
31.12.2025
-
-
-
Khatleen Pauwels
01.01.2025
31.12.2025
-
-
-
Jacques Rinino
01.01.2025
31.12.2025
284
-
-
Mariusz Warych
01.01.2025
31.12.2025
372
-
-
Total
1,971
49
148
1 applies only to remuneration for work in the Supervisory Board
2 value of shares determined based on the fair value in accordance with IFRS 2
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Table 148. Remuneration paid to members of the Supervisory Board in 2024
PLN’000
Period in office
Remuneration for work
in the Supervisory
Board
1
Cash part
Deferred variable remuneration due
to previous membership in the
Management Board
Name
from
to
Cash part
Issued
shares
2
Lucyna Stańczak-Wuczyńska
01.01.2024
31.12.2024
548
-
-
François Benaroya
01.01.2024
31.12.2024
-
-
-
Jean-Charles Aranda
01.01.2024
31.12.2024
-
223
234
Jarosław Bauc
01.01.2024
02.07.2024
135
-
-
Małgorzata Chruściak
01.01.2024
31.12.2024
233
-
-
Magdalena Dziewguć
01.01.2024
21.11.2024
223
-
-
Sophie Heller
01.01.2024
31.12.2024
-
-
-
Monika Kaczorek
03.07.2024
31.12.2024
97
-
-
Vincent Metz
01.01.2024
31.12.2024
-
-
-
Piotr Mietkowski
01.01.2024
31.12.2024
-
-
-
Khatleen Pauwels
01.01.2024
31.12.2024
-
-
-
Jacques Rinino
01.01.2024
31.12.2024
214
-
-
Mariusz Warych
01.01.2024
31.12.2024
382
-
-
Total
1,832
223
234
1 applies only to remuneration for work in the Supervisory Board
2 value of shares determined based on the fair value in accordance with IFRS 2
Information on the remuneration of the members of the Bank’s Management Board and Supervisory Board can also be
found in Note 52 Related Party Transactions in the Separate Financial Statements of BNP Paribas Bank Polska S.A. for the
year ended 31 December 2025.
On 24 August 2018, the Extraordinary General Meeting adopted a resolution under which a member of the Supervisory
Board who is concurrently employed in any entity within the BNP Paribas SA Group or in any subsidiary of any entity within
the BNP Paribas SA Group is not entitled to remuneration on account of being a member of the Supervisory Board of BNP
Paribas Bank Polska S.A.
Diversity policy
Diversity policy for supervisory, management and administrative bodies
The Bank has a diversity policy with respect to the members of the Supervisory Board, which formally forms part of the
Policy for assessing the suitability of the members of the Supervisory Board of BNP Paribas Bank Polska S.A., and a diversity
policy with respect to the members of the Management Board, which formally forms part of the Policy for assessing the
suitability of the members of the Management Board and key function holders at BNP Paribas Bank Polska S.A.
The diversity policies for members of the Management Board and the Supervisory Board are designed to ensure a wide
range of qualities and competences when appointing members of the Supervisory Board and the Management Board in
order to attract different viewpoints and experiences and to enable independent opinions and sound decisions to be made
within the body, thereby ensuring that the management and supervisory bodies carry out their tasks to a high standard.
Members of the Management Board are appointed by the Supervisory Board in an open vote, taking into account the
provisions of the Bank’s Articles of Association and taking into account the results of the suitability assessment carried out
in accordance with the Suitability Assessment Policy. The individual suitability assessment is carried out taking into
account the following criteria:
• knowledge, skills and professional experience covering:
significant areas of the Bank’s business and the main risks associated with that business, including ESG and ML/FT
risks that may arise from the Bank’s activities or those of its customers and counterparties,
significant areas of sector/financial expertise, including financial and capital markets, solvency and models,
management and strategic planning skills and experience,
information technology and cybersecurity,
local and regional markets,
financial accounting and reporting,
legal and regulatory environment,
management of national groups and the risks associated with the structures of such groups;
risk management, including ESG and ML/FT risks, as well as management of risks of non-compliance with generally
applicable or internal laws and internal audit recommendations;
• with regard to the warranty of the proper performance of the function entrusted, taking into account among others:
reputation,
financial situation,
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criminal record,
capacity for independent judgement, taking into account personal competences (behavioural requirements);
the existence of a possible conflict of interest;
• in terms of devoting sufficient time to the performance of the function entrusted, taking into account:
the number of other activities or functions performed simultaneously,
the actual participation of that person in the work of the Management Board.
The Bank aims to ensure sufficient diversity in the composition of the Management Board in terms of the following criteria:
• gender,
• age,
• geographical origin,
• educational direction, work experience and seniority,
• skills or expertise.
In terms of substantive criteria, the Diversity Strategy ensures the selection of individuals with a diversity of knowledge,
skills and experience, appropriate to their roles and responsibilities, which complement each other across the Supervisory
Board and the Management Board. These criteria are reviewed through the suitability assessment process described in the
aforementioned Suitability Assessment Policies. Furthermore, diversity encompasses and exploits to best effect the
differences that, in addition to knowledge, competence and professional experience, arise from gender, age and
geographical origin.
The Bank attaches a very high priority to the real implementation of diversity, including ensuring adequate representation
of women in the Bank’s bodies. Under the GObeyond strategy, the Bank decided to ensure that by 2025 it will have 30%
women on the Management Board and maintain the proportion of the underrepresented gender on the Supervisory Board
at a minimum of 30% of its composition.
As at 31 December 2025, the proportion of women on the Supervisory Board was 50.0%, while the proportion of women on
the Bank’s Management Board was 37.5%.
The table below shows the current diversity in terms of gender, age and length of service at the Bank of members of the
Supervisory Board, the Bank’s Management Board and key managerial positions.
Table 149. Gender, age and tenure diversity at the Bank as at 31 December 2025*
Gender
Women
Men
Supervisory Board
6
6
12
Management Board
3
5
8
Top management (B1+B2)
145
184
329
Total
154
195
349
Age
<30 years
30-50 years
>50 years
Total
Supervisory Board
0
0
12
12
Management Board
0
2
6
8
Top management (B1+B2)
1
224
105
329
Total
1
226
123
349
Seniority at the Bank (years)
<5
5-10
10-15
15-20
20-25
>25
Total
Supervisory Board
8
2
2
0
0
0
12
Management Board
2
4
1
0
1
0
8
Top management (B1+B2)
75
54
52
67
45
36
329
Total
85
60
55
67
46
36
349
* figures present the Bank’s active employees as at 31 December 2025
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Internal control system (including control and risk management system for the preparation of financial reports)
The internal control system at BNP Paribas Bank Polska operates in line with the requirements of the Polish supervisory
authorities and is aligned with the internal control rules in place at the BNP Paribas Group. The Bank has and develops an
internal control system adapted to its organisational structure, which includes the Bank’s organisational units and core
business units and the Bank’s subsidiaries.
The purpose of conducting internal control is to effectively control risks, including the prevention or early detection of risks.
The role of the internal control system is to achieve the general and specific objectives of the internal control system,
which should be taken into account at the stage of designing control mechanisms. The principles of the internal control
system are set out in the document "Internal Control Policy at BNP Paribas Bank Polska S.A.", approved by the Bank’s
Management Board. The document sets out the main principles, organisational framework and standards for the operation
of the control environment at the Bank, in compliance with the requirements of the Polish Financial Supervision Authority
set out in Recommendation H and the Regulation of the Minister of Finance, Funds and Regional Policy of 8 June 2021 on
the risk management system and internal control system and remuneration policy in banks. Detailed internal regulations
relating to specific areas of the Bank’s operations are adapted to the specific nature of the Bank’s business. The
development of detailed regulations relating to the area of internal control is the responsibility of the relevant
organisational units of the Bank, in accordance with the scope of tasks assigned to them.
