2023 SUSTAINABILITY REPORT
OF XTB S.A. CAPITAL GROUP
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XTB S.A. CAPITAL GROUP
SUSTAINABILITY REPORT FOR 2023
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Table of contents
1. ABOUT THE XTB S.A. CAPITAL GROUP .................................................................................................................5
1.1. BUSINESS PROFILE .................................................................................................................................................5
1.2. STRATEGY AND BUSINESS MODEL ............................................................................................................................7
1.3. VALUE CHAIN OF XTB S.A. CAPITAL GROUP ......................................................................................................... 12
1.4. BODIES OF THE COMPANY AND GROUP ................................................................................................................ 13
1.5. ORGANISATIONAL STRUCTURE ............................................................................................................................. 16
2. XTB BUSINESS ACTIVITY .................................................................................................................................... 19
2.1. RESPONSIBILITY TOWARDS THE MARKET ............................................................................................................... 19
2.2. XTB’S PRODUCTS AND SERVICES .......................................................................................................................... 20
2.3. DEVELOPMENT AND INNOVATION ........................................................................................................................ 23
3. OUR EMPLOYEES ............................................................................................................................................... 26
3.1. DIALOGUE WITH EMPLOYEES ............................................................................................................................... 27
3.2. DIVERSITY .......................................................................................................................................................... 28
3.3. XTB'S HR POLICY .............................................................................................................................................. 29
3.4. EMPLOYMENT CONDITIONS ................................................................................................................................. 29
3.5. EMPLOYMENT STRUCTURE ................................................................................................................................... 32
3.6. EMPLOYEES' DEVELOPMENT ................................................................................................................................ 37
3.7. CAREER AT XTB .................................................................................................................................................. 40
3.8. OCCUPATIONAL HEALTH AND SAFETY ................................................................................................................... 40
4. SOCIAL RELATIONS ............................................................................................................................................ 42
4.1. RELATIONS WITH STAKEHOLDERS ......................................................................................................................... 42
4.2. OUR CLIENTS ..................................................................................................................................................... 43
4.3. OUR SUPPLIERS.................................................................................................................................................. 44
4.4. COOPERATION WITH CONTRACTORS .................................................................................................................... 44
4.5. XTB’ CHARITY ACTIVITY ....................................................................................................................................... 45
4.6. XTB FOUNDATION ............................................................................................................................................. 45
5. IMPACT ON THE ENVIRONMENT AND CLIMATE CHANGE ...................................................................................... 48
5.1. ENVIRONMENTAL EDUCATION PROGRAMME "NATURAL INVESTMENT" .................................................................... 49
5.2. WASTE DISPOSAL ................................................................................................................................................ 50
5.3. CONSUMPTION OF UTILITIES ................................................................................................................................ 50
5.4. BIODIVERSITY ..................................................................................................................................................... 51
5.5. GHG EMISSIONS ................................................................................................................................................ 52
5.6. OTHER ENVIRONMENTAL ISSUES .......................................................................................................................... 52
5.7. EU NON-FINANCIAL TAXONOMY .......................................................................................................................... 53
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6. CORPORATE GOVERNANCE ................................................................................................................................ 62
6.1. XTB’S REGULATIONS AND PROCEDURES................................................................................................................ 62
6.2. BUSINESS ETHICS ............................................................................................................................................... 63
6.3. COUNTERACTING CORRUPTION ............................................................................................................................ 64
6.4. WHISTLEBLOWING .............................................................................................................................................. 64
6.5. PUBLIC AID ........................................................................................................................................................ 64
6.6. DATA PROTECTION ............................................................................................................................................. 65
6.7. RISK MANAGEMENT SYSTEM ............................................................................................................................... 65
6.8. RISK REGARDING NON-FINANCIAL ISSUES .............................................................................................................. 65
7. ABOUT THE REPORT ........................................................................................................................................... 67
7.1. LEGAL BASES ...................................................................................................................................................... 67
7.2. SIGNIFICANCE ..................................................................................................................................................... 67
7.3. PERFORMANCE TABLES - NON-FINANCIAL TAXONOMY ........................................................................................... 69
7.4. COMPLIANCE TABLE ............................................................................................................................................ 85
7.5. APPROVAL FOR PUBLICATION BY THE MEMBERS OF THE MANAGEMENT BOARD OF XTB S.A. ................................... 86
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XTB S.A. CAPITAL GROUP
SUSTAINABILITY REPORT FOR 2023
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XTB S.A. CAPITAL GROUP
SUSTAINABILITY REPORT FOR 2023
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1. About the XTB S.A. Capital Group
1.1. Business profile
XTB S.A. is one of the largest listed Forex and CFD brokers, building experience
in the investment industry for 20 years.
Our subsidiaries and foreign branches, together with the parent company,
form XTB S.A. (hereinafter: “XTB”, “Company”) international capital group.
Since 2016, XTB S.A. is listed on the regulated market of the Warsaw Stock
Exchange. Since December 2020, XTB's stocks have been WIG-ESG index-listed.
Our ambition is to offer the best All-in-One investment application in Europe, so that XTB Clients have the opportunity
to invest online in anything, at any time and in any way. We want to build solutions that will allow anyone interested
in investing to achieve their investment goals, regardless of their experience and knowledge. We support our Clients
through education and market analyses.
Functionality of the offer of the XTB S.A. Capital Group (hereinafter referred
to as: “Group”, “Capital Group”, “XTB Group”) provides Clients with immediate
access to financial markets around the world. The basic technology
of XTB Group uses software designed to ensure functionality and scalability.
We provide our Clients with the opportunity to invest online using trading
platforms: xStation 5, which is supported by advanced technological
infrastructure, and MetaTrader4 (platform offered to new Clients until
18 January 2021).
We are an international supplier of products, services and technological solutions in the scope of trade in financial
instruments. We specialise in the OTC market and, in particular, CFD (Contract for Difference) derivatives. These
are investment products whose return depends on changes in the price and value of the instruments and underlying
assets. We also offer investments in shares and ETF instruments on the same trading platform. Our offer includes
speculative products (CFDs), investment products (securities and ETFs) as well as Investment Plans which are a set
of so-called passive investing solutions.
For more information on the XTB Group’s portfolio, see chapter 2.2. Products and services of this Report.
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XTB Group’s activity segments:
In 2023, the retail activity segment generated ca. 93% of the Group’s total operating revenues, while the institutional
activity segment - ca. 7%. We define both segments as follows:
• The retail activity of the Group includes online trade in, securities, ETFs and derivatives based on underlying
assets and instruments traded on financial and commodity markets, serving mostly retail Clients.
• The Group's institutional activities include providing liquidity to our institutional Clients and proposing
technologies thanks to which they can offer their Clients the possibility of trading in financial instruments under
their own brand.
Information on communication with customers in relation to the above business segments can be found in chapter
4.2. Our Clients of this Sustainability Report.
The business of XTB Group is regulated and subject to oversight of competent authorities on the markets where
the Group operates, including EU Member States, on the basis of the so-called single European passport.
Education and support
In addition to investment tools, we provide our Clients with professional support from XTB Experts.
We constantly strive to build valuable relationships with Stakeholders based on, inter alia,
the highest level of customer service, availability and quality of offered products and services.
We believe in the far-reaching advantages of financial education as a basis for the development of society. That is why
we promote financial education among our Stakeholders, regardless of their experience in this field. We offer access
to free, professional XTB Investing Masterclass courses and conferences, daily market analyses
and the InvestResponsibly.com platform.
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1.2. Strategy and business model
[G.1.1.] The foundation of our approach to both business and ESG aspects is taking care
of relationships with Stakeholders. Thanks to this, our activities in every dimension are consistent
and effective. We do not stop striving to constantly develop and improve our activities. The business
strategy of the XTB Group, which assumes comprehensive development of our activities,
is complemented by the assumptions of the ESG strategy giving it a sustainable direction.
Business model
[G.1.2.] Our business model evolves as the organisation grows. At XTB, we place great emphasis on geographical
diversification of revenues, consistently implementing the strategy of building a global brand. The Management Board's
priority in the coming periods is to further develop the Client base and strengthen the market position of XTB worldwide.
We are more and more boldly marking our presence on non-European markets and, therefore, we anticipate further
development of the capital group structure with new subsidiaries.
We want to reach individual customers with our product offer through such activities as expansion of the product offer
and promotional campaigns. The Management Board's ambition in 2024 is to acquire on average at least
65-90 thousand new Clients quarterly.
Over the last few years, XTB has been transformed from a CFD broker into a provider of a universal All-in-One
investment application offering Clients easy, intelligent and efficient ways of executing transactions, investing
and saving, while providing immediate access to accumulated funds. Our intention is to continue activities in this area.
As a FinTech
1
, we continuously work on developing highly innovative, comprehensive solutions in the field
of transactions and online investments in financial instruments. The purpose of the above-mentioned activities
is to develop innovative technologies and solutions enabling, in particular, further development of the product offer.
We are the owner of a number of proprietary technological solutions, including the modern xStation trading platform.
The research and development works carried out in 2023 were aimed at developing tools necessary for the efficient
functioning of XTB's trading systems, effective order execution, efficient process of acquiring new Clients
(so-called onboarding) and further development of tools supporting the internal processes of the organisation
adequate to the identified development needs.
For a detailed description of our research and development activity, see chapter 2.3. Development and innovation of this
Sustainability Report.
There were no major changes in the business model of XTB Group in the analysed year.
1
FinTech - a technological entity operating in the finance sector.
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Business strategy
As a Polish FinTech company, we constantly develop our own technologies, striving to expand our product portfolio.
In the adopted business strategy, we have set the following directions for the development of the XTB Group's activities,
both on a local and global scale:
• Strengthening XTB's position on already conquered markets.
• Further expansion of XTB into new markets.
• Development of the institutional business segment (X Open Hub).
• Expanding the offer of XTB Group products and services and developing new technologies.
• Development through beneficial mergers, acquisitions and joint ventures.
We develop through innovation and bold decisions based on the foundations of prudent and conscious management.
A well-thought-out organisational and decision-making structure allows us to effectively respond to the challenges
of the changing environment, including taking opportunities and mitigating threats. This entire process and its effects
are the result of the synergy of effective management and the extensive competences of our Employees. At XTB, nothing
happens by chance, each process is covered and not neglected.
We build our organisational culture based on values, i.e.:
Over 20 years of operation, nearly 900,000 Clients have trusted us, and the employment level in the XTB Group
exceeded the mark of 1,000 Employees and associates in the second half of last year. However, we have not said
the last word, both values are still growing. We do not stop developing relationships with Stakeholders, transparent
communication and improving the quality of the products and services offered. Internally, we make every effort
to ensure that our Employees, regardless of the office location, feel appreciated and important in the XTB Team.
We support diversity, which we see as a potential for development for the entire organisation.
XTB experts are available 24 hours a day, five days a week to support our Clients when they need it most. We share our
knowledge by providing educational materials for the development of Stakeholders, regardless of their level
of advancement. We also support our Employees, not only by providing them with the tools needed to perform their
professional duties, but also by providing them with access to training, supporting their development, promoting
a healthy lifestyle, sports activity and proper eating habits. We also support our Employees, not only by providing them
with the tools needed to perform their professional duties, but also by providing them with access to training,
supporting their development, promoting a healthy lifestyle, sports activity and proper eating habits.
We fully understand technology as one of the most important elements of investing through XTB. Therefore,
we constantly improve our application in line with customer expectations, adapting it to emerging industry challenges.
We believe that xStation is one of the most reliable and functional applications on the market. It allows to access
a variety of investment options from a wide range of devices. In order to ensure high quality of services provided, access
and quality of the platform is verified continuously from several locations located in different regions around the world.
In addition, the platform uses and provides analytical tools enabling investors to assess companies' performance
in the field of sustainable development, adjust the strategy to their values and make informed investment choices.
Technology also accompanies us every day in our organisational culture. We appreciate and support the creativity
and innovation of our Team, giving it the opportunity to develop and implement its own initiatives.
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ESG strategy
In the last quarter of 2021, we adopted the ESG Strategy complementing the XTB Group's business
strategy. In 2023, we continued the activities undertaken earlier, while striving for continuous
development and achievement of the set goals. We believe that various initiatives in the area
of sustainable development will allow us to build long-term and effective awareness among
our Stakeholders. The intention of XTB is continuous increase of involvement in corporate social
responsibility projects. The full content of the document is available on the investor relations subpage
of XTB S.A. at: https://ir.xtb.com/en/esg/
Our ESG Strategy is based on three pillars:
Environment and counteracting climate change
As part of the area of environment and counteracting climate change, in 2023 we continued the actions
we had already taken, including: waste sorting, document digitization and server virtualization in order
to reduce the energy consumption of our IT infrastructure.
At the beginning of 2022, we moved the headquarters of XTB S.A. to the modern Skyliner office building with a BREEAM
Certificate at the Excellent level, which affects many solutions that we can share with you today:
✓ In 2023, almost all of the electricity consumed by Skyliner came from renewable energy sources.
Proportionally to the energy used in the entire building, the energy consumed by XTB in the rented space can
also be considered as originating from renewable sources. Energy consumption is reduced by energy-saving
LED lighting used in the building.
✓ Current water consumption is reduced thanks to the aerators installed in the taps and a system of photocells
that automatically regulate the water stream depending on the need.
✓ The very well-connected location of the XTB headquarters encourages our Employees to commute less
frequently by passenger cars in favour of public transport: metro, trams, buses. Employees commuting
to the XTB headquarters on bicycles have the option of leaving their bicycles in a separate area of the
underground car park of the office building using the available bicycle racks.
In order to reduce the energy consumption of our IT infrastructure in the long term, despite the dynamic development
of our business, we are gradually replacing older, energy-consuming servers with new, more energy-efficient servers
delivered by certified suppliers from the European Union. In addition to increased energy efficiency,
they are characterised by modern solutions such as intelligent adjustment of energy consumption to the load,
which also translates into electricity savings.
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Moreover, for the last two years we have intensified our activities regarding server virtualization, where we can embed
many other virtual servers on one physically owned server. Over the last two years, we have reduced the number
of physical servers by 15%, while increasing the number of virtual servers by as much as 72.34%.
In order to include climate risks in the internal risk management system, we plan to undertake a project to analyse
climate opportunities and risks of the XTB S.A. Capital Group in the upcoming reporting periods, which will also
constitute the basis of our future Climate Policy.
In order to counteract climate change and strive to develop social responsibility among our Employees,
as part of the XTB Foundation, we undertook a key initiative in 2023, which was planting an XTB forest
in cooperation with “Las na Zawsze” [Forest Forever] Foundation. Together we planted over 2,000 trees,
thus, giving nature back 1.2 ha of a biodiverse deciduous forest in Mieleszkowce Pawłowickie, Podlaskie
Voivodeship. The campaign was met with great enthusiasm of our Employees who had the opportunity
to participate in the project and build their environmental awareness as part of the volunteer day.
The forest we plant is a self-regulating complex ecosystem that should be seen as:
• CO
2
storage;
• soil stabiliser;
• water reservoir;
• place of existence of organisms;
• biodiversity sanctuary;
• oxygen producer.
In 2023, we also continued the "Natural Investment" programme, which we describe in more detail
in chapter 5.1. Environmental education programme "Natural Investment" of this Sustainability Report. Its aim is to
increase the awareness of our Employees regarding energy efficiency, waste sorting, digitization of documents,
reasonable food management, increasing the number of plants in the office, etc.