The Bank’s internal control system is based on the three lines of defence model, consisting of:
• first line of defence (1LoD):
− constituted by the owners of risk, exercised by managing that risk and ensuring that the controls in the area of
delegated responsibility operate effectively and in accordance with the law;
− responsible for compliance with the rules arising from approved policies, regulations, instructions and procedures;
− responsible for the design, implementation and application of controls designed to ensure that the general and
specific objectives of the internal control system are achieved and for independent monitoring of compliance with
the controls in the form of ongoing verification and/or horizontal testing.
• second line of defence (2LoD):
− responsible for managing individual risks independently of risk management on the first line of defence, taking into
account the requirements set by the supervisory authorities, business needs, including the risk appetite adopted by
the Bank;
− responsible for monitoring compliance with second line of defence controls in the processes it manages in the form
of ongoing verification and/or horizontal testing;
− performs the tasks arising from the second line of defence control function in accordance with the internally
adopted regulations of the individual 2LoD units and is responsible for monitoring compliance with first line of
defence controls, in the form of ongoing verification and/or vertical testing.
• third line of defence (3LoD) – the third line of defence is the independent and objective Internal Audit Division, which
verifies the correct functioning of the first and second lines of defence in accordance with dedicated internal regulations.
The Bank has a process architecture within which significant processes are identified according to specific criteria. The
control function for significant processes is documented by the Bank using the Control Function Matrix (CFM), which is a
description of the link between the general and specific objectives of the internal control system and the significant
processes, together with the key controls embedded in these processes and the independent monitoring of these controls.
The Bank supports the CFM with a dedicated application.
The role of the control function is to ensure compliance with the control mechanisms in the processes in place at the Bank,
including those relating to risk management, covering all the Bank’s units.
The Bank adapts the types of control mechanisms (procedures, segregation of duties, authorisation, access control, physical
control, recording of financial and economic operations in banking systems, inventory, documentation of deviations,
training, self-control) to the specific objectives of the internal control system, the complexity of the processes, the risk of
irregularities, taking into account the Bank’s available resources.
Irregularities detected during the exercise of internal control within each line of defence, including errors and fraud, are
categorised according to their source and their impact on ensuring the achievement of the stated objectives of the internal
control system.
As a result of the activities carried out at the Bank and the reviews and assessments of the effectiveness in the area of
internal control, the Bank’s Management Board and/or Supervisory Board receive appropriate reports.
The Accounting Policy has been adopted at the Bank in compliance with the International Financial Reporting Standards
approved by the European Union and other detailed internal acts concerning the recording of events and the processes of
preparing accounting and reporting data. The preparation of financial statements, periodic financial reporting and the
provision of management information are the responsibility of the Financial Accounting Division and the Management
Accounting and Investor Relations Division, supervised by the Vice-President of the Management Board responsible for the
Finance Area. The financial statements are adopted by resolution and approved for publication by the Bank’s Management
Board.
The Bank’s financial reporting process is based on accounting data, the preparation of which in source systems and
reporting databases is subject to formal operational and acceptance procedures. Reporting data are subject to control
mechanisms, such as reconciliation of reporting data with the accounting ledgers, analytical data and relevant
documentation. The process of month-end closing and preparation of accounting and reporting data is carried out and
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monitored on the basis of a schedule that defines the various stages of the process along with their owners, who are
responsible for the correct and timely execution of the various activities.
As part of risk management in the process of preparing financial statements, the Bank monitors changes in laws and
regulations relating to bank financial reporting and updates the accounting principles used and the scope and form of
disclosures in the financial statements accordingly, as well as making the required changes to the IT systems.
The Bank’s consolidated financial statements are prepared on the basis of the Bank’s separate data and information
received from the subsidiaries in the form of consolidation packages. The Financial Accounting Division verifies the
information received and maintains ongoing communication with the financial services of the subsidiaries to ensure the
best possible quality and consistency of the data received.
A key role in the process of evaluating the Bank’s financial statements is played by the Audit Committee, which monitors
the financial reporting process and the independence of the auditor and the audit firm, and recommends to the Supervisory
Board the approval or rejection of the annual financial statements. The annual financial statements, following a positive
recommendation by the Audit Committee and the Supervisory Board, are presented to the General Meeting for approval.
Information about the auditor
The Supervisory Board of BNP Paribas Bank Polska S.A. selects the audit firm to audit the financial statements of the Bank
and the Group and to provide sustainability reporting assurance pursuant to the provisions of the Bank’s Articles of
Association and based on a recommendation of the Audit Committee.
Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością sp.k. was appointed on 15 September 2023 by the
Bank’s Supervisory Board as the audit firm authorised to audit and review the separate financial statements of BNP Paribas
Bank Polska S.A. and the consolidated financial statements of the BNP Paribas Bank Polska S.A. Group, including the
reporting packages, for the years 2024-2025.
In September 2025, the Supervisory Board selected Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością
sp.k. to provide assurance of the Group’s sustainability reporting for 2025.
On 10 December 2025, based on a recommendation of the Audit Committee, the Supervisory Board selected the same audit
firm to audit and review the financial statements and to provide sustainability reporting assurance for 2026-2029.
Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warsaw at Rondo
ONZ 1, is entered in the list of audit firms under number 130, which is maintained by the Polish Audit Supervision Agency.
Table 150. Auditor’s fees by type of service
12 months
ended 31.12.2025
12 months
ended 31.12.2024
PLN’000 (incl. VAT)
Bank
Bank’s
subsidiaries
Total
Bank
Bank’s
subsidiaries
Total
Statutory audit
2,729
316
3,045
2,635,
305
2,940
Other assurance services*
1,845
875
2,720
1,556
843
2,399
Other
44
0
44
57
0
57
Total
4,618
1,191
5,809
4,248
1,148
5,396
* This category includes the fees of the auditor who performed the review of the interim financial statements, sustainability reporting assurance, verification of the reporting packages for the consolidation
of the BNP Paribas Group. The review and audit of funds managed by the subsidiary TFI are also included in this category.
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Other information
281 Legal compliance
289 Events after the balance sheet date
290 Statements of the Management Board of BNP Paribas Bank Polska S.A.
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Legal compliance
Court and administrative proceedings
Legal risk
As at 31 December 2025, there were no proceedings in the court, arbitration tribunal or state administration authorities
regarding liabilities or receivables of the Bank, the value of which would exceed 10% of the Bank’s equity.
UOKIK proceedings
Court decision on the UOKiK decision regarding calculation of the interchange fee
On 6 October 2015, the Court of Appeal issued a decision regarding calculation of the interchange fee by banks acting in
agreement. Thus, the decision of the first instance (Regional) Court of 2013 was changed by dismissing the banks’ appeals
in whole, while upholding the appeal brought by the Office of Competition and Consumer Protection (UOKiK), which had
questioned a considerable reduction in the fines by the first instance court. This means that the penalty imposed under the
first decision of the President of UOKiK of 29 December 2006 was upheld. It involved a fine levied on 20 banks, including
Bank BGŻ S.A. and Fortis Bank Polska S.A., for practices limiting competition by calculating interchange fees on Visa and
MasterCard transactions in Poland in agreement.
The total fine levied on Bank BGŻ BNP Paribas S.A. (presently BNP Paribas Bank Polska S.A.) amounted to PLN 12,554
thousand and included:
• a fine for the practice of Bank Gospodarki Żywnościowej in the amount of PLN 9,650 thousand; and
• a fine for the practice of Fortis Bank Polska S.A. (FBP) in the amount of PLN 2,895 thousand.
The penalty was paid by the Bank on 19 October 2015. The Bank prepared a last resort appeal against the aforesaid court
decision and brought it on 25 April 2016. On 25 October 2017, the Supreme Court overruled the judgment of the Court of
Appeal and remitted the case. Acquisition of the core business of Raiffeisen Bank Polska S.A. (RBPL) did not change the
situation of the Bank as RBPL was not a party to this claim.
On 23 November 2020, the Court of Appeal quashed the judgment of the first instance court and remitted the case for
reexamination. In November 2022, the first hearing was held. The case is pending.
Proceedings on practices violating collective consumer interests – unauthorised transactions
On 8 July 2022, the Office of Competition and Consumer Protection (UOKiK) initiated proceedings related to the practices
violating the collective interests of consumers. The UOKiK alleges that the Bank, upon receipt of a consumer complaint
regarding an unauthorised transaction, does not automatically return funds to customers within the D+1 deadline, but
instead conducts an initial clarification procedure to determine whether the transaction in question should be considered
as accepted/conducted by the customer. The second allegation of the UOKiK relates to the Bank providing inappropriate
information to customers when rejecting complaints about the disputed transaction. The Bank is talking to the UOKiK to
agree a final decision, the proceedings are expected to be completed in April 2026. The case is pending, the Bank is working
with the UOKiK to finalise it. The UOKiK announced an extension of the proceedings until 11 April 2026.
Details of the cost of provisions against unauthorised transactions of customers are described in Note 14 Other operating
expenses.
Proceedings for practices violating the collective interests of consumers – credit holidays
On 5 September 2022, the Bank received the UOKiK’s decision to initiate proceedings against practices that violate the
collective interests of consumers by limiting the possibility to apply for a mortgage loan payment suspension by limiting
one application to 2 months, whereas the customer should be able to apply for all periods at the same time (up to 8
months).
The Bank disagreed with the allegations and sent its reply to UOKiK, in which it pointed out that the Bank accepted and
processed all individual applications submitted by customers (for any number of months). Thus, there was no violation of
the collective interests of consumers, as the Bank did not deprive customers of their rights, but only failed to fully automate
the electronic application as of the effective date of the law. At the same time, the Bank informed UOKiK that it had
changed the questioned practice by launching a new application form in GOonline e-banking on 8 September 2022,
allowing customers to apply for any/all periods simultaneously (up to 8 months).
On 17 January 2023, the Bank received the Decision of the UOKiK, in which:
• it recognised the questioned practice as violating the collective interests of consumers;
• the practice was found to be abandoned;
• it ordered publication of the decision;
• it imposed a penalty on the Bank in the amount of PLN 2,721 thousand (reduced by 50% (30% – for cessation of the
practice, 20% as a result of initiating a meeting and expressing willingness to cooperate).
On 17 February 2023, the Bank appealed against the decision to the Competition and Consumer Protection Court. On 8
December 2023, the court delivered to the Bank the UOKiK’s response to the Bank’s appeal, filed with the UOKiK on 28
August 2023.
The Bank created a provision in the amount of the penalty imposed.
On 24 March 2025, the Court announced its decision which dismissed the Bank’s appeal. The Bank appealed against the
Court’s decision on 9 May 2025.
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PFSA proceedings
Administrative proceedings of the Polish Financial Supervision Authority for the imposition of a penalty in connection with
the performance of the function of depositary of investment funds
On 28 September 2022, the Polish Financial Supervision Authority initiated administrative proceedings for the imposition of
an administrative penalty against the Bank pursuant to Article 232(1a) of the Act on Investment Funds and Management of
Alternative Investment Funds, in connection with the Bank’s suspected breach of the provisions of the aforementioned Act
during the period 31 January 2017 to 31 August 2019, by failing to exercise due control of the factual and legal acts carried
out by investment funds PSF Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych and PSF 2 Fundusz Inwestycyjny
Zamknięty Aktywów Niepublicznych to ensure that the net asset value of these funds and the net asset value per
investment certificate were calculated in accordance with the law and the statutes of these funds.
By decision of 14 June 2024, the Polish Financial Supervision Authority imposed a fine of PLN 1,000 thousand on the Bank
for breach of obligations related to ensuring that the net asset value of the funds and the net asset value per investment
certificate are calculated in accordance with the law, for valuation dates falling between 31 October 2018 and 31 July 2019.
In the justification for the decision, the PFSA indicated that the breach of the aforementioned depositary duties consisted
mainly of: (i) not obtaining full information on the financial situation of the issuers of the bonds that the funds were
purchasing, which resulted in the Depositary not being able to fully assess the bond issuers’ ability to redeem the bonds,
(ii) not performing an analysis of the impact of circumstances regarding the financial situation of bond issuers on the
rationale for impairment losses on bonds and the final fair value measurement of bonds, (iii) failure to investigate the
reasons for negative capital on the part of bond issuers and the possible impact of these circumstances on the bond
issuers’ ability to repay their bond redemption obligations. The PFSA dismissed the proceedings in part to ensure that the
net asset value of these funds and the net asset value per investment certificate are calculated in accordance with the
statutes of these funds for the asset valuation days falling between 31 October 2018 and 31 July 2019, and in part to ensure
that the net asset value of these funds and the net asset value per investment certificate are calculated in accordance with
the law and the statutes of these funds for the asset valuation days falling between 31 January 2017 and 30 October 2018
(acting as depositary by Raiffeisen Bank Polska S.A.) and from 1 August 2019 to 31 August 2019.
On 4 July 2024, the Bank applied for reconsideration of the case by the Polish Financial Supervision Authority.
The Bank created a provision for the imposed penalty.
The Polish Financial Supervision Authority informed the Bank that the proceedings to determine the aforementioned
application are scheduled to be completed in March 2026.
On 7 December 2022, the Polish Financial Supervision Authority initiated administrative proceedings for the imposition of a
penalty under Article 232(1a) of the Act on Investment Funds and Management of Alternative Investment Funds, in
connection with the Bank’s suspected breach of the provisions of the aforementioned Act in the years 2017 – 2019, by
failing to exercise continuous control over the factual and legal actions carried out by the Retail Parks Fund of Fundusz
Inwestycyjny Zamknięty Aktywów Niepublicznych, in connection with the valuation of the fund’s assets, aimed at ensuring
that the net asset value of the fund and the net asset value per investment certificate are calculated in accordance with the
law.
By decision of 14 June 2024, the Polish Financial Supervision Authority imposed a fine of PLN 500 thousand on the Bank for
breach of duties related to ensuring that the fund’s net asset value and the net asset value per investment certificate were
calculated in accordance with the law, for the valuation days falling on 30 November 2018 and 28 February 2019.
In the justification for the decision, the PFSA indicated that the breach of the above-mentioned duties of the Depositary
consisted primarily in the failure to conduct a thorough analysis of the circumstances affecting the determination of the
situation of the issuers of the bonds purchased by the fund and to obtain sufficient information on the circumstances
affecting this situation. As a result the Depositary did not recognise the legitimacy of making impairment allowances for the
bonds in an appropriate amount and the valuation of the bonds was inadequate to their actual value. The PFSA dismissed
the proceedings in the part concerning the suspected breach in the period from 1 January 2017 to 30 October 2018.