In order to effectively monitor greenhouse gas emissions, we have been examining our emission intensity in Scope 1
and Scope 2 for three years. We also plan to expand our observations to include Scope 3, the effects of which we will
want to share with our Stakeholders in the upcoming reporting periods.
Social responsibility
As part of the area of social responsibility, in the year under review we addressed our activities to a diverse
group of recipients. We have expanded our portfolio with new products in response to the needs
of our lients, while ensuring immediate access to financial markets from around the world. In 2023,
we entered into strategic cooperation with the Association of Individual Investors in order to raise
the standards of the functioning of the financial market in Poland and appoint the Ombudsman for
Individual Investors.
We also continued XTB educational programmes, including: organising the next edition of the IT Academy internship
at XTB (for more information, see chapter 3.6. Development of the Employees of this Sustainability Report) and engaging
in various academic projects. In 2023, we had the honour of being a partner of the first edition of the National Stock
Exchange Competition "Young Investor" of the Department of Economics and the Department of Finance of the Faculty
of Economic Sciences of the Koszalin University of Technology. The competition gathered almost 600 secondary school
students from all over Poland who had the opportunity to test their investment skills and expand their knowledge
of the capital market.
As part of our charitable activities, we helped those affected by the earthquake in Turkey and Syria by providing funds
in cooperation with UNICEF. Moreover, our Employees were once again involved in the Noble Gift Campaign
and we played with the Great Orchestra of Christmas Charity.
We also joined the 2 Hours for Family campaign and organised a number of internal initiatives, including an integration
picnic for our Employees, Children's Day at XTB and Coffee Day. With the well-being of our Team in mind, in 2023
we started cooperation with the well-being platform provider "Helping Hand", enabling participation in webinars, events
and specialist advice sessions at the Employee’s discretion.
By supporting our Employees in fulfilling their various life roles, we provide them with the opportunity to flexibly start
their working day between 7:00 a.m. and 10:00 a.m. They also have a number of non-wage benefits at their disposal,
such as private medical care, subsidised meals, etc.
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Corporate Governance
As part of the corporate governance pillar, we continue our activities based on transparent information
provided to the market, development of our product portfolio, attention to its highest quality and,
as a result, trust of our Stakeholders. Our intention is to further develop the area of sustainable
development at XTB. For this purpose, we have expanded our organisational structure with a dedicated
ESG Team reporting directly to the Member of the Management Board and the Chief Financial Officer
of XTB S.A..
We care about the quality of processes within our organisation, and on a daily basis we are guided by the principles
of the applicable Code of Ethics of the XTB S.A. Capital Group. Our organisational structure has a separate internal audit
unit and a division responsible for the risk management system in the XTB S.A. Capital Group and managed
by the Member of the Management Board for Risk.
In addition to the above, legal and compliance issues are supervised by a legal team managed by a Member
of the Management Board for Legal Affairs.
Transparent and reliable communication with our Stakeholders is crucial in the activities we carry out from many
perspectives. As an issuer of securities on the Warsaw Stock Exchange, we exercise due diligence regarding
confidentiality, security, transparency and equal access to information on the capital market. Moreover,
as an international Capital Group employing Employees from all over the world, we are aware of the need
for continuous development in the field of our multilingual and multicultural internal communication. We communicate
via mailings, via the intranet platform and, as of 2023, via a modern communication platform, which can be adapted
to 16 different foreign languages. All messages sent are bilingual - in Polish and English. In addition, we support
our Employees with training that develops their language skills depending on their adaptation needs and the specific
nature of work on the given position.
Our subsidiaries and foreign branches demonstrate a number of activities in the area of sustainable development,
including:
• relocation of the office of the German branch of XTB S.A. in September 2023 to a building awarded the Gold
Certificate of the DGNB GmbH certification system in November 2020. This system is based on three main areas
of sustainability: ecology, economics and socio-cultural quality, which are equally weighted in the assessment;
• change of location of the office of the French branch of XTB S.A. to a building characterised by high
environmental quality (HQE);
• introduction of the well-being programme "YEES!" in branches in Spain and Portugal, which allows Employees
to use podcasts and specialist advice according to their needs. These branches are also involved in charitable
activities, e.g. in cooperation with foundations, and their Employees share their investment knowledge during
lectures and seminars.
At the beginning of 2024, we started projects in the area of sustainable development, including updating
of the ESG Strategy, conducting a double materiality study, preparing for reporting based on the European Sustainability
Reporting Standards (ESRS), or analysing the carbon footprint in the broadest Scope 3. For more details
on the above-specified initiatives in the ESG areas, see dedicated chapters of this Report.
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1.3. Value chain of XTB S.A. Capital Group
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1.4. Bodies of the Company and Group
[G.2.] Corporate Governance
As at 31.12.2023, the XTB S.A. Capital Group consisted of the parent company XTB S.A. as well as 12 subsidiaries
and 7 foreign branches.
Activities of XTB S.A. are regulated by such documents as:
• Articles of Association of XTB S.A.
• Management Board Regulations
• Supervisory Board Regulations
• General Assembly Regulations
All of the above documents constituting the Company's corporate governance are publicly available on the investor
relations subpage in the Corporate Governance tab at: https://ir.xtb.com/en/
[G.2.1.] [G.2.3.] Management structure
Management Board of XTB S.A.
As at 31.12.2023 and as at the date of publication of this Report, the composition of the Company's Management Board
remained unchanged:
Omar Arnaout Filip Kaczmarzyk Paweł Szejko Jakub Kubacki Andrzej Przybylski
Board President Board Member Board Member Board Member Board Member
for trading for finance for legal affairs for risk
Table No. 1. Composition of the Management Board of XTB S.A. as at 31.12.2023 and as at the day of publication
of this Report.
NAME AND SURNAME
COMMENCEMENT DATE
OF THE FIRST TERM
OF OFFICE
END DATE
OF THE CURRENT
TERM OF OFFICE
Omar Arnaout
10.01.2017
01.07.2025
Filip Kaczmarzyk
10.01.2017
01.07.2025
Paweł Szejko
28.01.2015
01.07.2025
Jakub Kubacki
10.07.2018
01.07.2025
Andrzej Przybylski
01.05.2019
01.07.2025
The current composition of the Management Board of XTB S.A. was appointed on 2 June 2022 by the resolution
of the Supervisory Board of the Company on the appointment of the current five-person composition
of the Management Board of XTB S.A. for the new joint three- year term of office (from 1 July 2022 to the end of 1 July
2025).
In the reviewed reporting period, in the current term of office of the Management Board of XTB S.A. men accounted
for 100% of the Company's governing bodies.
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Supervisory Board of XTB S.A.
As at 31.12.2023 and as at the date of publication of this Report, the composition of the Company's Supervisory Board
remained unchanged:
Table No. 2. Composition of the Supervisory Board as at 31.12.2023 and as at the day of publication of this Report.
NAME AND SURNAME
FUNCTION
COMMENCEMENT
DATE OF THE CURRENT
TERM OF OFFICE
END DATE
OF THE CURRENT
TERM OF OFFICE
Jan Byrski
Chairman
of the Supervisory Board
22.11.2021
19.11.2024
Jakub Leonkiewicz
Member of the Supervisory Board
19.11.2021
19.11.2024
Łukasz Baszczyński
Member of the Supervisory Board
19.11.2021
19.11.2024
Bartosz Zabłocki
Member of the Supervisory Board
19.11.2021
19.11.2024
Grzegorz Grabowicz
Member of the Supervisory Board
19.11.2021
19.11.2024
In the reviewed reporting period, in the current term of office of the Supervisory Board of XTB S.A. men accounted
for 100% of the Company's governing bodies.
Supervisory Board Committees
The following committees operate within the Supervisory Board:
• Audit Committee;
• Remuneration Committee;
• Risk Management Committee.
The Supervisory Board, pursuant to a resolution adopted by it collectively, performs the tasks of the Remuneration
Committee and the Risk Management Committee. Since 13 October 2017, the Audit Committee has operated
as a separate committee. The Supervisory Board may also appoint other committees. Detailed tasks and rules for
appointing and operating committees are specified in the Regulations of the Supervisory Board available on the XTB
website at: https://ir.xtb.com/ in the Corporate Governance, Regulations tab. Detailed information regarding the
composition of the above-mentioned committees are included in the Management Board's Report on the operations
of the XTB S.A. Capital Group.
Shareholding structure of XTB S.A.
The main shareholder of XTB S.A. is XXZW Investment Group S.A. based in Luxembourg which as at 31 December 2023
held 60.93% of shares and votes at the General Meeting.
The highest-level parent entity in relation to the Company and XXZW Investment Group S.A. is Mr Jakub Zabłocki,
founder of XTB S.A.
In accordance with the notice of change in the Company's voting share received from XX ZW Investment Group S.A.
of 8 February 2024 and current report No. 6/2024, as at the date of publication of this Report, the shareholder structure
of XTB S.A. was as follows:
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Chart No. 1. Shareholding structure as at the date of publication of this Report.
Management of the sustainable development area
For the first time, the issues of XTB's sustainable development were addressed in the ESG report in 2021.
We identify this area as important and take actions to further develop it.
Direct supervision over the activities of the sustainable development area within the Group is performed
by the Management Board of XTB S.A., which sets goals and coordinates the non-financial reporting process
in accordance with the adopted standards. Within the organisational structure of the parent company, a separate
ESG Team was established in 2023, whose Employees report directly to the Chief Financial Officer and Member
of the Management Board for Finance of XTB S.A.
The duties of the ESG team include, without limitation:
• comprehensive coordination of the sustainable reporting process,
• monitoring social and environmental aspects of activities,
• cooperation with the Group's business areas to develop sustainable operations,
• initiating and implementing sustainable development projects of the XTB Group and the XTB Foundation,
• monitoring XTB's ESG strategy,
• adapting and developing the Company's internal regulations in the ESG area.
As part of the activities of XTB S.A., there is an internal audit unit verifying the Group's sustainable development reports,
reporting to the highest company structures, and a risk management department coordinating the XTB S.A. Risk
Management System.
In addition, sustainable development issues are the subject of work by individually selected working groups as part
of specific projects within the organisation within which committed Employees share their competences.
In 2024, we launched projects in the area of sustainable development, including conducting a double materiality study
of the XTB Group, preparing for reporting based on the European Sustainability Reporting Standards, or analysing
the carbon footprint in relation to the value chain.
50,93%
49,07%
XX ZW Investment Group S.A.
59 872 869
Pozostali Akcjonariusze
57 696 382
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1.5. Organisational structure
The Capital Group is headed by XTB S.A. It is responsible for management processes and coordinates the activities
of companies and branches of the Group. It sets development goals for businesses operating in individual countries,
establishes budgets and financial goals, standards of conduct and supervises their achievement.
Subsidiaries and branches employ from several to several dozen persons. Thus, the vast majority
of operational processes are carried out at XTB in Poland. The activity of subsidiaries and foreign
branches, in principle, supports the sale and ensures compliance with local regulations required
for the conducted business. Both in Poland and in other countries, the Group conducts its business
in rented properties only. These include office space and IT infrastructure space.
We have offices in several countries. In the coming year, we plan to expand our operations to additional markets.
We identify the following as key to our operating activities:
• processes related to providing users with their own IT technology, for which the IT department of XTB S.A.
is responsible, and
• processes related to Client acquisition and support are conducted both directly by XTB in Poland as well
as through branches and subsidiaries operating on the local markets.
The most important processes in the area of sustainable development are undertaken and implemented at XTB S.A.
Due to the high degree of independence of the Group's subsidiaries, creating extensive corporate solutions
and dedicated policies for individual subsidiaries should be considered ineffective. Therefore, the identification
of significant management areas and the risks associated with them is carried out at the level of XTB S.A. in consultation
with individual organisational units operating in subsidiaries. This process is related to the continuous assessment
of impact on the surrounding and the risk connected with individual areas of interaction with Stakeholders.
Furthermore, the assessment takes into consideration on-going changes (including but not limited to legal, economic
and social changes) in the surrounding. These aspects are identified and assessed in detail in accordance
with the relevant procedures regarding identification of threats and assessment of risk for the given area.
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As at 31 December 2023, the XTB S.A. Capital Group consisted of the parent company and its 12 subsidiaries.
Diagram No. 1: Organisational structure of the XTB S.A. Capital Group as at 31 December 2023, including the shares.
Until the date of publication of this Report, the following changes were noted in the structure of the XTB Group:
• On 17 January 2024, the parent company acquired 90% of shares in PT Rajawali Kapital Berjangka
based in Indonesia.
Moreover, XTB S.A. also conducts its business through 7 foreign branches, as shown below in Diagram No. 2.
Diagram No. 2: Foreign branches of XTB S.A. as at 31 December 2023.
The subsidiaries belonging to XTB Group take individual actions to meet the requirements of local regulations.
On the other hand, XTB is the addressee of information regarding effects of activities in specific ESG areas, including
but not limited to situations where these effects could result in breach of effective laws and related financial liability
or image-related repercussions. Therefore, according to the best knowledge, this Non-Financial Statement
does not omit any information that could have a significant impact on the reliability of description of the impact
of XTB Group on social issues, employment-related issues, natural environment, respect for human right, counteracting
corruption or climate-related issues.
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2. XTB Business activity
2.1. Responsibility towards the market
When providing our products and services to XTB Clients, we exercise due diligence to ensure that,
despite the global scale of our operations, we remain close to our Stakeholders. We want to develop
in accordance with the idea of sustainable development, providing only reliable and transparent data.
We are aware of our impact on the environment of the Capital Group, both in Poland and abroad.
Our intention is to build lasting relationships based on trust in the XTB brand. As a company listed on the main market
of the Warsaw Stock Exchange, we are subject to a number of legal regulations. Our business activities and designated
development directions are consistent with the values we represent. We listen and interpret signals
from the environment and, thus, adapt our product portfolio to the changing needs of our Clients.
The solid foundation of our business is a constantly growing customer base and the number of active Clients. Volatility
on financial and commodity markets and high inflation meant that trading in financial instruments in 2023 involved
new groups of Clients. As a result, in 2023, a record number of 311,971 new Clients trusted us (+58.5% y/y),
with the number of active Clients increasing by 51.0% y/y from 270,560 to 408,528 people. Such high scores indicate
the undeniable intensive development of our activities, but also a growing sense of responsibility towards our
Stakeholders.
The XTB Group operates in an environment characterised by high volatility. In addition to the SARS-CoV-2 virus
pandemic accompanying respective societies in recent years, since 24 February 2022, we have been observing a tense
geopolitical situation related to the armed conflict in the territory of Ukraine. Due to the still ongoing war on the eastern
border of Poland, the Management Board of XTB S.A. monitors its progress on an ongoing basis and analyses
its possible impact on the Group's operating activities.
As at 31 December 2023 and as at the date of publication of this Report, no circumstances have been identified
that could disrupt the continuity of the Company's operations.
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2.2. XTB’s products and services
Basic products and services
In 2023, we improved the processes of acquiring new Clients, optimising transaction costs (both for Clients
and the Company) and processes leading to the start of cooperation with XTB. We are also constantly developing
our trading platform, making it even more intuitive and easier to use.
Wanting to build value for our Stakeholders, we have expanded product portfolio, including but not limited
to Investment Plans that allow to invest savings in an intelligent way and earn interest on free funds on Clients' accounts.