On 4 July 2024, the Bank has applied for reconsideration of the case by the Polish Financial Supervision Authority. The Bank
created a provision for the imposed penalty. The Polish Financial Supervision Authority informed the Bank that the
proceedings for the recognition of the aforementioned application are scheduled to be completed in March 2026.
Administrative proceedings of the Polish Financial Supervision Authority for the imposition of a penalty in connection with a
breach of the Act on Trading in Financial Instruments
On 24 January 2025, the Polish Financial Supervision Authority opened administrative proceedings against BNP Paribas
Bank Polska S.A. for the imposition of a penalty under Article 138(3)(3a) or Article 138(7aa)(1) of the Banking Law in
connection with a breach of the Act on Trading in Financial Instruments.
The proceedings are pending.
Legal risks of the portfolio of foreign currency and CHF denominated loans
Court proceedings instigated by the Bank’s customers being parties to foreign currency and CHF denominated loan
agreements
The gross balance sheet value of residential mortgage loans granted to retail customers in CHF as at 31 December 2025
amounted to PLN 254,276 thousand, compared with PLN 406,207 thousand as at 31 December 2024.
As at 31 December 2025, the number of active foreign currency and CHF denominated loans amounted to 5.3 thousand.
As at 31 December 2025, the Bank was a defendant in 5,865 (1,456 new cases in 2025) pending court proceedings
(including legally finalised cases, customers brought a total of 11,047 claims against the Bank), in which they demand
either that a foreign currency or CHF denominated mortgage loan agreement be declared invalid or that the agreement be
declared permanently ineffective and the amounts paid to date be repaid. The claims are based on the presence of abusive
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provisions in the agreement which do not allow the agreement to be sustained (Article 3851 of the Civil Code); the Bank is
not a party to any collective claim involving such loan agreements.
The total value of the claims asserted in the currently pending cases as at 31 December 2025 amounted to PLN 3,126,776
thousand (PLN 3,495,835 thousand as at 31 December 2024), and in the legally concluded cases to PLN 2,107,350 thousand
(PLN 1,141,019 thousand as at 31 December 2024).
By 31 December 2025, in 5,182 finalised proceedings, there were 1,403 judgments in favour of the Bank, including 908 in
connection with court settlements and 453 cases in connection with the proceedings being stayed. In 3,779 cases the
courts ruled against the Bank, declaring the loan agreement invalid or permanently ineffective.
The Bank continuously assesses the impact of legal risks related to pending court proceedings involving denominated or
foreign currency loans, taking into account the current status of judgments in cases against the Bank and the line of
jurisprudence.
The Polish courts, despite the different indications resulting from the rulings of Court of Justice (EU) (C-19/20 and C-
932/19), in the vast majority rule on the invalidity or ineffectiveness of credit agreements.
The total impact of legal risk related to litigation as at 31 December 2025 was PLN 2,823,983 thousand (PLN 3,238,760
thousand as at 31 December 2024), with an impact of PLN 498,751 thousand on the Bank’s statement of profit or loss in
2025 (PLN 795,728 thousand in 2024).
In 2025, the Bank used PLN 289,634 thousand from the estimated impact of legal risk of CHF loans in connection with
settlements reached (in 2024, the Bank used PLN 422,952 thousand on this account).
In 2025, the Bank used PLN 622,260 thousand from the estimated impact of legal risk of CHF loans in connection with final
judgments received declaring loan agreements invalid (in 2024, the Bank used PLN 438,786 thousand on this account).
In estimating the impact of legal risk, the Bank takes into account, among others, the estimated number of future lawsuits,
the number of lawsuits filed, the probability of losing the case, and the Bank’s estimated loss in the event of an
unfavourable judgment. In addition, the Bank included in the model the estimated number of settlements that will be made
with customers. The amount of the estimated impact of the legal risk associated with the settlements was PLN 145,884
thousand from the total impact estimate.
The Bank estimates the probability of losing a case based on historical judgments, separately for the foreign currency and
denominated loan portfolios. Due to the observed volatility in case law, the Bank, when estimating the probability of an
adverse judgment, takes into account judgments made after 31 December 2020.
In estimating the loss in the event of a judgment declaring the loan invalid, the Bank assumes that the customer is obliged
to return the capital paid out without taking into account other benefits from the consumer (remuneration for the use of the
capital or valorisation), that the Bank is obliged to return the sum of the principal and interest instalments repaid together
with the statutory default interest awarded, and that the Bank writes off the credit exposure. The loss estimate takes into
account the time value of money.
The accounting effect of signing a settlement agreement with a customer is the derecognition of a CHF loan, recognition of
a new loan in PLN and the recognition of a result from the derecognition and the recording of settlements with customers.
The accounting effect of a final judgment declaring the loan agreement invalid is the derecognition of CHF loan exposure
and the recording of settlements with customers due to the declaration of invalidity of the agreement.
Should the assumed average loss change by +/- 5%, with all other significant assumptions unchanged, the amount of the
estimated impact would change by +/- PLN 79,630 thousand.
The Bank conducted a sensitivity analysis of the model used to estimate the number of lawsuits lost. A change in this
estimate would have the following impact on the estimated loss due to legal risk related to CHF loans.
parameter
scenario
impact on Bank’s loss due
to legal risk
Percentage of lost cases
+5 p.p.
+PLN 62.8 million
-5 p.p.
-PLN 80.4 million
The Bank conducted a sensitivity analysis of the model used to estimate the number of future lawsuits.
A change in the number of future lawsuits would have the following impact on the estimated loss due to legal risk related
to CHF loans.
parameter
scenario
impact on Bank’s loss due
to legal risk
Number of future lawsuits
+20%
+PLN 26.7 million
-20%
-PLN 26.7 million
Additionally, according to the Bank’s assessment, if an additional 1% of customers with CHF loans filed a lawsuit against
the Bank, the loss due to legal risk would increase by approx. PLN 24,246 thousand.
When calculating the expected loss on legal risk related to CHF loans, the Bank takes into account the available historical
data, including the content of judgments in concluded cases. The Bank monitors the number of collected certificates and
the changing number of lawsuits in order to update the estimated impact of legal risk of foreign currency loans accordingly.
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The current line of jurisprudence in cases involving actions by CHF borrowers is unfavourable to banks, but nevertheless
some legal issues are still not clarified, in particular the qualification of loans as foreign currency loans. The above issues
are relevant to the assessment of the risks associated with proceedings involving part of the Bank’s portfolio.
The Bank monitors the courts’ rulings on an ongoing basis and will adjust the level of estimated impact of legal risk to the
current case-law. At the same time, the Bank is aware that the assumptions made are subject to a subjective assessment of
the current situation, which may change in the future. In determining the value of the estimated impact of legal risk, the
Bank relies on all information available at the date of signing the financial statements.
At the same time, the Bank has taken into account the right to recognise a deferred tax asset in connection with the
entitlement to apply a tax preference in respect of settlements falling within the scope of the Regulation of the Minister of
Finance of 11 March 2022, as amended by the Regulation of 20 December 2022, in force until the end of 2024, on the
abandonment of the collection of income tax on certain income (net income) related to a residential mortgage loan.
As at 31 December 2024, the Bank held assets of PLN 38,165 thousand, which were realised in full in 2025. In 2025, the
Bank additionally realised assets at PLN 1,863 thousand, set up during 2025 on the basis of additional legal risk provisions.