Additionally, as of April 2023, we enable our Clients to invest on selected European and non-European markets
in company shares and ETFs for a fraction of their value. Fractional shares allow for greater flexibility and control over
investments. This gives you the ability to easily tailor your investment portfolio to suit one’s unique financial goals
and risk tolerance.
The XTB products proposed so far can be classified as follows:
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Table No. 3. Product portfolio of the XTB Group in 2023 due to the investment offer:
CFD
We offer clients access to over 2,000 CFD
contracts based on the price of company
shares and the price of ETF units listed on
regulated markets. We offer CFDs for:
ETFs, Raw Materials, Forex (Currencies),
Stocks, Cryptocurrencies,
Indices, Bonds where:
ETF - ETF CFD is an instrument that reflects the price movements
of an investment fund. Thanks to ETF CFD, clients can easily achieve
long-term investment goals by creating a diversified investment
portfolio. Additionally, they can multiply the value of the position using
financial leverage.
Raw materials - the most popular raw materials on financial markets
include gold, silver and oil. CFDs whose underlying instruments are
raw materials allow to speculate on the prices of raw materials, betting
on price increases or decreases. XTB offers selection of nearly 30 raw
material-based CFD instruments.
Forex (Currencies) - (Foreign Exchange Market) is an international
decentralised currency market. Trading on the Forex market takes
place continuously from 11 p.m. on Sunday to 10 p.m. on Friday.
XTB offers ca. 500 CFD instruments based on currency pairs.
Stocks - the stock offer at XTB is complemented by the possibility
of executing CFD transactions based on stock prices. The client decides
whether he/she wants to build an investment portfolio by becoming
a stockholder or take advantage of the speculative nature of CFDs
on shares.
Cryptocurrencies - cryptocurrencies are a form of digital currency.
XTB offers a CFD instrument which means that you do not need to
physically purchase the cryptocurrency, you just need to speculate on
future price changes without owning the underlying instrument. XTB
makes available ca. 40 cryptocurrency-based CFD instruments.
Indices - CFDs on indexes are derivatives based
on the biggest stock indices. By executing a transaction, the Client does
not acquire the underlying instrument (stock index), but speculates
whether its price will increase or decrease. XTB offers over 30 CFD
instruments based on indices from the entire world: USA, Germany,
China.
Bonds - CFD instruments based on the prices of the futures contract
for a 10-year bond of the United States government listed on the CBOT
exchange and for a 10-year bond of the German government listed on
the Eurex exchange.
Stocks
Stocks are equity securities that give their holders certain corporate
and property rights (e.g. the right to participate in the company's
general meeting, dividends, participation in the division of assets in the
event of liquidation of the company). The subject of organised trade
are stocks without a tangible form. Stocks may be characterised with
high volatility of quotes, both in short- and long-term perspectives.
XTB offers Clients the opportunity to invest in over 3,400 stocks
of companies listed on major markets in Europe and the USA.
ETFs
ETFs (Exchange Traded Funds) are investment funds whose units are
listed on regulated markets. The essence of an ETF is to reflect the rate
of return of a reference index by purchasing financial instruments
included in this index (physical replication) or by using derivatives
based on the index (synthetic replication). A characteristic feature
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of an ETF is the constant creation and redemption of units carried out
by financial institutions (investment banks, brokers) authorised by the
institution managing the given fund. Due to the separation of the legal
personality of the fund and the institution managing it, the fund's
assets are separated from the manager's assets. XTB offers Clients
the opportunity to invest in over 370 ETFs listed in Europe.
Table No. 4. Product portfolio of the XTB Group in 2023 due to the passive investing/saving:
Investment plans
In 2023, we expanded our offer to include Investment
Plans that allow you to invest your savings
in an intelligent way. Thanks to this product, the Client
can easily build his/her Plan and invest specific funds -
starting from PLN 50.
Interest on free funds
In November 2023, we introduced another novelty to the
offer, i.e. interest on free funds in Clients accounts.
Interest is accrued daily and paid to the account after
the end of the month. Interest rates are offered
for the following currencies: PLN, EUR, USD, GBP,
CZK and RON.
Product plans
As in previous years, also in 2024, XTB will focus on acquiring new Clients and expanding this group to include people
interested not only in investing, but also in broadly understood financial products. Therefore, we plan not only
to expand the offer, but also to introduce changes aimed at increasing the comfort of using the investment platform
and mobile application. The Company has been preparing for all these changes and implementations for many months,
as evidenced by the intensive development of the Technology and Product Department, ongoing development
and research and development work, also related to the use of technologies based on artificial intelligence.
The first weeks of 2024 will see further development of the product offer addressed to passive investors. Investment
Plans, which enabled in the I quarter of 2024 investing in over 300 ETF funds, have been enriched with an automatic
investing function thanks to which Investors can determine how often and with what amount they want to regularly top
up their individual investment portfolios. Thus, compared to competitive products, Investment Plans have become even
more attractive for Clients looking for medium- and long-term investment products.
In the following quarters of 2024, the passive investment offer will be enriched with:
• bonds. - both treasury bonds (issued by countries such as Poland, the USA and Germany)
and corporate bonds issued by reputable, global companies with a relatively stable rating (from AAA to BBB-).
Thanks to the use of a mechanism analogous to that of fractional shares, investing in bonds will be available
for small amounts;
• social trading, enabling Clients to track transactions executed by other investors whose strategies they consider
worthy of attention. As part of social trading, Clients’ data will be fully anonymised and classified solely
on the basis of the achieved rate of return on investment or the accepted level of risk;
SOCIAL TRADING BONDS PENSION PRODUCTS VIRTUAL WALLET MULTI-CURRENCY CARD
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• IKE (Individual Pension Accounts) and IKZE (Individual Pension Security Accounts). As the Company sees
the potential for further development in the long-term investing segment, the offer of pension products will
also be developed on other global markets, including Great Britain, where XTB plans to operate as an ISA
Manager (Individual Savings Accounts Manager).
• virtual wallet with a multi-currency card, which will enable Clients using the XTB mobile application to make
payments and transfers, card transactions and currency exchange. The added value will be the possibility
of immediate payments between all accounts in XTB. Real-time notifications will ensure full control
of your expenses.
The environmental and social aspects are not the dominant factor in designing the product offer. Nevertheless,
the XTB's offer includes financial instruments (e.g. ETFs) enabling investments in climate-aware entities or entities
classified to indices factoring in ESG criteria. In 2023, the Company added information on the ESG rating
to its investment platform for most of the securities of companies on offer and for ETF instruments.
In 2023, we recorded a large increase in interest in ESG companies among our Clients. We currently offer over 10 ETFs
that provide diversified exposure to stocks or bonds of companies with a high ESG rating (3 and above) in relation
to a specific benchmark. The ETFs offered can be divided according to the region of exposure: France, China, Europe,
United States, emerging markets, global markets. Creating a benchmark for ESG ETFs involves removing companies
from a broader index (the so-called parent index) that do not meet the ESG criteria specified in the index methodology.
Additionally, XTB offers financial instruments related to CO2 emission rights (EMISS contract). Expanding the offer
with instruments supporting direct management of selected aspects of climate risk, e.g. weather derivatives, is being
considered.
2.3. Development and innovation
Technology development
As an entity with a FinTech profile, we offer our services and investment products via the advanced xStation
technological platform, available to Clients in both mobile and website versions. Our operation is based on a developed
strategy for the selection of IT systems, which assumes the development of an original transaction system
and investment products offered by the xStation platform built on this foundation, strengthening the competitive
advantage, combined with systems offered by suppliers, the implementation of which shortens the time to deliver
the product to the client (time to market) and investments in Artificial Intelligence (AI) technologies in all areas of activity.
A defined and efficiently enforced strategy allows Technology Department Employees to focus on research
and development (R&D) work in the form of highly innovative, comprehensive solutions in the investment domain
via the xStation platform.
The R&D works carried out in 2023 were aimed at increasing the range of investment products available to Clients, while
ensuring the stability of solutions and improving internal operational processes with a dynamically growing number
of Clients and transactions.
The most important areas in which the XTB Technology team undertook innovative initiatives are:
• creating new investment solutions such as Investment Plans or introducing interest on free funds accumulated
in the account,
• improving existing processes and products based on continuous Client research and observations
of the activities of competitive companies on the global market conducted by the Research team, with
particular emphasis on the process of new client onboarding,
• creating new analytical models based on highly advanced machine learning techniques based on public cloud
solutions,
• creating processes and new solutions that increase the productivity of internal departments based on Artificial
Intelligence solutions,
• improving operational processes that translate into the efficiency of handling client inquiries within the CRM
system,
• implementing improvements to the order execution system in order to maintain high operational efficiency,
minimise order execution delays and handle significantly increasing transaction volumes,
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• implementing innovative solutions compliant with the latest standards in the field of software development
and implementation (Platform Engineering),
• implementation of highly comprehensive solutions at the hardware level, including dedicated connections
to key Internet traffic exchange points,
• work on improving the security of the platform, both in the field of data processing and storage security
and the immediate detection of security incidents.
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3. Our Employees
One of our key Stakeholders are XTB Employees. It is their commitment,
competences and individual personality traits that create our organisational
culture which is reflected in the identity and results of XTB's business activities.
As an employer, we are aware of our impact on the quality and balance
of professional and private life of our Employees. The positive and pro-
employee work atmosphere that we promote, employment stability and
various non-wage benefits make XTB perceived as an attractive and
developmental workplace.
In 2023, we were among the 50 best Polish employers according to the Wprost
Ranking. Moreover, we took 4
th
place in the category of financial companies,
and 26
th
overall. We were pleased to hear that our activities aimed at creating
a friendly work environment that supports the development, mutual respect
and diversity of our Team have been noticed in such a clear way. However,
the best confirmation of the attractiveness of XTB as a workplace is the constant increase in employment in the Group.
In the second half of the year, the number of our Employees and Associates exceeded the threshold of 1,000 people.
Every day, we provide our Employees with modern office space with professional equipment. New Employees
are welcomed at XTB during an introductory training and receive support from the assigned HR Department supervisor.
Building relationships and a good working atmosphere is very important to us, which is why we are happy to organise
and meet at team building events. In 2023, a sports and team building picnic was held which met with great interest
and enthusiasm of XTB Employees.
Procedures and regulations
As part of due diligence in the parent company, XTB S.A., there are regulations, policies and procedures regulating
Employee issues in place. These include:
• Work Regulations of XTB S.A.
• Distance Work Regulations of XTB S.A.
• HR Policy
• Remuneration Policy
• Policy of Educational Trainings and Confirmation of Knowledge and Skills of Employees of XTB S.A.
• Code of Ethics of XTB S.A. Capital Group
• Credit Risk Management Procedure
• Recruitment and Selection Procedure of XTB S.A.
• Procedure for Non-Wage Benefits for Employees of XTB S.A.
Within the Employee area, the Capital Group's subsidiaries operate based on regulations and procedures individually
adopted within the units in accordance with local law.
Flexibility of the working day
We give our Employees the opportunity to adapt their work mode to their needs. Many of them fulfill their role
as parents, combining professional life with family responsibilities. Understanding their daily efforts, we would like work
at XTB to be a positive, developmental complement to their lives, enabling equal access to work, bringing satisfaction
from implemented projects, regardless of the place of work. That is why we offer our Employees a hybrid employment
model. The possibility of distance work is regulated by the relevant provisions of the Distance Work Regulations.
As part of the flexible working hours adopted in the Work Regulations, our Employees can start their duties between
7:00 a.m. and 10:00 a.m.
XTB AMONG
TOP 50
EMPLOYERS
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Organisational culture and work-life balance
At XTB, we care about the development of an organisational culture based on effective communication, development
and cooperation. In addition to non-wage benefits and a well-thought-out HR policy, we try to organise initiatives that
integrate our Employees and support a good working atmosphere and work-life balance.
In 2023, as part of the implementation of the assumptions of the ESG Strategy, we organised a forest planting campaign
in which 39 XTB S.A. Employees took part as part of the volunteer day. In addition to building climate awareness, our
Employees had the opportunity to integrate in the sense of the rightness of their actions for the environment. The same
year, we also organised a Coffee Day for our employees at the XTB headquarters, because building mutual relationships,
conducting inspiring conversations and exchanging experiences in a friendly office atmosphere is of great importance
to us.
We want to support the building of strong family and interpersonal relationships of our Employees,
which is why on 7 June 2023, our working day ended two hours earlier. This took place as part of the 2 Hours for Family
campaign, organised by the Humanites Foundation to deepen relationships with loved ones, in which we have been
participating regularly since 2019. It encourages being together, not next to each other, promoting a balance between
professional and private spheres. XTB branches also join the campaign every year, including the branches from
Germany, Spain, Great Britain, Romania, Cyprus, Portugal, France. In 2023, XTB received a special distinction and the
title of ambassador from the project organiser for promoting the campaign around the world.
The XTB office also became a meeting place on Children's Day. We invited our Employees and their children to celebrate
together. In addition to refreshments, guests could enjoy attractions and games organised by the animators.
3.1. Dialogue with Employees
Communication is the foundation of valuable Team relationships and mutual trust between the Employee
and the Employer. As an international Capital Group, over the years we have adapted our communication
methods to the changes taking place, wanting to remain in contact with our Employees despite
the significant size of our operations.
In addition to ongoing communication within teams and with direct superiors, the basic and most common form
of communication is e-mail communication conducted bilingually. All documents, procedures
and communications are created and translated with all Group Employees in mind. Moreover, important employment
aspects are also communicated through a dedicated HRM platform available to Employees of the entire XTB Group As
an international organisation, we care about the quality of communication with all our Employees. Since 2023, we have
been using a modern communication platform available in 16 foreign languages. In addition, depending on the needs,
we support our team with language training both for adaptation and development of language competences.
Our Employees are informed about the key directions of XTB's strategic activities and are aware of the direction in which
the organisation is heading. On a quarterly or semi-annual basis, the President of the Management Board of XTB S.A.
communicates to the Team the results achieved by the XTB Group, the current level of strategy implementation
and strategic plans for the next period.
XTB also organises regular meetings with Employee representatives during which proposals are discussed regarding
changes in regulations related to changes in the Labor Code, changes in benefits, improvements in work organisation,
and other suggestions and proposals from Employees are presented, which are then directed to discussion
with the Management Board.
Employee satisfaction survey
Every year, the XTB Group conducts an anonymous Employee satisfaction survey, during which Employees can express
their opinion on areas such as:
• trainings and development,
• motivation,
• communication,
• work environment,
• performance,
• management and relations.
As part of the survey, Employees have the opportunity to express their opinion about the Employer and submit
their own conclusions. The results of the global satisfaction survey are sent to all XTB Employees.
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The above-mentioned study was carried out both in 2023 and 2024. The 10
th
edition held in January this year among all
Employees of the XTB S.A. Capital Group was met with interest from 556 Employees (+45.5% y/y).
The overall results of the latest edition of the study showed that the highest rated areas are cooperation
and relationships. In the area of communication, as many as 93% of Employees stated that they had very good
relationships with team members (+2.0% y/y), which makes the area of team work one of our greatest values
for the ninth year in a row. 91% of respondents admitted that they are treated with respect, 82% admitted that they
feel that the Company cares about them. Training was identified as an area for further improvement. Already
throughout 2023, we have introduced internal improvements among others to our knowledge base, which we plan
to continue to develop.
We are proud that as many as 87% of respondents would recommend XTB to their family and friends as a good place
to work. We do not stop developing and searching for the best solutions for our Team.