Based on an new estimate of the impact of the legal risk associated with foreign currency loans as at 31 December 2025,
the Bank leaves PLN 32,161 thousand in assets with an expected realisation by the end of 2026; at a rate of 19%, the asset
would be PLN 23,599 thousand.
In addition, based on:
• the ruling of the Supreme Administrative Court on the tax treatment of returned interest related to cancelled foreign
currency loan agreements and the exchange rate differences arising in relation to these loans, recognised in previous
years, as well as the individual interpretation, according to which statutory interest for late payment ordered by the court
consists of a tax-deductible cost for the Bank on the date of payment, and
• the analysis of their impact on the deferred tax estimate,
the Bank recognised a deferred tax asset.
Individual settlements offered by the Bank in CHF loan cases
Since December 2021, the Bank is involved in individual negotiations with its customers with whom the Bank is in dispute
or for whom there is a reasonable risk of entering into a dispute. The Bank took this parameter into account when updating
the amount of the total impact of legal risk.
As at 31 December 2025, the Bank made individual settlement proposals to 14,473 customers (13,915 customers as at 31
December 2024) and 7,130 customers accepted the terms of the proposals presented (6,202 in 2024), out of which 6,724
settlements were signed (5,550 in 2024).
Case law of the Court of Justice (EU) in 2025
On 19 June 2025, the CJEU passed a judgment in case C-396/24 (Lubreczlik) concerning mBank S.A. According to the CJEU,
Directive 93/13 should be interpreted as precluding national case-law according to which:
1) where a term of a loan agreement classified as unfair renders that agreement invalid, the seller or supplier is entitled to
require the consumer to repay the full nominal amount of the loan, irrespective of the value of repayments made by the
consumer in performance of that agreement and irrespective of the amount remaining due;
2) in the event of the consumer’s acceptance of a claim, brought by a seller or supplier, for repayment of the sums paid
under a loan agreement declared invalid based on the presence of an unfair term in that agreement, the court is required
to declare of its own motion the judgment granting that claim immediately enforceable, in so far as national law does not
allow that court to adopt all the measures necessary to protect the consumer from the particularly unfavourable
consequences which that declaration could have with regard to that consumer.
On 27 November 2025, the CJEU passed a judgment in case C-746/24 (Gryczara) concerning Bank Millennium S.A. According
to the judgment, Directive 93/13 should be interpreted as precluding national legislation which allows a consumer, as the
defendant who has been unsuccessful in an action brought by a seller or supplier for repayment of the loan capital
following the annulment of a loan agreement on account of the unfairness of terms contained therein, to be ordered to pay
the costs including court costs which, as a result of the distinction made by that legislation in the calculation of the amount
of those costs according to whether the applicant is a consumer, significantly exceed those which that consumer would
have had to bear if he or she had been unsuccessful in an action brought by him or her seeking a declaration that those
terms are unfair and, as the case may be, a declaration of the invalidity of those terms and of the loan agreement.
On 11 December 2025, the CJEU passed a judgment in case C-767/24 (Kuszycka) concerning mBank S.A. According to the
CJEU, Directive 93/13 must be interpreted as meaning that, in the context of the annulment in its entirety of a mortgage
loan agreement concluded between a consumer and a banking institution, on the ground that that agreement contains an
unfair term without which that agreement cannot continue in existence, it precludes the application of national case-law
according to which the submission by that consumer of a declaration of set-off of his or her claim against that of that
banking institution entails an implied waiver of the objection that the claim relied on by that institution is time-barred.
Supreme Court case law on CHF denominated and foreign currency loans
On 25 April 2024, the full formation of the Civil Chamber of the Supreme Court adopted the so-called ‘large resolution on
Swiss franc loans issue’, resolving the key legal issues, ref. III CZP 25/22, according to which:
1) If a provision of an index-linked or denominated loan agreement relating to the method of determining the foreign
currency exchange rate consists of an unfair contractual term and is not binding, that provision cannot, in the current state
of the law, be regarded as being replaced by another method of determining the foreign currency exchange rate which
results from legal or customary provisions.
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2) If it is not possible to establish a foreign currency exchange rate that is binding on the parties in an indexed or
denominated loan agreement, the agreement shall also not be otherwise binding.
3) Where, in the execution of a loan agreement which is not binding due to the unfair nature of its terms, the bank has
provided the borrower with all or part of the amount of the loan and the borrower has made repayments of the loan,
independent claims for the repayment of undue benefits arise in favour of each party.
4) If a loan agreement is not binding because of the unfair nature of its terms, the limitation period for the bank’s claim for
repayment of sums paid out in respect of the loan begins, as a general rule, from the day following the day on which the
borrower challenged the terms of the agreement as binding.
5) If a loan agreement is not binding because of the unfair nature of its terms, there is no legal basis for either party to
claim interest or other remuneration for the use of its funds during the period between the time when the undue benefit
was provided and the time when repayment of that benefit is delayed.
The resolution refers only to the effects of declaring conversion clauses in indexed or denominated loan agreements as
unfair (without prejudging whether such clauses are unfair). The resolution does not apply to foreign currency loans, where
the conversion clauses are of an optional nature and as such are not necessary for the execution of the loan agreement.
It should be emphasised that the position of the Supreme Court expressed in the justification does not unequivocally
resolve previous divergences in case law regarding the definition of a foreign currency loan (see, e.g., the judgment of the
Supreme Court of 20 May 2022, case no. II CSKP 713/22; the decision of the Supreme Court of 24 June 2022, case no. I CSK
2822/22; the judgment of the Supreme Court of 26 January 2023, case no. II CSKP 408/22; the judgment of the Supreme
Court of 31 January 2023, case no. II CSKP 334/22; the judgment of the Supreme Court of 15 September 2023, case no. II
CSKP 1356/22; the judgment of the Supreme Court of 9 May 2024, case no. II CSKP 2416/22; and the judgment of the
Supreme Court of 25 July 2024, case no. II CSKP 1424/22).
However, as the Supreme Court noted in the justification to the resolution, this kind of loan is not subject to questions
referred by the First President of the Supreme Court.
The Supreme Court noted that in the case of foreign currency loans in which there is no problem of unfair terms in
determining the exchange rate at the time of disbursement of the loan by the bank, or in which, as a result of the removal
of such unfair terms, the agreement is still in force in a form in which, in principle, repayment of the loan in foreign
currency is possible, it may be assumed that Article 358 § 2 of the Civil Code, as the relevant provision, applies to the
conversion of the exchange rate (i.e. the agreement may be continued using the average exchange rate of the National Bank
of Poland).
This position of the full formation of the Chamber of the Supreme Court was reflected in a separate opinion of Supreme
Court Judge Dariusz Pawłyszcze regarding the judgment of the Supreme Court of 25 June 2024, ref. II CSKP 1765/22
(concerning the Bank). In the justification of the separate opinion, the Judge pointed to the different structure of the Bank’s
loan agreements and argued that Resolution III CZP 25/22 did not apply to foreign currency loans as, under such
agreements, the option of repayment in PLN (at the bank’s exchange rates) is merely the borrower’s right.
The case-law of common courts includes decisions pointing to the different nature of foreign currency loans and the impact
of such classification on the validity of agreements. This position was taken by the Appeal Court in Warsaw in its legally
valid judgment, favourable to the Bank, of 5 June 2025, ref. VIII ACa 2851/25. The Court stressed the foreign currency aspect
of the loan agreement between the Bank and the consumer, found no infringement of consumer interests, and confirmed
the validity of the loan agreement.
Following the CJEU judgment of 19 June 2025 in case C-396/24 (Lubreczlik), the Supreme Court confirmed the applicability
of the legal principle defined in the resolution of the full formation of the Civil Chamber of the Supreme Court of 25 April
2024, ref. III CZP 25/22, i.e., where a loan agreement is not binding due to its terms being unfair, separate claims arise for
the return of undue benefits for each party of the agreement. On 6 August 2025, the Supreme Court passed a judgment in
case II CSKP 774/23, confirming that the theory of two separate claims applied to settlements between a bank and
borrowers where the loan agreement is declared invalid. Likewise, the Supreme Court in another formation pointed out in
its judgment of 5 September 2025 in case II CSKP 550/24 that the legal principle defined in point 3 of the resolution of the
full formation of the Civil Chamber of the Supreme Court of 25 April 2024 in case III CZP 25/22 was binding (similar to the
judgment of the Supreme Court of 18 July 2025, II CSKP 84/23). In its judgment of 10 July 2025, II CSKP 64/23, the Supreme
Court ruled that the legal principle defined by the full formation of the Chamber of the Supreme Court could only be
departed from by passing another resolution of the same formation (Article 88 of the Act on the Supreme Court).
As at 31 December 2025, 295 appeals on a point of law were filed with the Supreme Court in cases of CHF loans granted by
the Bank, 44 appeals were accepted by the Supreme Court for examination and are awaiting substantive decision, as to 159
appeals on a point of law, the Supreme Court issued a decision on refusal to accept them for examination. Nine cases were
sent back for examination, while in 22 it dismissed the appeals on a point of law.
Draft Act on special solutions for handling cases concerning loan agreements denominated or indexed to CHF concluded
with consumers
On 30 January 2025, the Ministry of Justice published a draft Act on special solutions for handling cases concerning loan
agreements denominated or indexed to CHF concluded with consumers. Following comments raised in the public
consultation and the CJEU judgment of 19 June 2025 in case C-396/24 (Lubreczlik), a new draft Act was published dated 30
June 2025.
The goal of the draft law is to accelerate court proceedings concerning loan agreements denominated or indexed to CHF.
The key mechanisms set out in the draft include:
• protection of consumer interests (Article 3 of the draft) – once an action lodged by a consumer is served on the defendant
or once a counterclaim lodged by the consumer is served on the plaintiff, the obligation of the consumer to perform the
benefits arising from the loan agreement is suspended by law until the proceedings are closed with a final judgment;
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• plea of offset (Articles 5 and 18 of the draft) – change to the time limitation for the option of raising the plea of offset in
the proceedings (until the proceedings are closed in second instance);
• counterclaim (Article 8 of the draft) – change to the time limitation in civil proceedings (under the general procedure, no
later than in the statement of defence) – allowing for a counterclaim to be lodged until the hearing is closed in first
instance.
The draft law was tabled to the Sejm on 2 October 2025.
The Sejm held the first reading of the draft on 16 October 2025, after which the draft was referred to the Committee for
Justice and Human Rights (and the Committee for the Economy and Development). Both Committees started to work on the
draft on 17 December 2025 at a joint meeting.
The work on the draft is scheduled to continue in 2026.
Other material court proceedings
Court proceedings concerning mortgage loan agreements with interest rates based on WIBOR
In January 2023, the Bank received the first claims challenging the variable interest rate clauses based on the WIBOR
benchmark in mortgage loan agreements. These claims seek to challenge WIBOR as the basis for variable interest rates. In
addition, the extent to which and the manner in which consumers are provided with instructions and information about the
volatility of the benchmark as well as the methods of calculating the benchmark and the factors influencing its change are
contested.
By 31 December 2025, the Bank received a total of 130 claims (2 claims were withdrawn). The actions were filed on behalf
of consumers and relate to mortgage loan agreements in PLN, only 1 action was filed by an entrepreneur and relates to a
revolving credit agreement.
In the case of the Bank’s products offered to consumers, only mortgage loans and certain products for Wealth customers
are based on the WIBOR reference rate. The total value of the subject of litigation in ongoing court proceedings lodged by
customers is PLN 33,401 thousand. Most of the court proceedings are pending before the courts of first instance. In nine
cases, judgments of the court of first instance favourable to the bank were issued, three of which are legally binding. One
judgment is unfavourable to the Bank and is not legally binding.
Arguments challenging WIBOR as a benchmark are also raised in debt enforcement cases filed by the Bank.
The Bank’s position is that the customers’ claims are unjustified, in particular in view of the fact that WIBOR is an official
benchmark whose administrator has received the relevant approvals required by law, among others from the Polish
Financial Supervision Authority, and the process of its determination, carried out by the administrator (an independent
entity not affiliated with the Bank), is in accordance with the law and is also subject to supervisory assessment by the
Polish Financial Supervision Authority. The Polish Financial Supervision Authority confirmed WIBOR’s compliance with the
requirements of the law. The same position was presented by the Financial Stability Committee, which comprises
representatives of: the National Bank of Poland, the Polish Financial Supervision Authority, the Ministry of Finance, and the
Bank Guarantee Fund.
Four questions regarding WIBOR have been referred to the CJEU, including one question referred to in connection with a
case pending against the Bank (no judgments have yet been passed in those cases):
• Case C-471/24 against PKO BP SA (agreement concluded after the effective date of the BMR and the Act on mortgage
loans and supervision over mortgage loan intermediaries and agents, the “mortgage loan act”) – questions were referred
on the possibility of examining contractual provisions concerning floating interest rates based on WIBOR, information
obligations of banks regarding floating interest rate risk, and the possibility of continued existence of a loan agreement
based on a fixed margin where contractual provisions concerning floating interest rates based on WIBOR are declared
unfair. According to the opinion of the Advocate General published on 11 September 2025, it is admissible to examine
contractual provisions concerning floating interest rates under Directive 93/13, the WIBOR determination method cannot
be challenged by reference to Directive 93/13, the bank should inform the consumer of the name of the benchmark, its
administrator and the effect of changes to the benchmark on loan interest rates. The judgment is expected to be
announced on 12 February 2026.
• Case C-586/25 against PKO BP SA (agreement concluded before the effective date of the BMR and the mortgage loan act)
– the Court referred among other questions whether, in the light of Directive 93/13, the provisions of a loan agreement
concerning floating interest rates based on WIBOR could be considered to be phrased in a simple and understandable
language, whether the fact that the floating interest rate of a loan is based on WIBOR, whose determination rules were
not based on generally applicable law but which was determined by a third party while the bank had an indirect impact
on the benchmark, results in a significant imbalance of the rights and obligations of the parties, and whether, where the
provisions of an agreement concerning floating interest rates based on WIBOR are declared unfair contractual provisions,
the agreement may continue to exist as a loan at a fixed interest rate based on the bank’s margin or whether the
agreement must be declared invalid.
• Case C-607/25 against the Bank (the question concerns an agreement concluded after the effective date of the BMR and
the mortgage loan act) – the Court asks whether national legislation laying down the method for fixing the variable
interest rate as the value of the reference index and the amount of the margin ensures effective balance between the
parties to the agreement where the provisions of national law do not set any maximum limits on the permitted increase
in the value of the reference index and in the amount of the margin during the lifetime of the agreement, and the
maximum interest rate permitted under provisions of national law governing maximum contractual interest rates may be
changed throughout the lifetime of the agreement.