3.2. Diversity
[S.6.] From 2021, we are a Signatory of the Diversity Charter. Our Employees differ in talents, skills, character
and personality traits, experience, views and many other attributes. For us, diversity, tolerance and equal treatment
of all Employees is the foundation of a healthy relationship based on mutual respect and trust. We are deeply convinced
that not only is it a basic value of modern society, it also translates significantly into the development, competitiveness
and innovation of the XTB Group.
Our organisational culture is focused on achieving goals by building diverse project teams, which
translates into more effective problem solving, a better working atmosphere, a higher level of creativity
and a more effective flow of knowledge. We communicate with our Employees bilingually, in Polish and
English, wanting to reduce the communication barrier in teams and provide everyone with equal access
to information within the XTB Group. We want to support and discover the potential of our Employees,
giving them the opportunity to fully use their skills, talents, passions and professional competences.
We employ Employees who are diverse in many respects: gender, age, education, qualifications and professional
experience, nationality, ethnic origin, religion, denomination and non-denomination, political beliefs, health condition,
psychosexual orientation, family status, lifestyle, place of residence, form, scope and employment basis.
[S.6.1.] Diversity management at XTB consists also in inclusion of provisions in applicable policies and procedures that
regard counteracting discrimination, mobbing and other regulations determining the standards of equal treatment,
protection against violence, sexual abuse or unjustified dismissal. The principles of equal treatment in employment are
described in internal documents, including but not limited to the Work Regulations, and are available to the Employees.
According to the effective whistleblowing procedure, all Employees and co-workers are obliged to react if they witness
exclusion or harassment of their colleagues.
[S.6.2.] [S.6.3.] In 2023, no cases of discrimination, mobbing or sexual harassment were reported or identified
in the XTB Group. No cases of breach of human rights were identified in the above period either.
Diversity policy regarding the Members of the Company's Management Board
As regards diversity in connection with appointment of the Company's governing bodies, the Diversity Policy
for the Members of the Company's Management Board was adopted. XTB ensures diversity of qualifications
and competences in terms of education, professional experience and skills of the selected staff, including
the management staff, to guarantee comprehensive and reliable performance of entrusted tasks. Furthermore, under
the Diversity Policy, in the recruitment process the governing bodies take into consideration professional qualifications,
reputation, professional experience, predispositions to perform obligations on the given position or in the given
function as well as diversity in terms of sex, age, place of origin and education. The members of XTB's governing bodies
specialise in various areas of knowledge and have diversified industry-related experience corresponding with their
current function. The individual competences of the members of XTB's governing bodies are complementary in order
to ensure the appropriate level of collective management in the organisation.
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3.3. XTB's HR Policy
The HR Policy of XTB is strictly connected with the company's mission and strategy. The guidelines of the HR Policy aim
at effective management of human resources through effective selection, support of development and retention
of the team of Employees that will guarantee performance of the business activities planned by the Company
at the highest level. The HR Policy is based on the assumption that the most important factor of the Company's success
is its staff and, thus, the paramount goal is continuous striving for creation of the best work places and work conditions
possible that enable development of competences.
The aim of the HR Policy includes, in particular:
• acquisition of the optimal number of Employees having specific qualifications and professional potential
required to ensure proper staffing of specific organisational units of XTB by means of a professional
recruitment process;
• support in the process of identification of Employees with the organisation's goals and mission;
• shaping of attitudes and standards of conduct of Employees compliant with internal regulations, ordinances
and procedures effective in XTB;
• ensuring professional stabilisation, counteracting turnover of Employees and retaining highly qualified
and valuable Employees;
• support of development of specialised qualifications required to perform tasks and accomplish set goals;
• creation of an incentive system based on proper shaping of work conditions in combination
with the remuneration, promotion and bonus system as well as assessment of professionalism
and performance.
Areas of operation in the scope of HR Policy include:
• employment planning;
• recruitment;
• Employee assessment;
• retention of Employees (incentivising, remunerating, promoting, granting of bonuses);
• development of Employees (individual professional development programmes, trainings).
All XTB Group entities rely on the assumptions of the HR Policy.
3.4. Employment conditions
Remuneration system
In order to build a sense of employment stability among our Employees, we take due care to ensure that the applicable
rules are simple and transparent. The internal Remuneration Regulations lay down the principles and conditions
of remuneration for work and services connected with work. According to it, Employees receive remuneration
corresponding to the type, quality and quantity of work performed and the qualifications required for its performance.
The general principles of the remuneration policy aim to ensure the coherence of the remuneration system
and additional benefits in relation to the adopted long-term development strategy, taking into account the costs
provided for in the financial plan, while respecting the principles of risk management and stability of XTB's operation.
The remuneration, rotation and promotion system of is implemented through creation of mechanisms incentivising
our Employees to improve the quality and effectiveness of performed work. These activities are influenced
by employment needs, planned budgets of head office departments/foreign branches, funds allocated for human
resources as well as Employee qualifications and the evaluation of their work.
As part of XTB, we also develop non-wage benefits, constantly striving to strengthen Employees' identification
with the company. People employed at the XTB Headquarters are covered by a package of additional benefits.
The remuneration/promotion system is built in cooperation with directors of departments of the XTB Headquarters
by the HR Management Department. In the branches, the remuneration system and the scope of non-wage benefits
are regulated by branch directors in cooperation with regional directors.
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Gender Pay Gap Ratio
In the scope of remuneration, the Company applies market rules, i.e. it makes the value of remuneration of Employees
conditional upon, in particular, possessed knowledge, professional experience and substantive contribution
to the Company's development.
The organisation carries out periodical analysis of the remuneration of men and women in all Departments.
If any discrepancies are detected, the head of the given organisational unit is consulted and remedial actions are taken
if needed.
Information regarding the Gender Pay Gap Ratio (GPGR) for XTB Headquarters is presented below. The Company
presents the ratios for XTB Headquarters considering the highest diversity of positions in XTB Headquarters
in comparison to other foreign branches and subsidiaries where employees on sale positions are predominant.
[S.2.9] GPGR is expressed as a percentage calculated as the absolute value of difference of the product of average
monthly pay of women divided by the average monthly pay of men and number 1. The ratios are presented taking into
consideration the base salary as well as base salary plus extra benefits.
Table No. 5. Gender Pay Gap Ratio for XTB S.A. Headquarters for 2023 and for the same period of the previous year
[%].
XTB S.A. Headquarters
2023
2022
GPGR
(based on base salary)
Employees on managerial positions
8%
19%
Employees on executive positions
14%
1%
Employees on positions other than
above
27%
14%
GPGR
(base salary plus extra
monetary benefits, awards,
etc.)
Employees on managerial positions
12%
10%
Employees on executive positions
22%
14%
Employees on positions other than
above
25%
19%
The Company explains that ca. 46% of Employees of XTB Headquarters are IT Department Employees (especially
software developers) whose remuneration value and predominant share of men in this category result in a gender pay
gap. The high remuneration of this professional group is related to the pay pressure on the labour market and need
to acquire and retain high class specialists in this area. This dependency is, however, typical for the IT industry and does
not apply only to XTB.
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SUSTAINABILITY REPORT FOR 2023
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Table No. 6. Gender Pay Gap Ratio for XTB S.A. Headquarters, excluding the IT Department, for 2023 and for the same
period of the previous year [%].
XTB Headquarters (excluding IT Department)
2023
2022
GPGR
(based on base salary)
Employees on managerial positions
3%
10%
Employees on executive positions
5%
0%
Employees on positions other than
above
1%
0%
GPGR
(base salary plus extra
monetary benefits, awards,
etc.)
Employees on managerial positions
9%
9%
Employees on executive positions
14%
0%
Employees on positions other than
above
2%
9%
The difference between the rate based on base salary and the rate based on based salary plus extra benefits is related
mainly with higher share of men employed in the Trading Department and Sale Department where additional benefits
(i.e. including but not limited to bonuses and premiums) are higher than analogous benefits on administrative positions.
[S.2.10] The relation of the lowest remuneration in the Company (based on conversion into full-time equivalents)
to the average remuneration of the members of the Management Board in years 2023 was ca. 0.08.
Non-wage benefits
[S.2.15.] We want to take care of the well-being of our Employees in many dimensions. Depending on the form
of employment, we provide the following non-wage benefits:
For Employees employed under a contract of employment and mandate contract:
● private medical care;
● MyBenefit platform and Multisport Package;
● the "Helping Hand" well-being platform, which provides psychological support focusing on psychoeducation
and prevention (including online sessions with therapists, webinars, workshops, educational articles).
The platform is also available to XTB contractors.
For Employees employed under a contract of employment:
● reimbursement of costs of corrective glasses;
● holiday vouchers;
● subsidies for annual leave;
● allowance for using the leave entitlement in the given calendar year;
● group life insurance;
● an additional day of paid leave on a birthday;
● an additional day of paid leave to care for young parents;
● days off for volunteering;
● co-financing of meals.
The scope and form of non-wage benefits in the subsidiaries are adjusted to the local conditions and standards
in the area of remuneration of Employees and include, for instance, additional healthcare services, group insurance
or holiday gifts.
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SUSTAINABILITY REPORT FOR 2023
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Promotion of health
Out of concern for the health and well-being of our Employees, we take long-term and ad hoc actions
to support them in this respect. In 2023, we organised flu vaccinations for Employees at the XTB
headquarters for the thirteenth time. People who did not take part or were unable to get vaccinated
on the given date had the opportunity to get vaccinated free of charge as part of their medical
subscription at a selected medical care provider's facility.
In addition to access to fresh fruit every Monday at the XTB headquarters,
we primarily work to increase the awareness of our Employees in the field of health prevention. We promote such
initiatives as: European Breast Cancer Day or Movember. We organise webinar meetings with specialists in health
prevention and a series of internal first aid training courses for employees. In addition, our Employees willingly engage
in blood donation campaigns.
We believe that movement is health. We implement projects related to the promotion of sports activities, wanting
to strengthen positive habits among our Employees. We support, among others: the XTB team playing football
in the business league or the XTB Running Team, which celebrated its 5
th
anniversary in 2023. In the year in question,
the XTB Team once again took part in the Janusz Kusociński Night Relay Run, taking 33
rd
place out of 127 teams. Shortly
afterwards, they also took part in the 32
nd
Warsaw Uprising Run. The event gathered almost 8,000 runners who
commemorated the events of 1944. In the coming periods, a number of activities and events are planned to increase
the involvement of our Employees in practicing various sports disciplines and promoting a healthy lifestyle.
We also support activities in the field of broadly understood well-being and work-life balance. In order to increase the
mental and emotional well-being of our Employees, we have established cooperation with the provider of the "Helping
Hand" platform, which enables participation in webinars and consultations with specialists. We believe that the balance
between professional and private life is crucial in maintaining health and translates into the quality of life in every
sphere on many levels. Since 2019, the Capital Group has been actively involved in the Two Hours for Family campaign,
enabling our Employees to leave the workplace two hours earlier so that they can spend this time with their loved ones,
which we write about in more detail in Chapter 3. Our Employees of this Report.
3.5. Employment structure
[S.2] [S.2.1.] [S.2.2.] [S.2.3.] Average annual employment in full-time equivalents in the XTB S.A. Capital Group
has been growing systematically over the last 3 years. In 2023, it was 796 (+20.8% y/y).
Chart No. 2. Structure of average annual employment in full-time equivalents in the XTB Group in 2021-2023.
796
659
562
2023 2022 2021
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Table No. 7. Employment structure of the XTB S.A. Capital Group and XTB S.A. (XTB S.A. headquarters together
with foreign branches of XTB S.A.) as at 31 December 2023 and as at 31 December 2022.
Criterion
XTB S.A. Capital Group
XTB S.A.
Form of
employment
Age group
Sex
(F/M)
As at
31.12.2023
As at
31.12.2022
Change
y/y [%]
As at
31.12.2023
As at
31.12.2022
Change
y/y [%]
Contract of
employment
(in full-time
equivalents)
below 30 y.o.
Total
325
297
+9.4
275
267
+3,0
Women
104
88
+18.2
88
79
+11.4
Men
221
209
+5.7
187
188
-0.5
30-40 y.o.
Total
413
333
+24.0
335
291
+15.1
Women
143
110
+30.0
103
89
+15.7
Men
270
223
+21.1
232
202
+14.9
40-50 y.o.
Total
113
71
+59.2
100
69
+44.9
Women
37
22
+68.2
30
21
42.9
Men
76
49
+55.1
70
48
45.8
over 50 y.o.
Total
14
10
+40.0
13
10
+30.0
Women
5
2
+150.0
4
2
+100.0
Men
9
8
+12.5
9
8
+12.5
Total:
865
711
+21.7
723
637
+13.5
Bearing in mind the nature of activity and business model of XTB Group, the main groups of Employees are specialists
in the area of IT and customer support.
The highest employment diversity understood as diversity of functions and positions is recorded in the XTB S.A.,
i.e. the Company’s Headquarters in Poland. The Employees of subsidiaries and branches are mainly persons
responsible for support of sale processes on the local markets.
Proportions of key categories of positions and functions are presented below for:
• XTB S.A. Headquarters, characterised with the highest employment diversity (except for foreign branches
of XTB S.A.);
• XTB S.A., i.e. the Headquarters and its foreign branches;
• XTB S.A. Capital Group, including the Headquarters, foreign branches of XTB S.A. and subsidiaries
of the Capital Group.
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Table No. 8. Proportion of key categories of positions and functions in the audited year and in the corresponding
period of the prior year.
Area/position*
XTB S.A. Headquarters
XTB S.A. (headquarters and
foreign branches)
XTB S.A. Capital Group
2023
2022
Change
y/y
2023
2022
Change
y/y
2023
2022
Change
y/y
IT area
45%
41%
+4 p.p.
37%
33%
+4 p.p.
30%
29%
+1 p.p.
Sale area
4%
4%
no
change
12%
14%
-2 p.p.
19%
19%
no
change
Customer
service area
21%
24%
-3 p.p.
17%
19%
-2 p.p.
15%
17%
-2 p.p.
Other
specialised
positions
17%
15%
+2 p.p
21%
17%
+4 p.p.
22%
18%
+4 p.p.
Managerial
positions
9%
10%
-1 p.p.
9%
10%
-1 p.p.
8%
9%
-1 p.p.
Executive
positions
4%
6%
-2 p.p.
4%
7%
-3 p.p.
6%
8%
-2 p.p.
Total
100%
100%
-
100%
100%
-
100%
100%
-
* Number of people employed in the given area in relation to the number of people employed in individual organisational
units, expressed in%.
In 2023, the largest share both within the XTB S.A. Headquarters and the parent company XTB S.A. (i.e. the headquarters
and foreign branches) and the XTB S.A. Capital Group were positions in the IT area, similarly to the previous year.
The second area with the largest share was the customer service area within the Headquarters. As regards XTB S.A.
and the XTB S.A. Capital Group - the second area were other specialist positions. The smallest share both within
the Headquarters and XTB S.A. and the Group were executive positions, and in the case of the Headquarters
- also the sales area.
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Table No. 9. Employee turnover of the XTB S.A. Capital Group in 2023 and in the corresponding period of the prior
year and the hiring and leaving of Employees at XTB S.A. in 2023.
Criterion
XTB Group
XTB S.A.