• Case C-630/25 against PKO BP SA (agreement concluded before the effective date of the BMR and the mortgage loan act)
– the Court asks whether the requirement under Directive 93/13 to phrase the provisions of an agreement in a simple and
understandable way requires the bank to inform the consumer of the entity which is providing the benchmark forming
the basis of the interest rate on the loan and the detailed rules setting out the method for fixing the benchmark (in
particular, whether the bank is required to present the consumer with the regulations containing those rules for fixing the
benchmark and whether the bank is required to make the consumer aware that that benchmark is calculated on the basis
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of declarations by a group of banks and not on the basis of actual market transactions). Furthermore, the Court asks
whether it is possible to regard as unfair a contractual term setting the interest rate on a loan that uses a benchmark
which is calculated on the basis of declarations by a group of banks and is not defined in provisions of national or EU law,
with no State authority supervising the manner in which that benchmark is provided, and which does not reflect the
actual costs of financing the loan.
Court proceedings concerning claims of investment fund members in connection with the function of investment fund
depositary
Up to 31 December 2025, the Bank received in total 197 individual claims and 6 claims in collective proceedings lodged by
investment fund members in connection with the function of investment fund depositary (including the investment fund
depositary function performed by Raiffeisen Bank Polska S.A.).
The total amount of the claims is PLN 211,221 thousand. The total provisions are PLN 3,739 thousand.
The first two collective claims were filed by members of the Retail Parks Fund of Fundusz Inwestycyjny Zamknięty Aktywów
Niepublicznych w likwidacji (formerly Fundusz RPF) respectively on behalf of 397 members with claims at PLN 96,221
thousand and on behalf of 181 members with claims at PLN 25,302 thousand.
Other collective claims are to establish the Bank’s responsibility for its actions as depositary of the following funds: (3) PSF
2 Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych (filed on behalf of 17 fund members; claims value not
specified), (4) PSF Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych (filed on behalf of 81 fund members; claims
value not specified) (5) EPEF Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych (filed on behalf of 42 fund
members; claims value PLN 128 thousand) and (6) PSF Lease Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych
(filed on behalf of 38 fund members; claims value PLN 8,988 thousand).
The claims raised focus in particular on undue performance by Raiffeisen Bank Polska S.A. and subsequently the Bank of
obligations to ensure that the net asset value of the fund and the net asset value per investment certificate are calculated
in accordance with the law and the investment fund statute and of the obligation to check the compliance of the
investment fund with laws governing investment funds and with the statute. The Bank takes the view that the claims of the
fund members against the Bank are unfounded.
Up to 31 December 2025, a total of 27 non-final judgments of first instance courts and 2 legally valid judgments were
passed:
• 1 legally valid judgment unfavourable to the Bank (in the case of the InMedica fund, the Court awarded PLN 64 thousand
to the plaintiff due to incorrect diversification of fund assets);
• 1 legally valid judgment favourable to the Bank (in the case of the InMedica fund, the Court dismissed the claim in its
entirety as the criteria of the Bank’s liability for damages were not met);
• 27 judgments favourable to the Bank (claims of individual fund members were dismissed as the criteria of the Bank’s
liability for damages were not met).
Court proceedings concerning free credit sanction referred to in Article 45 of the Consumer Credit Act of 12 May 2011
(‘u.k.k.’)
The institution of free credit sanction is regulated in Article 45 of the Consumer Credit Act, according to which, in the event
of a breach by the creditor of the provisions of the Act listed therein, the consumer, after submitting a written statement to
the creditor, shall repay the credit without interest and other credit costs due to the creditor within the time limit and in
the manner agreed in the credit agreement, and if no such manner has been agreed, shall repay the credit in equal
instalments, payable monthly, from the date of the conclusion of the credit agreement. Pursuant to Article 45(5) of the
Consumer Credit Act, the entitlement to the free credit sanction expires one year after the execution of the credit
agreement.
The first lawsuits related to customers’ use of the free credit sanction started to be received by the Bank in 2021. As at 31
December 2025, the Bank received 1,456 lawsuits with a total litigation value of PLN 35,099 thousand.
As at 31 December 2025, the provisions stood at PLN 1,491 thousand.
The Bank disputes the validity of the claims raised in these cases.
The jurisprudence to date is overwhelmingly in favour of the Bank.
Out of all the cases pending against the Bank: 943 are at first instance, 217 are at the second instance stage, while 296
have been finalised.
The use of the free credit sanction is also raised in the Bank’s debt enforcement proceedings. As at 31 December 2025, the
plea was raised in 64 such cases.
Legal issues concerning the free credit sanction are the subject of numerous preliminary questions referred by Polish courts
to the Court of Justice of the European Union (CJEU) concerning:
• the admissibility of interest on non-interest credit costs and the information obligations incumbent on financial
institutions in this regard (C-566/24, C-744/24 and C-473/25),
• the interpretation of the one-year time limit for declaring use of the free credit sanction (C-566/24),
• the scope of the consumer’s information on the early repayment procedure (C-566/24, C-831/24) and the consumer’s
right of withdrawal (C-566/24),
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• examination by the court of its own motion of the creditor’s infringement of provisions other than those specified in the
declaration of use of the free credit sanction (C-831/24),
• the application of the free credit sanction in the light of the principle of proportionality (C-566/24, C-831/24, C-684/25),
• the mutual relation of unfair terms of contracts and the free credit sanction (C-429/25, C-684/25) and information
obligations of the Court versus the consumer in this regard (C-684/25),
• the admissibility of the free credit sanction where the financial institution formally performed the information obligation
but the information provided to consumers was erroneous or unclear (C-473/25),
• the admissible method of phrasing the modification clause on fees and commissions reserved in the agreement and the
grounds for the free credit sanction in the case of minor irregularities to this extent which do not affect the consumer’s
decision to enter into the agreement (case C-684/25).
On 24 October 2024, the Court of Justice (EU) passed its judgment in Case C-339/23 (Horizon). The CJEU ruled that the
provisions of Directive 2008/48/EC of the European Parliament and of the Council of 23 April 2008 on credit agreements for
consumers and repealing Council Directive 87/102/EEC (“Directive 2008/48”) allow the Member States to introduce various
sanctions for failure to carry out a consumer credit assessment and for breach of the information obligations set out in the
Directive. The CJEU did not analyse the Polish legislation or identify a specific sanction for breaching the obligation to carry
out a consumer creditworthiness assessment, noting that the choice of sanctions is up to the Member State, provided that
they are effective, proportionate and dissuasive. In Article 45 u.k.k., the legislator did not provide for the possibility of
applying a free credit sanction for a bank’s breach of its obligation to examine the consumer’s creditworthiness.
On 13 February 2025, the CJEU passed its judgment in case C-472/23 concerning the impact of an overstated annual
percentage rate of charge (due to terms providing for interest on non-interest costs being declared unfair) on an
infringement of the information obligation by the creditor which may result in the application of the free credit sanction,
the rules for phrasing of clauses providing the terms of adjusting fees and commissions, the proportionality of national
legislation providing for a uniform sanction for each infringement of information obligations. The CJEU ruled that:
1. the fact that a credit agreement refers to an annual percentage rate of charge, which proves to be overstated because
certain terms of that agreement are subsequently found to be unfair, does not constitute, in itself, an infringement of the
creditor’s obligation to provide information which may result in the application of the free credit sanction;
2. the provisions of the loan agreement which provide for a change in the fees paid under the agreement should be worded
in a clear and understandable way so that a reasonably well-informed and reasonably observant and circumspect
consumer is in a position to ascertain whether circumstances justifying an increase in the costs have arisen and their effect
on those costs;
3. the principle of proportionality of sanctions does not preclude national legislation which provides for a uniform penalty
in the event of an infringement of the creditor’s information obligation, consisting of depriving the creditor of its right to
interest and charges, irrespective of the individual level of seriousness of such an infringement, where that infringement is
capable of calling into question the possibility for the consumer to assess the extent of his or her liability.
On 9 October 2025, the CJEU passed a judgment in case C-80/24 concerning the admissibility of a claim assignment arising
from a consumer credit contract and the obligation of the court to examine the assignment of its own motion to check
whether its terms are unfair. The CJEU ruled that Directive 2008/48 does not preclude national legislation that allows a
consumer to assign a claim arising from the infringement of a right conferred on him or her to a third party which is not a
consumer and that Directive 93/13 must be interpreted as meaning that a national court is not required to examine of its
own motion the unfairness of a term in a claim assignment agreement concluded where the dispute does not concern that
assignment agreement, but the consumer’s claim against that seller or supplier.
The interpretation of the provisions on the free credit sanction is also the subject of legal issues referred for consideration
by the Supreme Court, concerning: the obligation of the court to examine of its own motion all circumstances which justify
the application of the free credit sanction (including other than those indicated in the content of the declaration submitted
by the consumer on the use of the free credit sanction), the interpretation of the one-year time limit for the submission of
the declaration on the use of the free credit sanction, the mutual relation of unfair terms and the free credit sanction, as
well as the admissibility of interest on non-interest costs and the possibility of applying the free credit sanction on this
account (ref. III CZP 3/25 and III CZP 15/25). The Supreme Court has suspended these cases as long as the cases referred by
Polish courts to the CJEU are pending.
Compliance with other regulations
In 2025:
• no court or administrative proceedings concerning behaviours infringing free competition or antitrust regulations were
initiated against the Bank or the Group,
• in the area of personal data protection, the Group companies did not receive any substantiated complaints regarding data
leaks, theft or loss,
• no instances of non-compliance with regulations and/or voluntary codes relating to marketing communications (including
advertising, promotion and sponsorship) were recorded,
• no monetary fines or non-financial sanctions for non-compliance with environmental laws and/or regulations were
recorded.
Selected changes to legislation applicable to the banking sector
Changes which took effect in 2025
• Act of 26 April 2024 on ensuring that economic operators comply with accessibility requirements for certain products and
services;
• Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational
resilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014,
(EU) No 909/2014 and (EU) 2016/1011;
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• Act of 25 June 2025 amending certain acts in connection with ensuring the digital operational resilience of the financial
sector and the issuance of European green bonds (Journal of Laws 2025, item 1069);
• Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules
on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU)
2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (the
Artificial Intelligence Act);
• Act of 20 December 2024 on credit servicers and credit purchasers (Journal of Laws 2025, item 146).
Events after the balance sheet date
January 2026
• 7.01. – Registration in the National Court Register of the amendments to the Articles of Association of BNP Paribas Bank
Polska S.A. adopted at the Extraordinary General Meeting of the Bank on 27 November 2025.
February 2026
• 11.02. – Intention of the Bank’s Management Board regarding the dividend payment from the 2025 net profit
The Management Board of the Bank announced that it will request the General Meeting to adopt a resolution allocating
approximately 50% of the Bank’s standalone net profit for 2025 to dividend distribution.
As at the date of providing this information, the Bank meets the criteria and requirements of the Polish Financial
Supervision Authority (“KNF”) that allow for the payment of up to 75% of the 2025 profit in the form of a dividend; however,
the Bank has not yet received an individual dividend recommendation from the KNF.
The proposed dividend amount takes into account the Bank’s current financial position and its development plans.
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Statements of the Management Board of BNP Paribas Bank Polska S.A.
Accuracy and reliability of the statements presented
The Management Board of BNP Paribas Bank Polska S.A. hereby declares that to the best of its knowledge:
• The Separate Financial Statements of BNP Paribas Bank Polska S.A. for the year ended 31 December 2025 and the
Consolidated Financial Statements of the BNP Paribas Bank Polska S.A. Group for the year ended 31 December 2025 and
the comparative data have been prepared in accordance with the applicable accounting principles and give a true, fair
and clear view of the financial position and financial performance of the Bank and the Group.
• The Management Board’s Report on the Activities of the BNP Paribas Bank Polska S.A. Group in 2025 (including the Report
of the Management Board on the Activities of BNP Paribas Bank Polska S.A. in 2025 and the Sustainability Statement of
the BNP Paribas Bank Polska S.A. Group for 2025) provides a true picture of the development, achievements and situation
of the Group, including a description of the principal risks and threats.
Position of the Bank’s Management Board on the possibility of meeting previously published forecasts
for a given year
• The Bank has not published financial performance forecasts for 2025.
Information of the Management Board, prepared on the basis of a statement of the Supervisory Board
or a supervising person, on the selection of an audit firm to audit the annual financial statements and
the annual consolidated financial statements and to provide assurance for sustainability reporting in
accordance with applicable regulations
The Management Board of BNP Paribas Bank Polska S.A. declares that Ernst & Young Audyt Polska spółka z ograniczoną
odpowiedzialnością sp.k. based in Warsaw (Ernst & Young) was selected by the Bank’s Supervisory Board pursuant to the
provisions of the law as the entity authorised to:
• audit the Consolidated Financial Statements of the BNP Paribas Bank Polska Group for 2025 and the Separate Financial
Statements of BNP Paribas Bank Polska S.A. for 2025 (decision of the Supervisory Board of 15 September 2023),
• provide assurance for the sustainability reporting of the BNP Paribas Bank Polska Group for 2025 (decision of the
Supervisory Board of 22 September 2025).
The Management Board confirms that Ernst & Young and the members of the audit and assurance team met the all the
conditions of impartiality and independence necessary to prepare an independent audit report on the annual financial
statements and the annual consolidated financial statements and assurance of sustainability reporting in accordance with
applicable regulations, professional standards and professional ethics.
The Bank’s Management Board declares that the Bank complies with the applicable legal provisions concerning the
rotation of the audit firm and the key auditor and mandatory grace periods and that the Bank has in place internal
regulations in this regard including:
• the "Policy on the selection of the audit firm at BNP Paribas Bank Polska S.A.",
• the "Procedure for the selection of the audit firm at BNP Paribas Bank Polska S.A.",
• the "Policy on the provision of permitted non-audit services at BNP Paribas Bank Polska S.A. by the audit firm, by
affiliates of the audit firm and by members of the audit firm’s network".
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SIGNATURES OF THE MEMBERS OF THE MANAGEMENT BOARD OF BNP PARIBAS BANK POLSKA S.A.
4.03.2026
Przemysław Gdański
President of the Management Board
signed with a qualified electronic signature
4.03.2026
Małgorzata Dąbrowska
Vice-President of the Management Board
signed with a qualified electronic signature
4.03.2026
Wojciech Kembłowski
Vice-President of the Management Board
signed with a qualified electronic signature
4.03.2026
Piotr Konieczny
Vice-President of the Management Board
signed with a qualified electronic signature
4.03.2026
Magdalena Nowicka
Vice-President of the Management Board
signed with a qualified electronic signature
4.03.2026
Volodymyr Radin
Vice-President of the Management Board
signed with a qualified electronic signature
4.03.2026
Natalie Yacoubian
Vice-President of the Management Board
signed with a qualified electronic signature