As at
31.12.2023
As at
31.12.2022
Change
y/y [%]
As at
31.12.2023
As at
31.12.2022
Change
y/y [%]
Employees
hired/leaving
Age structure
Sex
(F/M)
Employees
hired
(number
of persons)
below 30 y.o.
Total
147
155
-5,2
117
140
-16.4
Women
49
42
+16.7
41
36
+13.9
Men
98
113
-13.3
76
104
-26.9
30-40 y.o.
Total
84
76
+10.5
66
63
+4.8
Women
27
33
-18.2
18
27
-33.3
Men
57
43
+32.6
48
36
+33.3
40-50 y.o.
Total
19
9
+111.1
14
9
+55.6
Women
4
5
-20.0
2
5
-60.0
Men
15
4
+275.0
12
4
+200.0
over 50 y.o.
Total
3
1
+200.0
3
1
+200.0
Women
2
0
-
2
0
-
Men
1
1
no
change
1
1
no
change
Employees
leaving
(number
of persons)
below 30 y.o.
Total
60
53
+13.2
52
42
+23.8
Women
19
16
+18.8
16
12
+33.3
Men
41
37
+10.8
36
30
+20.0
30-40 y.o.
Total
69
47
+46.8
39
37
+5.4
Women
27
8
+237.5
12
5
+140.0
Men
42
39
+7.7
27
32
-15.6
40-50 y.o.
Total
7
11
-36.4
5
10
-50.0
Women
1
3
-66.7
1
3
-66.7
Men
6
8
-25.0
4
7
-42.9
over 50 y.o.
Total
3
2
+50.0
2
2
no
Women
2
0
-
1
0
-
Men
1
2
-50.0
1
2
-50.0
including in
connection with
acquisition of old-
age pension or
disability pension
rights
Total
6
0
-
6
0
-
Women
1
0
-
1
0
-
Men
5
0
-
5
0
-
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Table No. 10. Employee turnover rate within the XTB S.A. Capital Group in 2023 and in the comparative period of 2022.
[%].
Employee turnover rate*
XTB Group
XTB S.A.
2023
2022
2023
2022
Total
17.64%
17.28%
14.41%
15.68%
Women
19.18%
13.24%
14.42%
11.90%
Men
16.87%
19.11%
14.38%
17.23%
* The number of employees who left their job divided by the average of the sum including the initial and final number
of employees in the period under review.
In 2023, the total employee turnover rate, both within the XTB S.A. Capital Group as well as the parent company
XTB S.A. remained at a similar level compared to the previous year.
Analysing turnover rates on the scale of the XTB S.A. Capital Group, the largest deviation compared to the same period
in 2022 was recorded among women, where the rate increased by 5.94 percentage points. y/y and amounted to 19.18%.
The men's turnover rate decreased by 2.24 percentage points y/y.
With respect to the parent company XTB S.A., in the audited period the women's turnover rate reached a lower value
compared to the Capital Group discussed above, i.e. 14.42% (+2.52 p.p. y/y). Men's turnover, similarly to the Group,
decreased to 14.38% (-2.85 percentage points y/y).
Table No. 11. List of the number of civil law contracts within the XTB S.A. Capital Group in 2023 and in the comparative
period of 2022 and for XTB S.A.
Criterion
XTB Group
XTB S.A.
2023
2022
2023
2022
Civil law
contracts
Number of civil law
contracts at the end of
the period
100
38
69
38
Number of civil law
contracts concluded in
the period
91
54
82
54
Number of civil law
contracts
terminated/expired in
the period
55
31
51
31
[S.2.6] In 2023, there were 4 disabled people employed in the XTB Group.
[S.2.5.] In 2023, the XTB Group cooperated on the basis of employee outsourcing with 6 full-time positions, including
4 within XTB S.A.
There are no trade unions in any of XTB Group companies. According to the law, representatives of Employees
have been appointed in the XTB S.A. Headquarters in Poland.
There were no collective disputes in 2023.
[S.2.14.] In 2023, there were three situations in the XTB Group in which a woman, after giving birth to a child
and returning to work, resigned from her job within 12 months from returning to work.
We do not plan to employ Employees from economically weaker countries to perform the so-called low-cost tasks.
The priority at XTB is to ensure equal employment rules in similar positions. Thus, even if an Employee comes from
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a less economically developed country, he/she is employed on terms equal to those offered to Employees from Poland,
EU or other regions of the world.
3.6. Employees' Development
Managerial approach
[S.5] At XTB, we pay special attention to creating favourable conditions for the long-term professional
development of our Employees. This is aimed at strengthening their potential, supporting efficiency
by building competences, and thus improving the quality of their work. Appropriately educated staff
is the foundation of the business, ensuring professional implementation of assigned tasks
and responsibilities. Career planning and development are considered both in the context
of the Employee's personal development, predispositions and needs as well as XTB's requirements regarding
the desired competencies for a given job position.
Financial resources allocated to improving qualifications are part of the budgets of individual XTB departments.
The training budget of foreign branches is determined by each branch director. The Employees are delegated
to trainings by their immediate superiors, according to the requirements in terms of improvement of their competence
level.
Our professional staff is the highest value of XTB. We support and promote gaining specialised qualifications
by our Employees, reimbursing costs of passed exams, e.g. obtaining broker, investment advisor or CFA licences, etc.
[S.5.2.] External trainings
The main external training categories include:
• technical trainings (IT area);
• specialised trainings (regarding improvement of professional knowledge, including post-graduate studies, CFA,
ACCA, MBA, ICA, course preparing to obtain the broker's licence, etc.);
• training in the scope of soft skills;
• language courses (co-financing of education, reimbursement of language course costs, access to the eTutor
foreign language e-learning platform).
Table No. 12. List of key external training and educational programmes at XTB S.A. in 2023:
No.
Training and educational programmes
Number
of participants
1.
Studies and postgraduate studies with co-financing (maintenance of co-
financing for Employees continuing their studies in subsequent semesters,
therefore participation in education costs is planned also in the following
years).
10 persons
2.
27 theme conferences
81 persons
3.
51 technical trainings (IT area)
91 persons
4.
78 specialist training courses
178 persons
5.
12 soft skills training courses
56 persons
6.
Co-financed language courses
20 persons
7.
E-learning platform eTutor for learning foreign languages online - 339
training hours were used in 2023
43 persons
[S.5.1] In 2023, XTB Group held nearly 650 trainings, including IT trainings, specialised trainings, trainings connected
with foreign languages as well as soft skills. In 2023, the XTB Group trained a total of over 520 people
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(approx. 1/3 women and 2/3 men), with almost 6.5 thousand PLN allocated for training hours (including approximately
1/3 dedicated to women and 2/3 dedicated to men).
Moreover, in 2023, a series of 147 hours of managerial skills workshops were conducted for 40 Employees holding
executive, managerial and leadership positions. As a result of a previously conducted demand survey, important
training topics were identified, which focused on developing competences related to team management and soft skills.
Employees also had the opportunity to participate in webinars on various topics, including: supporting mental health,
development of soft skills, and health prevention. A first aid course was also conducted, attended by 74 Employees.
XTB also cares about building awareness of online security. As every year, all Employees received Security Awareness
training and practical anti-phishing training.
[S.5.2.] In 2023, no XTB Employee took training leave.
Internal training system
We also organise internal training to ensure the appropriate level of competence of our Employees in relation
to the scope and nature of the work they perform. This ensures the correctness of the processes carried out
in accordance with the applicable laws and recommendations of the supervisory authority, in accordance
with
the adopted ethical standards and principles of fair trading and in the best interest of the Client/prospective Client.
The rules of functioning of the training system are described in the dedicated Procedure for Educational Trainings
and Confirmation of Knowledge and Skills of Employees.
Within XTB, from the point of view of training criteria, the following were distinguished:
• Authorised Employees and
• Unauthorised Employees.
Authorised Employees are persons authorised to supply information on brokerage services provided by XTB
and financial instruments covered by XTB's offer to the Clients or prospective Clients. Authorised Employees are hired
in the Global Customer Support Department, Analysis Department, Customer Service Department, Sale Department
and External Partner Cooperation Department, and they are obliged to participate in the mandatory educational
programme.
Authorised Employees are also obliged to:
• regular participation in additional educational trainings in the principles and mode of provision of brokerage
services, held by XTB in connection with legal changes or introduction of new legal regulations applicable
to XTB's business,
• regular participation in additional educational trainings provided by XTB with regard to features
and characteristics of financial instruments offered by the Company or to be introduced in XTB's offer.
• take the annual knowledge and competence test by authorised Employees, and passing it with a positive result.
Failure by an Authorised Employee to review knowledge and competencies constitutes a serious breach of his or her
Employee duties and may result in the inability to continue working for the Employer.
Unauthorised Employees are also obliged to participate in the onboarding educational programme. In such a case,
training materials are transferred automatically via the education platform on the first days of work.
Additionally, at the XTB Headquarters, the HR Department, in cooperation with the Legal Department, conducts
the "First Day at XTB" training. This is an onboarding training on the first day of work for all newly employed people
(including interns and employees employed under a mandate contract). In 2023, a total of 285 employees were trained.
Moreover, in 2023, an annual GDPR training was held dedicated to all Group Employees, in which 832 Employees took
part.
Regardless of the training conducted using the organisation's own resources, the XTB Group incurred expenditure
on training in 2023 equivalent to approx. PLN 970,000. zloty.
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Employee performance assessment system
The assessment system for our Employees is an important element of human resources management at XTB. Obtaining
reliable information is an essential element of the HR Policy, enabling formulation of the assessment of Employee's
performance, taking into consideration his/her competences, possibilities, motivation and contribution to performance
of tasks.
The assessments are carried out for the following purposes:
• improvement of quality and effectiveness of work of XTB's employees;
• providing feedback to the Employee with regard to the assessment of his/her performance;
• recording and promoting accomplishments;
• improving employees' motivation;
• identification and analysis of potential problems, mistakes in performance of obligations;
• making sure the superior can make reasonable staff-related decisions, including planning of individual
professional development of employees (delegation to trainings).
The assessments are carried out objectively, professionally and reliably, so as to reflect the actual level of performance
of duties and work performed. The employees are subject to continuous assessment carried out by immediate
superiors as well as periodical assessments. Continuous assessment allows employees to receive ongoing feedback
on the quality of their work and the degree to which they fulfil their duties. This approach allows to effectively correct
and improve areas that require more attention from the Employee, e.g. during the project. This allows to reduce
the risk of error by minimising the consequences of its accumulation in subsequent stages of work, and may also have
a positive impact on relations with your superior by building the basis for mutual dialogue and understanding.
Periodical assessments of Employees' performance are carried out quarterly or annually, depending on the department
and position. This type of Employee evaluation allows to identify his/her progress visible in the long term. The quarterly
performance assessment is carried out, inter alia, by the superiors from the Customer Service, Trading and Sale
Departments.
The annual assessment applies to employees of other departments, higher tier employees and management staff
who are assessed by their immediate superiors.
Development Review career planning programme
XTB has introduced the Development Review programme the purpose of which is support in planning of professional
development, gaining knowledge and new competences.
After a one-year break as a result of system changes, the "Your Next Best Step" survey is planned to be resumed
in 2024, the aim of which is to provide support in career development within the organisation. The results of the survey
help in career planning and reaching Employees with accurate career-related proposals.
Internship programmes
Implementing the assumptions of the XTB Diversity Policy, we employ students and graduates of universities with various
professional profiles for internships and apprenticeships.
Wanting to connect young and ambitious IT students with business, we initiated a 3-month internship program,
IT Academy. The 6
th
edition of the program began in October 2023, and is becoming more and more popular every year.
As part of the latest edition of the IT Academy, participants had the opportunity to develop their skills in technologies
such as: Java, QA, Apex, Kotlin, C++, Angular, SQL, Business Analysis. In addition, participants could build knowledge
about XTB, not only as a brokerage house, but above all as a FinTech organisation where proprietary IT products
are created based on various technologies.
We also conduct periodical recruitment of candidates for internships in software engineering who, having completed
the onboarding period under supervision of a mentor, join selected teams using technological innovations. In addition
to the IT Department, internships held by the XTB Headquarters covered the following departments: Analyses, Trading,
Marketing and Risk.
Internships are organised by the XTB Headquarters all year long. During 2023, a total of 71 interns took advantage
of this opportunity, most of them within the IT Department, where as many as 58 people took part in the IT Academy.
The internship programmes are also implemented in the foreign branches but, due to the scale of activity of specific
branches, cooperation in this area regards usually one or two interns - mostly in the marketing or sale departments.
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3.7. Career at XTB
As an international Capital Group, we are open to a variety of candidates from interested people. Thanks to the wide
scale of our activities, we are looking for specialised Employees in various areas such as:
• IT,
• Trading,
• Global Customer Support,
• Sale Department,
• IBD Department,
• Risk Department,
• Marketing
• Compliance,
• Research and Development
Department,
• Accounting and Finance.
We also undertake activities to recruit qualified staff. For example, in October 2023, representatives of our HR Tech,
technology and business teams took part in the IT Job Fair at the Main Building of the Warsaw University of Technology,
where they had the opportunity to talk about innovative XTB projects and our internship programme - IT Academy.
For more information on this subject, see the previous chapter (3.6. Employee Development) of this Sustainability Report.
XTB job offers are published regularly on our website at: https://www.xtb.com/pl/dlaczego-xtb/kariera. Each of them
contains a short description of our activities, the expected scope of responsibilities and requirements for the given job
position, and information about what we as an organisation offer our candidates. For more information on employment
conditions, see further sections of the chapter 3 Employees of the Sustainability Report.
3.8. Occupational health and safety
From 2023, XTB Employees work in distance or hybrid (partially stationary) mode, depending on the department.
Taking into account, inter alia, still a large share of distance work, care for the mental and physical condition
of Employees, we have established cooperation within the well-being platform "Helping Hand", which provides holistic
psychological support, focusing on psychoeducation and prevention, and also gives access to:
• webinars and workshops,
• didactic materials,
• podcasts,
• coaching,
• chats with experts
• online consultations and psychotherapy,
• 24 support helpline.
Using the platform, XTB Employees can also use free sessions with online therapists.
In 2023, XTB continued its information policy encouraging vaccinations and carried out an annual preventive vaccination
campaign organised at the XTB S.A. office in Warsaw.
The above health-promoting activities were also implemented in previous years 2021 and 2022.
[S.4.1] [S.4.4.] In 2023, in the Headquarters of XTB S.A. no accidents at work were reported. There was 1 accident
at work classified as minor in one of the foreign branches of XTB S.A., which resulted in a five-day sick leave
for the injured person.
[S.4] XTB operates an Occupational Health and Safety Committee established in accordance with the applicable law.
[S.4.7.] [S.4.8] There are no positions for which the threshold limit values (TLV) or permissible exposure limits (PEL)
are exceeded and there are no positions for which the level of assessed occupational risk is unacceptably high.
[S.4.6] In 2023, no cases of occupational disease were identified.
private medical care
group insurance
benefit platfom
modern office
day off to
celebrate
birthday
English learning
platform
co-financing
for courses
and training
an additional
day off for parents
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4. Social relations
4.1. Relations with Stakeholders
We strive to be a responsible partner for our Stakeholders. We achieve this goal through our business activities based
on the highest quality products, services, customer service and reliable technology.
Within the Capital Group, we identify the following key groups of Stakeholders:
• Employees of XTB S.A. Capital Group;
• Retail and institutional Clients;
• Prospective Clients - persons interested in education regarding financial markets;
• Suppliers;
• State institutions, including local supervisory authorities;
• Media representatives;
• Shareholders, Analysts and prospective Investors.
[S.9.3.] As a stock exchange entity that communicates transparently with the market, we publish information about
our Strategy, long-term goals and planned activities on our website. The degree of implementation of our Strategy,
determined using financial and non-financial measures, is presented in current and periodic reports of XTB S.A.
By ensuring equal access to information, we also organise quarterly meetings for Investors, dedicated in particular
to our Shareholders, Analysts, industry experts and media representatives. As a stock exchange-listed company,
XTB S.A. publishes periodical reports every quarter. Its reports for supervisory institutions are prepared at least once
a month.
We also build relationships with Stakeholders through participation in industry events, job fairs
and partnerships. In 2023, we became a strategic partner of the Association of Individual Investors
to work together to protect the rights of individual investors. Together, we will strive to appoint
an Ombudsman for Individual Investors in order to raise the standards of the financial market
in Poland.
We also conduct marketing activities aimed at increasing the recognition of the XTB brand and educational activities
addressed to Stakeholders regardless of their level of experience in the investment area. We also conduct extensive
communication activities within available social media channels, i.e. Facebook, LinkedIn, X. The further part
of this Report also includes information on activities undertaken as part of communication and education of retail
Clients.
When developing our business, we respect the competitive environment and other participants of the markets in which
we operate. We strive for market expansion only while maintaining the principles of fair competition and within
the limits and respect of legal regulations in the field of competition protection. We actively promote transparency,
fair market practices and openness to cooperation and partnerships that can contribute to achieving common
sustainable development goals.
At XTB, we believe in the development of financial education. We are the author of the IT Academy internship
programme, which we describe in more detail in chapter 3.6. Employee Development of this Report. In 2023, we had
the honour of being a partner of the first edition of the National Stock Exchange Competition "Young Investor”.
The organisers of this prestigious event were the Department of Economics and the Department of Finance
of the Faculty of Economic Sciences of the Koszalin University of Technology. The competition gathered almost
600 secondary school students from all over Poland who had the opportunity to test their investment skills and expand
their knowledge of the capital market. The grand finale, to which the 49 best participants qualified after the theoretical
part, consisted of competing in live trading on the xStation platform.
[S.9.1.] [S.9.2.] In 2023, we did not identify any possible nuisances that could negatively affect the local community
and we did not receive any complaints from the local community regarding the activities of the XTB Group.
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4.2. Our Clients
Among our key Stakeholders we identify XTB Clients (both retail and institutional segments) and our prospective Clients.
Wanting to build value for our Clients, we do not stop developing our business activities, setting ambitious goals
and constantly expanding our product portfolio. One of the main communication channels is contact through
our Customer Service Experts available 24/5. In order to reach as many recipients as possible, we also conduct
marketing campaigns with the participation of athletes and actively inform about our activities through available social
media channels. We provide educational materials for those interested in building their knowledge in the area
of investing.
Retail segment
The retail activities of the XTB Group include online trading in derivatives based on assets and underlying instruments
for retail Clients, which takes place on financial and commodity markets, as well as activities related to trading in shares
from selected stock exchanges from around the world and ETF instruments.
We strive to increase the availability of financial instruments for individual investors. For Investors with a portfolio
of instruments with a value not exceeding the equivalent of EUR 100,000, we offer gratuitous and commission-free
access to foreign instruments in the form of ETFs on global indices or shares of companies listed on the largest world
stock exchanges. Thanks to this, even an individual investor who does not have significant capital and organisational
resources has the opportunity to diversify his/her investments using global financial instruments.
The retail Clients of the Group are granted access to the front-end type trading platform and a number
of its components as well as back-office systems.
In the retail segment, the XTB Client base is characterised by the following parameters:
• new Clients,
• total number of Clients and
• average number of active Clients.
XTB has a solid foundation in the form of a constantly growing Client base and the number of active Clients. In 2023,
we recorded another record in this area, acquiring 311,971 new Customers compared to 196,864 a year earlier, which
is an increase of 58.5%. Similarly to the number of new Clients, the number of active Clients was also record-breaking.
It increased from 270,560 to 408,528, i.e. by 51.0% y/y.
Communication with the individual Client and educational activity
From the very beginning of our existence, we pay special attention to education regarding the functioning of financial
markets. The paramount goal of XTB is building investment awareness and facilitation of access to knowledge.
XTB makes sure that any person interested in the functioning of financial markets has access to the necessary
knowledge. Most educational materials prepared by XTB are available for free. These materials include nearly 100 hours
of educational trainings in a video version, available on the xStation platform developed by XTB, and tens of articles
shared on the XTB’s website in the Education tab. The authors of the training are XTB Experts and external financial
market experts. The variety of subjects and advancement levels makes them valuable for both beginning and advanced
Investors.
Furthermore, depending on individual needs, Clients can participate in the regular conferences and webinars organised
by XTB.
Since 2016, XTB has been organising the Masterclass Conference, attended by several thousand people every year.
[S.15.5.] In 2023, there were no situations of imposition of penalties/violation of competition regulations
by companies from the XTB Group (defined in Section II of the Act on Competition and Consumer Protection),
and in 2023 no penalties were imposed related to violation of regulations regarding marketing communication.
In 2023, proceedings were underway by the Office of Competition and Consumer Protection against XTB S.A. based
in Warsaw regarding the recognition of a standard contract as prohibited. As part of the proceedings, due to the Office's
questioning of two provisions of the regulations, a decision was imposed on the Company obliging the Company,
inter alia, to change these provisions, publish the content of the decision, submit appropriate declarations
to the indicated group of persons and provide compensation with interest to persons whose complaints were rejected
by applying the challenged provisions of the regulations. No fine was imposed on the Company. The Company
is currently implementing the obligations imposed by the decision of the President of the Office of Competition
and Consumer Protection.
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Institutional segment
As regards institutional Clients, XTB is a liquidity provider. We offer as well technologies allowing such Clients to offer
trading in financial instruments under their own brand to their own Clients. The offered IT solutions can also be used
by: CRM and Client Office providers, companies offering reporting and Business Intelligence solutions, Payment
Providers and other technology providers. Institutional Clients include, without limitation: brokerage houses, banks,
start-ups and other financial institutions and technology companies. Institutional Clients receive full access
to settings and management functions, branding system, reports, front and back-office tools.
Reliance on recipients
Due to the nature of the primary business activity, focused on retail Clients, there is no risk of becoming reliant
on any recipient.
4.3. Our Suppliers
Materials used and services provided to the Group
As part of its business activity, we cooperate with providers of services supporting organisational, marketing, analytical
processes, IT development as well as supporting the trading area. The activity of these entities is located mainly
in Europe and USA.
In most cases, cooperation with our suppliers is of permanent nature. In certain cases, ad hoc, one-off cooperation
is also established.
XTB's key suppliers are:
• service providers supporting the XTB Client service process (including those responsible for the automation
of the above-mentioned processes);
• service providers for the needs of the trading area (e.g. market data providers).
As regards other supplies, these include, in particular, purchase of IT hardware, energy and office supplies.
In 2023, no cases of violation of employee rights were identified among the XTB Group's suppliers. Due to the business
profile of suppliers, the XTB Group does not identify practices that may pose a threat to the right to freedom
of association and the right to collective disputes or that may violate these rights.
Reliance on suppliers
Due to the nature of conducted business activity, XTB Group does not rely on any suppliers.
4.4. Cooperation with Contractors
[E.7.5.] Contracts with the contractors do not include any clauses regarding ethical, environmental or human
rights-related clauses in a scope other than resulting from the locally governing law.
The XTB's business model does not provide for participation in public tenders. In 2023, the XTB Group companies
did not participate in any tenders of this type.
[E.7.6.] The XTB Group companies did not order any audits regarding the environmental, OHS, human rights or ethical
areas in 2023. XTB's Group contractors did not order any XTB audits in the above areas either.
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4.5. XTB’ charity activity
[S.9.4] XTB's charitable activities are one of the foundations of our dialogue with society. We use our
support wisely to reach the places most in need.
Due to the above, in 2023 the XTB S.A. Capital Group donated the amount of PLN 100,000 in cooperation
with UNICEF to help victims after the earthquake in Turkey and Syria.
[S.9.6.] In addition to donations, in 2023 we enabled 39 Employees to use a total of 320 hours as part of Employee
volunteering.
4.6. XTB Foundation
Starting from 2020, the Group operates the XTB Foundation, with the help of which
we implement initiatives in the ESG area.
The foundation's objects of operation include, in particular:
• increase in entrepreneurship and innovativeness, especially in the area of new technologies and financial
market,
• improvement of awareness and knowledge related to the economy, finance and new technologies,
• scientific and research activities as well as promotion of solutions developed as part of the business activity
of XTB Capital Group,
• supporting and organising all initiatives connected with promotion of financial institutions and new
technologies;
• financial support, providing knowledge or business advising to selected entrepreneurs;
• actions in the scope of corporate social responsibility, sustainable development;
• promotion of employment and education as well as aiming at equal opportunity for development;
• initiation and support of activities of XTB Capital Group's Employees;
• charity and social activity.
[S.9.4.] In 2023, the XTB Foundation donated the total amount of PLN 50,000 for charity purposes.
Moreover, in cooperation with an external agency, the Foundation carried out a study on saving young Poles, the results
of which were published in the report "Dreams and plans of young Polish women and men". The aim of the study was
to identify the most important dreams of young citizens, which their financial situation prevents them from realising.
Their approach to saving and investing was also analysed, both in terms of behaviour and the accompanying beliefs.
Increasing economic awareness among younger generations is becoming one of our priorities.
The most important action in the field of environmental protection in 2023 was the involvement of the XTB Foundation
in cooperation with the “Las na Zawsze" (Forest Forever) Foundation. As a result, in October 2023, XTB Employees
planted over 2,000 trees in an area of 12,000 m2, creating a biodiverse deciduous "XTB Forest" located in Mieleszkowce
Pawłowickie in the Podlaskie Voivodeship. The planted forest is a self-regulating system that serves as a CO2 store,
a soil stabiliser, a water reservoir, a habitat for many organisms, a biodiversity sanctuary and an oxygen producer.
In 2023, our Employees were once again involved in the fundraising for the Noble Gift Campaign, which allowed them
to purchase products that meet the needs of a selected family. In 2023, we also played with the Great Orchestra
of Christmas Charity during the 31
st
Final. We donated the following to charity auctions:
• a Real Madrid shirt autographed by Iker Casillas;
• Kuba Przygoński's Dakar'23 gloves and Team sweatshirt;
• UFC gloves with Joanna Jędrzejczyk's autograph.
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Thanks to our auctions, we managed to support the campaign with a total amount of PLN 10,557.
The XTB Foundation is constantly developing new directions of activity and looking for opportunities to cooperate
with external entities in order to implement its statutory assumptions.
The annual statements of the Foundation are available on the corporate website of XTB Group.
Activities in the social area planned by the Foundation
• gradual extension of the knowledge base for every advancement level, gradual supplementation of our video
educational materials with stenographic records to facilitate their reception to persons suffering from hearing
impairments;
• increasing involvement in programmes supporting development and innovativeness of Polish entrepreneurs;
• gradual increase of expenditure on charity and development of the area of partnership in social projects;
• increasing involvement in environmentally-friendly projects;
• intensified involvement in social projects through gradual increase in voluntary work;
• taking actions to prevent exclusion of children and youth, economic education programme.
Irrespective of the aforementioned, subsidiaries took, depending on their scale, individual activities in the scope
of charity, addressing them mainly to local medical centres and institutions.
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5. Impact on the environment and climate change
[E.1.1.] [E.1.2.] Taking into account the specificity of our activities, which are based mainly on IT
and office activities, the XTB Group does not identify a significant impact of its activities on the natural
environment and climate change. Due to the non-production nature of our activities,
there is no demand or consumption of specific or significant volumes of raw materials and materials.
At the same time, when providing our services, we use IT infrastructure, office supplies and electricity,
which is necessary to maintain the continuity of our operations.
So far, we have not taken climate issues into account in the decision-making processes of the XTB Group. The impact
of the primary operating activity (taking into account also the product offer and the source of revenues and costs)
on climate issues can be considered immaterial in comparison to the impact of organisations with a similar scale
of activity and functioning in traditional sectors of the industry or construction. Nevertheless, our intention is to reduce
the impact on the natural environment (including but not limited to the climate) has become one of the basic criteria
taken into consideration when making decisions in the area of business and administrative support.
Last year, we identified our impact on climate issues in the following areas:
● impact on emission of greenhouse gases originating from direct use of fuels,
● indirect impact connected with consumption of purchased electrical and heat energy,
● indirect impact connected with suppliers' activities;
● education of Employees and Associates for the purpose of increase of their climate awareness.
[E.8] Our offer includes ETF (Exchange Traded Fund) financial instruments enabling investments
in climate-conscious entities. We plan to systematically expand this offer. At the same time, if there
is wider interest in products supporting climate risk management (e.g. weather derivatives),
we will conduct a thorough analysis of them.
The climate issues have or may have in the future a potential impact on the following areas:
● legislative changes imposing the obligation to incur capital expenditures limiting energy intensity of IT
infrastructure;
● impact on the possessed product offer in the scope of instruments used for the purpose of climate risk
management;
● possibility of intensification of local, sudden weather phenomena that could have an effect on physical
destruction of office sites and IT infrastructure;
● growing prices of electricity and heat.
Over recent years, we have undertaken the following initiatives in the environmental area:
• initiatives related to energy efficiency of the infrastructure used (e.g. replacement of electronic equipment with
newer and more energy-efficient ones, server virtualization),
• introduction of document digitization, which allows for reduction of paper consumption,
• reduction of waste production as well as waste sorting,
• Employee education and awareness building under the "Natural Investment" programme,
• involvement in the forest planting campaign; In 2023, we planted over 2,000 trees in an area of 1.2 ha.
For more information, see other chapters of this Report.
• transfer of the seat of XTB S.A. – as of January 2022, our headquarters is located at a new site having
a sustainable construction certificate, designed with the environment in mind, as confirmed by the BREEAM
Certificate at the Excellent level. Nearly all of the energy consumed by the Skyliner building in 2023 originated
from renewable energy sources. Proportionally to the energy used in the entire building, the energy consumed
by XTB in the rented space can also be considered as originating from renewable sources.
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• activities in the area of monitoring and calculation of emissions in accordance with the GHG Protocol
and initiatives aimed at reducing the organization's carbon footprint (digitization of documents, control
of media consumption, building Employee awareness, planting a forest in 2023, etc.).
• In order to build climate and environmental awareness, we have supplemented our Business Strategy
with an ESG Strategy implemented in 2021.
Over the next reporting periods, we plan to develop in the area of counteracting climate change by:
• analysing climate opportunities, risks and threats used in the next step to develop the climate policy
of the XTB Group,
• inclusion of previously identified opportunities, risks and climate threats into the internal Risk Management
System at the XTB Group level.
● monitoring of carbon footprint for the organisation, as a target: in three scopes;
● updating the ecological education programme "Natural Investment" and further building climate
and environmental awareness in the XTB Team in subsequent initiatives;
● building the climate and environmental awareness of our business partners through the assumptions of the
ESG Strategy.
5.1. Environmental education programme "Natural Investment"
In 2023, we continued the implementation of the internal ecological education programme entitled
"Natural Investment". Its goal is to increase climate and environmental awareness among XTB Employees
and to build an environmentally responsible organisational culture. We wish to create a friendly
workplace with respect for the natural environment and attentiveness to its well-being and effective use
of natural resources.
The programme aims to encourage Employees to adopt pro-ecological attitudes and reinforce them not only
in the workplace, but also in their private lives. It includes a number of actions aiming at reduction of impact
on the environment, including but not limited to:
● water and electricity saving;
● reducing printing and copying of documents and, thus, saving paper;
● sorting waste in common areas of the office (waste sorting bins with instructions placed in the kitchens);
● collecting plastic caps and transferring them to the collection centre or donating them to support charity
actions;
● promoting environmental days, such as the day without your car;
● gradual replacement of traditional flipcharts with whiteboards;
● not using plastic kitchen accessories in favour of reusable dishes;
● increase in the number of plants in the office space.
The goal of XTB in the environmental area is continuous increase of environmental awareness of Employees. In the first
phase of the programme, the priority is to implement all solutions covered by the programme at the headquarters
of XTB S.A. in Warsaw. Extension of the programme to cover the branches and subseries is planned to achieve cohesion
of the adopted environmental policy in work place.
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5.2. Waste disposal
[E.6.] Providing its services, the XTB Group uses IT infrastructure, office supplies and electricity.
The generated waste includes, first and foremost, IT hardware and municipal waste.
Thus, our business activity is characterised with relatively low impact on the natural environment.
This activity does not cause significant emissions and does not generate significant amounts of waste.
The generated waste is classified as household waste and includes mostly packaging and typical office
waste. Due to the low scale of generated waste, the XTB Group companies were not obliged to registration in the BDO
(Waste Database) register.
Waste sorting is carried out in the offices, appropriate waste sorting bins are placed in XTB kitchens.
The used electronic equipment is regularly transferred to recycling. The equipment transferred to recycling includes
mainly PCs, laptops, screens, telephones and printers. Employees can purchase the replaced computer equipment.
5.3. Consumption of utilities
5.3.1. Fuels and electricity
[E.2] The sources of direct fuel consumption in the XTB Group are a few company cars and power generators. However,
the basic administrative and office activities of XTB and the server room are responsible for the most significant
consumption of electricity and heat in the XTB S.A. Capital Group. Below is information on the direct consumption
of electricity, heat and fuel in the XTB S.A. Capital Group.
Table No. 13. Total consumption of electricity, heat energy and fossil fuels in the XTB S.A. Capital Group and in XTB S.A.
according to the main sources of its acquisition in 2023 and in the comparative period of the previous
year.
Unit
XTB Group
XTB S.A.
2023
2022
Change
y/y
2023
2022
Change y/y
Fuels consumed in the use of own vehicles
Diesel oil
Mg
3.43
2.51
+36.86%
3.43
2.51
+36.86%
MWh
40.98
29.94
40.98
29.94
Petrol
Mg
1.54
1.50
● +2.44%
1.54
1.50
+2.44%
MWh
18.97
18.52
18.97
18.52
Total fuel
consumption in the
use of own vehicles
MWh
59.95
48.46
+23.71%
59.95
48.46
+23.71%
Purchased electricity
Electricity
MWh
1,100.08
1,016.21
+8.25%
1,011.13
994.41
+1.68%
Heat energy purchased
Heat energy
GJ
494.64
319.10
+55.01
494.64
319.10
+55.01
MWh
137.40
88.64
137.40
88.64
Total energy
consumption (heat
and electricity)
MWh
1,237.48
1,104.85
+12.00%
1,148.53
1,083.05
+6.05%
Total energy
consumption from all
sources
MWh
1,297.43
1,153.31
+12.50%
1,208.48
1,131.51
+6.80%
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The increase in the consumption of electricity and heat is related to the increase in the scale of operations in Poland,
expressed by increasing the number of Employees.
In 2023, almost all of the electricity consumed by Skyliner, where the headquarters of XTB S.A. is located, originated
from renewable energy sources. Proportionally to the energy used in the entire building, the energy consumed by XTB
in the rented space can also be considered as originating from renewable sources. Energy consumption is reduced
by energy-saving LED lighting used in the building.
In order to reduce electricity consumption and greenhouse gas emissions, we have been intensifying the virtualization
process of XTB servers for about 2 years. This project involves placing virtual servers on one physically functioning
server. This allows to limit the space used and reduce electricity consumption. Over the last two years, we have reduced
the number of physical servers by 15%, while increasing the number of virtual servers by as much as 72.34%.
In addition to the above activities, we also gradually withdraw old, energy-intensive servers from use, replacing them
with new, more energy-efficient servers from certified suppliers from the European Union. In addition to increased
energy efficiency, they are also characterised by modern solutions such as intelligent adjustment of energy
consumption to the load, which also translates into electricity savings.
5.3.2. Water and sewage
In our daily activities, we pay special attention to conscious and reasonable water management. In the Skyliner office
building, where the headquarters of XTB S.A. is located, all toilets have taps with photocells and aerators to reduce
water consumption as well as flush valves with two-stage adjustment. XTB kitchens have dishwashers and network
water dispensers, which have replaced plastic water bottles.
[E.3.] Supply of water and collection of sewerage is provided by local municipal entities, according to the contracts
concluded with building owners. Due to the location of the seat and offices in office buildings, the Group companies
use only water from water supply systems.
[E.3.1.] Total water consumption in 2023 in the XTB S.A. Capital Group amounted to approximately 1,838 m3.
[E.3.2.] In 2023, the Group did not recover water for reuse.
5.4. Biodiversity
[E.4.1.] [E.4.2.] As our core business is the provision of financial services (online trading in financial instruments)
and the provision of technological solutions, we identify the issue of biodiversity as irrelevant.
We also do not identify any impact on particularly valuable natural areas or fauna and flora, especially those under legal
protection, or on naturally valuable areas in the vicinity of the Group's impact. The leased office space is located
in urban locations, mainly in business centres. Subject to the waste generated in the course of conducted business
activity, the specific sites do not generate any major negative impact on the surrounding.
[E.4.3.] In 2023, no environmental losses resulting from the Company's operations were identified.
[E.4.4.] Together with the "Las na Zawsze" Foundation, we decided to plant over 2,000 trees, thus giving nature back
1.2 ha of a biodiverse deciduous forest in Mieleszkowice Pawłowickie, Podlaskie Voivodeship. A planted forest,
as a self-regulating, complex ecosystem, is not only a CO2 store and an oxygen producer, but also a place for organisms
to live and a haven for biodiversity.
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5.5. GHG emissions
[E.5.1.] [E.5.2.] The nature of our core business is reflected in our significantly limited impact on greenhouse gas
emissions compared to high-emission industries, e.g. manufacturing, construction or energy.
Table No. 14. Greenhouse gas emissions into the atmosphere in the XTB S.A. Capital Group and XTB S.A. in 2023
and in the same period last year.
Type and scope
of emission
Unit
XTB Group
XTB S.A.
2023
2022
Change
y/y
2023
2022
Change
y/y
Scope 1
Emissions resulting
from fuel
consumption
Mg CO2e
14.5
11.9
+21.8%
14.5
11.9
+21.8%
Scope 2 location-based
Emissions related
to energy
consumption
Mg CO2e
723.4
705.2
+2.6%
683.8
694.5
-1.5%
Scope 1 + Scope 2 location-based
Total GHG emissions
Scope 1 + Scope 2
(location based)
Mg CO2e
737.9
717.1
+2.9%
698.3
706.4
-1.1%
In 2023, as a result of the activities of the XTB S.A. Capital Group we emitted a total of 737.9 Mg CO2e (carbon dioxide
equivalent) into the atmosphere through direct emissions (Scope 1) and indirect emissions (Scope 2 location-based),
which means a slight increase (+2.9% y/y). Within the parent company XTB S.A. however, we recorded a slight decrease
in the value of emissions (-1.1% y/y).
The sources of emission rates for Poland were publications of KOBIZE (National Emission Balancing and Management
Centre) and the Energy Regulatory Office. The sources of emission rates for other countries included, in particular,
the UK Government Conversion Factors (Defra) The Issuer presents data on emissions in Scope 2 in accordance with
the location-based methodology. Currently, the process of aggregating information on the carbon intensity of electricity
consumption in accordance with the market-based methodology is in progress, which will be presented
in the Company's next Sustaiability report. In the coming reporting periods, it is planned to expand the emission study
to include the widest Scope 3.
The XTB's intention is taking actions aiming at reduction of carbon footprint and, as a target, reaching climate neutrality
of the organisation, especially through:
● initiatives reducing energy consumption, including but not limiting to the possessed IT infrastructure
(replacement of old, energy-intensive equipment with new, more energy-efficient equipment; server
virtualization),
● use of electricity from renewable sources (almost all electricity used in 2023 by the Skyliner office building,
where the headquarters of XTB S.A. is located, originated from renewable energy sources);
● effective management of resource consumption.
5.6. Other environmental issues
[E.7.2] In the reporting period, there were no failures that resulted in contamination or other damage to the natural
environment.
[E.7.3] [E.7.4] In 2023, there were no administrative proceedings pending against the XTB Group for violations
of environmental regulations and no penalties were imposed.
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5.7. EU non-financial taxonomy
Contextual information – ratios for non-financial undertakings
Regardless of the disclosures on the EU Non-Financial Taxonomy dedicated to investment companies, for the purposes
of this Report, an analysis of the activities indicated in the EU Non-Financial Taxonomy was carried out in relation to:
• assessing the alignment of activities with the Taxonomy for Objectives 1 and 2 (excluding the so-called new
climate activities, i.e. activities that have expanded the scope of activities included in the climate objectives
under Regulation 2023/2485) in total turnover, capital expenditures and operating expenses, and disclosure
of adequate information quality as far as it concerns the above-mentioned ratios for the financial year 2023);
• assessing the eligibility of activities for the Taxonomy for the so-called new climate activities (i.e. activities that
have expanded the scope of activities included in the climate goals under Regulation 2023/2485) and other
environmental goals in total turnover, capital expenditures and operating expenses as well as adequate
qualitative information to the extent related to the above-mentioned ratios for the financial year 2023).
In relation to alignment, the presented rates refer concurrently to the taxonomy related to mitigation of climate changes
and adaptation to climate changes. In relation to eligibility for the Taxonomy, the ratios refer jointly to the remaining
4 environmental objectives and the so-called new climate activities.
With respect to the presented ratios, no changes were made to the calculation of ratios in relation to the alignment
assessment for activities included in the climate objectives presented in the 2022 report.
The Group presents data on the assessment of the eligibility of activities for the so-called new climate activities
and in relation to other environmental objectives for the first time. Therefore, the Group does not have comparative
data for 2022 for these activities.
So far, the Group has not implemented the plan referred to in Point 1.1.2.2. of Annex No. 1 to Commission Delegated
Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament
and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject
to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and
specifying the methodology to comply with that disclosure obligation (Regulation 2178). XTB Group has no investments
in equity accounted in joint ventures, pursuant to IFRS 11 or IAS28. For the purposes of calculating individual ratios,
double recognition of items was avoided by assigning a given item only to expenditure items or capital expenditures.
For calculations related to the turnover ratio in relation to any of the analysed activities, there was no risk of double
entry.
For the purposes of calculating non-financial ratios, no data disaggregation was carried out. For none of the activities
included in the Taxonomy, production was carried out for the so-called own consumption.
a) Turnover ratio
Table No. 15. Turnover ratio - percentage of turnover aligned with the taxonomy in 2023 compared to the same period
of the previous year.
2023
2022
Value of revenues
[PLN thousand]
Proportion of
revenues
[%]
Revenues [PLN
thousand]
Proportion of
revenues [%]
Taxonomy-aligned
activity
0
0.0
0
0.0
Not taxonomy-
aligned activity
1,588,305
100.0
1,444,249
100.0
Total:
1,588,305
100.0
1,444,249
100.0
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For the turnover ratio:
● the basis were consolidated total revenues of the Group in 2023 disclosed in the consolidated financial
statements, i.e. PLN 1,588,305 thousand;
● for the purposes of analysing the numerator for 2023, no revenues from the sale of products and the provision
of services related to the activities of the XTB Group eligible for the Taxonomy were identified
for any of the Taxonomy's objectives, i.e. both for 2 climate objectives and for 4 environmental objectives.
The XTB Group companies did not issue any green bonds or debt securities to finance specific identified types
of taxonomy-aligned activities.
b) CapEx ratio
Table No. 16. CapEx ratio - percentage of capital expenditures aligned with the taxonomy in 2023 compared
to the same period of the previous year.
2023
2022
Capital
expenditures
[PLN thousand]
Proportion of
capital
expenditure [%
Capital
expenditures
[PLN thousand]
Proportion of
capital
expenditure [%
Taxonomy-
aligned activity
PLN 0 thousand
0.0
0
0.0
Not taxonomy-
aligned activity
25,121.8
100
41,771
100
Total:
25,121.8
100.0
41,771
100.0
For the CapEx ratio:
● the basis was the capital expenditure incurred by XTB Group in the amount of ca. PLN 25 121.8 thousand,
calculated according to IAS/IFRS regulations specified in the Annex to Regulation 2178;
● for the purposes of analysing the numerator, no capital expenditures classified as activities included in the EU
non-financial taxonomy for objectives 1 and 2, i.e. two climate objectives, were identified;
● in relation to the remaining 4 environmental objectives and the so-called new climate activities, no capital
expenditures have been identified whose activities would be Taxonomy-eligible.
XTB Group has not adopted any investment plan regarding capital expenditure referred to in point 1.1.2 of Annex No.
1 to Regulation 2178. The Group companies did not issue any green bonds or other securities to finance specific
identified taxonomy-aligned capital expenditure.
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c) Operating expense ratio
Table No. 17. Operating expense ratio - percentage of operating expenses aligned with the taxonomy in 2023 compared
to the same period of the previous year.
2023
2022
Operating capital
expenditure
[PLN thousand]
Proportion
of operating
expense (%)
[%]
Operating
capital
expenditure
[PLN thousand]
Proportion
of operating
expense (%)
[%]
Taxonomy-aligned
activity
0
0.0
0
0.0
Not taxonomy-
aligned activity
89,792.5
100.0
57,461
100.0
Total:
89,792.5
100.0
57,461
100.0
As regards the ratio of operating expenses, the analysis of components of operating expenses was carried out according
to the definition of the EU non-financial taxonomy, showing that the value of the denominator for the turnover ratio
is ca. PLN 89,792.5 thousand. The value specified above includes, in particular, non-capitalised costs of research and
development works amounting in total to ca. PLN 89,066.00 thousand, which accounts for 99.2% of the value
of identified operating expense, and expenses connected with on-going servicing of the Group's fixed assets and their
maintenance in proper condition (including but not limited to costs connected with repairs, renovations or cleaning)
amounting in total to ca. PLN 726.5 thousand.
Considering the business model of XTB Group consisting in supply of products, services and technological solutions
in the scope of trade in financial instruments and due to the fact that the value of identified operating expenses
is considered immaterial from the point of view of the scale of activity of XTB Group, for the purpose of calculation
of the ratio of operating expenses, the option to assign zero as the value of the ratio numerator was used.
The performance tables for the ratios of turnover, capital expenditure and operating expenses, respectively,
are included in point 7.3 of this Report.
At the same time, bearing in mind that the activities of the XTB Group are not related to energy from natural gas and
nuclear energy (so the activities of the XTB Group are not eligible for the activities specified in the Commission Delegated
Regulation (EU) 2022/1214 of 9 March 2022 amending Delegated Regulation (EU) 2021/2139 as regards economic
activities in certain energy sectors and Delegated Regulation (EU) 2021/2178 as regards specific public disclosures for
those economic activities) for all KPIs of non-financial undertakings, the presentation in tables provided in Annex III
to the above-mentioned Regulation is waived.
Contextual information – ratios for investment companies
Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020
on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088
("Taxonomy") provides for the publication by investment firms of information on how and to what extent their activities
are related to and consistent with economic activities that qualify as environmentally sustainable under Article 3 and 9
of the above Regulation.
The Issuer deems it appropriate to explain that, taking into account the specific business model of the XTB Group, which
includes operating on the OTC market, the key disclosure indicators related to the asset portfolio held as a result of the
activity of concluding transactions on own account differ significantly from the significance of these data for other
financial and investment companies.
In particular, it must be noted that while XTB has a portfolio of financial assets, the portfolio of these assets does not
have the nature of a classic investment portfolio. The XTB Group does not engage in financing business activities
or investment projects. However, taking into account the business model of the XTB Group, operating revenues are
generated from the portfolio of financial assets held. The result on financial assets measured at fair value through profit
or loss is the result on financial instruments from transactions with Clients and brokers.
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Table No. 18. Information on the portfolio of assets measured at fair value through profit or loss. The assets included
in this portfolio correspond to assets invested as part of the investment company's own account activities.
As at 31.12.2023
As at 31.12.2022
Value
[in PLN
thousand]
Share in
total
assets of
the
Group
[%]
Share
in financial
assets
measured at
fair value
through
profit or loss
Value
[in PLN
thousand]
Share
in total
assets of
the
Group
[%]
Share in
financial
assets
measured
at fair value
through
profit or loss
Derivatives contracts for
difference (CFDs)
485,303
10.4%
53.7%
470,151
11.4%
55.8%
Debt instruments
(Treasury bonds)
401,265
8.6%
44.4%
362,074
8.8%
43.0%
Stocks and ETFs
16,687
0.4%
1.8%
10,284
0.2%
1.2%
Total assets invested
as part of operation of
an investment
company regarding
trading on own
account
903,255
19.3%
100%
842,509
20.5%
100%
Total assets (balance
sheet total)
4,685,092
100%
n/a
4,114,323
100.0%
n/a
The structure of the financial asset portfolio indicated above consists of:
● derivative instruments - for which the percentage share in total assets invested as part of the activities
of investment companies relating to trading on own account of the exposure referred to in Article 7(2)
of Regulation 2021/2178, i.e. derivatives, is 53.7%.
● treasury bonds - for which the percentage share in total assets invested as part of the activities of investment
companies related to trading on own account of the exposure referred to in Article 7(1) of Regulation
2021/2178, i.e. exposure to central governments, central banks and supranational issuers is 44.4%.
The remaining part of the XTB asset portfolio consists of shares and ETF (Exchange Traded Fund) units. Stocks and ETF
units held account for approximately 1.8% of the above portfolio and 0.2% of total assets. The stocks included
in the portfolio in question constitute security for the transaction of purchase by the XTB Client of the so-called synthetic
action. Therefore, the composition of the stock portfolio results mainly from the structure of orders received from
Clients and brokers. The composition of our stock portfolio is constantly adjusted to subsequent client orders. Due to
the above, the Issuer does not, at any stage of creating the portfolio in question, assess or take into account aspects
that would be related to the eligibility or alignment of given assets from the point of view of the Non-Financial
Taxonomy. The above significantly distinguishes the asset portfolio of the XTB Group from the loan portfolio of a credit
institution or the investment portfolio of an investment fund or a similar entity. In practice, the composition of the non-
financial asset portfolio within the XTB Group may undergo daily, significant and unintentional changes. The structure
of the portfolio, in particular the stock portfolio, is, therefore, almost random from the point of view of the eligibility
of the activities of individual issuers for the Non-Financial Taxonomy.
It must be noted that the technical process of detailed analysis of eligibility in relation to the issuers of individual stocks
included in the portfolio at the end of the reporting period from the point of view of the KPI for non-financial enterprises
would require a significant amount of work. This, in turn, should be assessed as an action that is inadequate
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from the perspective of the XTB Group's operations and its business model in relation to the potential level of usefulness
of the calculated ratios for other market participants.
Thus, for the purposes of disclosures for 2023, the Issuer assumed that the exposure (percentage share) in total assets
invested as part of the activities of investment companies related to trading on their own account to:
• not taxonomy-eligible economic activity is 100%
• taxonomy-eligible economic activity is 0%.
The above applies to:
• objectives 1 and 2, i.e. climate objectives,
• other 4 environmental objectives.
Taking into account the assumption made regarding the non-eligibility of assets for the taxonomy, the Issuer also
assumed that the percentage share in the total assets of the exposure referred to in Article 7(3) of Regulation 2021/2178,
i.e. exposures to enterprises that are not subject to the obligation to publish non-financial information in accordance
with Article 19a or 29a of Directive 2013/34/EU is 0%.
The XTB Group has not introduced any modifications regarding the presentation of the above-mentioned ratios
compared to the previous financial year.
So far, compliance with Regulation 2020/852 has not been taken into account in relation to business strategy, product
design process and cooperation with Clients and contractors. The XTB Group does not conduct activities related
to financing the activities of third parties.
Debt instruments (treasury bonds) were excluded from calculating the numerator and denominator of the KPI. In turn,
derivatives were excluded from the KPI numerator. The companies of the XTB Group did not issue green bonds or green
debt securities aimed at financing specific identified types of activities, and the companies of the XTB Group did not
invest in green bonds and green debt securities issued by third parties. The XTB Group has not granted and does not
have any special-purpose loans in its portfolio.
Taking into account the zero values in the KPI numerators, the Issuer does not present a detailed division of the KPI
numerator into exposures to individual types of financial and non-financial enterprises as well as to derivative
instruments.
At the same time, the Issuer indicates that it will monitor market needs regarding the aggregation and presentation
mode and the usefulness of data provided for disclosures by investment companies in accordance with the target scope
of disclosures provided for in Art. 10 of Regulation 2021/2178.
Minimum safeguards
Pursuant to Article 3 of the EU Non-Financial Taxonomy Regulation
2
, for the purposes of determining the degree
to which an investment is environmentally sustainable, an economic activity qualifies as environmentally sustainable if:
(i) it contributes substantially to one or more of the environmental objectives set out in Article 9 in accordance with
Articles 10 to 16 of this Regulation; (ii) it does not significantly harm any of the environmental objectives set out in Article
9 in accordance with Article 17 of this Regulationb; (iii) it is carried out in compliance with the minimum safeguards laid
down in Article 18; and (iv) it complies with technical screening criteria that have been established by the Commission
in accordance with Articl.e 10(3), 11(3), 12(2), 13(2), 14(2) or 15(2) of the EU Non-Financial Taxonomy
Minimum safeguards, in turn, are the procedures used by an enterprise conducting business activities to ensure
compliance with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business
and Human Rights, including the principles and rights set out in the eight fundamental conventions indicated
in the Declaration of the International Labor Organisation on fundamental principles and rights at work and the
principles and rights set out in the International Charter of Human Rights. When applying the procedures referred to
above, companies comply with the "do no serious harm" rule ("DNSH") referred to in Article 2(17) of the SFDR
3
.
The assessment of compliance with minimum safeguards was carried out by the Company, taking into account, among
others: assessing the level of implementation of the six due diligence steps referred to in the OECD Guidelines
on Due Diligence for Responsible Business Conduct. The assessment was made after analysing the risk of negative effects
for individual principles, values and rights and after assessing the importance of individual issues. The analysis omits
2
Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable
investment, and amending Regulation (EU) 2019/2088,
3
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial
services sector,
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those risks to which the XTB Group contributes on a small scale or contributes only slightly to their occurrence.
The analysis also applied the conclusions presented in the Platform Report
4
and the TEG Report
5
containing conclusions
and interpretations regarding the methods of implementing the guidelines and assessing compliance with minimum
safeguards, taking into account, inter alia, the principle of prioritisation (implementing solutions first in relation
to the principles and values that pose the greatest risk of violation and negative impact) and proportionality (taking into
account the scale and structure of the enterprise and the so-called "position of the enterprise" in terms of the possibility
of influencing cooperators). The study also took into account the requirement to respect the DNSH rule and not to
violate the principles of cooperation with the National Contact Point referred to in Part II of the OECD Guidelines and
the Business & Human Rights Resource Center.
Subject to the reservation made below, in the Company's opinion, in all key areas, individual activities conducted by the
Company, even though they have not been identified as eligible for and aligned with the non-financial taxonomy, both
in relation to XTB S.A. as well as the XTB Group, the vast majority of them meet the requirements of minimum
safeguards referred to in Article 18 of the Regulation on the EU non-financial taxonomy. However, the assessment is
influenced by the fact that it is subject to "final responsibility", i.e. the final finding by the Supreme Administrative Court
in March 2023 that XTB was in violation of the principles and rights set out in Chapter VIII of the OECD Guidelines.
Our due diligence in the responsible conduct of business activities within the XTB Group is reflected in an extensive
compliance system, based on procedures, other regulations and system solutions, the task of which is to ensure
compliance with the principles, values and rights set out, inter alia, in the files referred to above.
Since 2019, XTB has had a Code of Ethics that lays down the basic norms, rules of conduct and values to be observed
by all Employees and associates. It contains provisions regarding:
• ethical principles in mutual relations;
• ethical principles regarding loyalty, integrity and conflict of interest;
• ethical principles regarding gifts and loyalty towards Contractors, Business Partners and retail Clients;
Formal references to respect for human rights within XTB Group are included in Work Regulations and in the Code
of Ethics. Any doubts regarding compliance of conducted activities with aspects related to protection of human rights
must be reported, in accordance with the Code of Ethics, as part of the whistleblowing procedure.
XTB has a whistleblowing procedure in place which determines the rules of submitting by the Employees of anonymous
reports of actual or potential breaches of the law, including breaches of regulations regarding counteracting money
laundering and terrorism financing, internal procedures and ethical standards. Breaches are reported using a dedicated
electronic form ensuring anonymity. The reports are received by the Member of the Management Board for Legal
Affairs, and if the breach regards the Management Board or is Members - by the Supervisory Board. Employees are
obliged by internal regulations, including but not limited to the ethical standards provided for in the Code of Ethics,
to react to any irregularities. Every person has the right and can report the above breaches in a confidential manner
and will be protected against retaliation, discrimination or any other types of unfair treatment, according
to the whistleblowing procedure.
XTB Group has adopted an incentives management policy and conflict of interest management regulations.
Furthermore, all centralised purchases (i.e. made in Poland) are made according to the dedicated goods and services
procurement procedure.
XTB is an obliged entity within the meaning of the law on counteracting money laundering and financing of terrorism.
Considering the need to ensure compliance with the above regulations, XTB has adopted the AML/CFT
6
Procedure
determining detailed solutions, including obligations of Employees of specific departments in the scope
of counteracting money laundering and terrorism financing. The AML Procedure lays down, inter alia, the rules of
conduct and obligations connected with the above area for the Employees of the Sale Department, Global Customer
Support Department, Finance and Accounting Department, Legal and Compliance Department, External Partner
Cooperation Department and IT Development Department. The rules for anonymously reporting violations, including
violations
of anti-money laundering and anti-terrorist financing regulations, are set out in a dedicated procedure.
XTB Group operates in a strictly regulated surrounding, with major obligations imposed on it in the form of many
international and local regulations and laws.
4
“Final Report on Minimum Safeguards, PLATFORM ON SUSTAINABLE FINANCE, OCTOBER 2022”,
5
“Taxonomy: Final report of the Technical Expert Group on Sustainable Finance, March 2020”.
6
AML/ CFT – AML: Anti-money laundering, CFT: Counter-Terrorism Financing.
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On the Group scale, we have established a compliance function for each of the XTB Group companies providing
brokerage services to ensure compliance with the law and regulatory requirements it is subject to. The Legal
and Compliance Department at the XTB Group level is managed by the Department Director who, at the same time,
is the Member of the Management Board for Legal Affairs and reports directly to the President of the Management
Board. The Legal and Compliance Department is divided into the following four teams: Internal Control Team,
Compliance Supervision Team, Operating Support Team as well as Team Counteracting Money Laundering and
Terrorism Financing.
Within the XTB Group, we have adopted a dedicated HR Risk Management Policy laying down the rules and mode
of management of this risk as part of the operating risk management policy. HR risk identification and assessment as
well as risk counteracting methods are carried out and determined by the HR Management Department on a current
basis.
The main role in the field of compliance at XTB is played by the Supervision Inspector acting on the basis
of the Compliance Regulations and the Organisational Regulations of the Legal and Compliance Department. The purpose
of the above regulations is, inter alia, establishing a compliance system, i.e. supervision of compliance of activities with
the law, serving to disclose and prevent violations by XTB of obligations arising from the laws regulating the conduct
of brokerage activities. The goals of the compliance system implemented at XTB are achieved, inter alia, by:
• taking actions aimed at fulfilling the Company's obligations arising from the laws regulating the conduct
of brokerage activities,
• advice and ongoing assistance to persons performing activities as part of the brokerage activities conducted
by XTB in fulfilling their obligations in accordance with the laws regulating the conduct of brokerage activities,
• examining and regularly assessing the adequacy and effectiveness of the adopted compliance system as well
as actions taken to fulfil XTB's obligations arising from the laws regulating the conduct of brokerage activities.
Ensuring the proper operation of the compliance system in XTB branches is the responsibility of the person indicated
in the structure of a given XTB branch, who reports directly to the Supervision Inspector in this respect.
The Supervision Inspector at XTB is primarily responsible for:
• developing and implementing XTB's policy regarding the compliance function and supervising its compliance
by individual XTB organisational units,
• managing the process of identifying and assessing compliance risk in various areas of XTB's operations,
• preparing and presenting to the Management Board and Supervisory Board of XTB a report on the functioning
of the compliance supervision system,
• managing the verification process, analysing the evaluation of information received on violations of internal
regulations in terms of compliance risk.
The compliance risk management process at XTB includes the identification of compliance risks, assessment
of the probability of their occurrence, assessment of the consequences of the occurrence of a given compliance risk,
assigning weights to individual risks, applying risk mitigating measures and documenting the measures used. As part
of the compliance system at XTB, inspection procedures are also conducted in XTB's organizational units in accordance
with generally applicable regulations.
The involvement of the Management Board is also important from the perspective of the functioning of the compliance
system at XTB. As part of the compliance system, the Member of the Management Board for Legal Affairs is responsible,
inter alia, for expressing opinions and making decisions on all legal issues related to XTB, supervising the process
of identifying and assessing compliance risk in various areas of XTB's activities, preparing, implementing and settling
the budget of the Legal and Compliance Department, and supporting the Supervision Inspector in supervising
the compliance of XTB's activities.
At XTB S.A., we also have an effective and adequate set of identified and described processes and procedures
for managing the performance of obligations arising from tax laws and ensuring their correct implementation. We have
appropriate control over our tax processes, which ensures ongoing identification of risks and timely submission of tax
returns containing correct data. Additionally, XTB is able to ensure the proper functioning of internal control
mechanisms in the field of the tax function, has appropriate internal tax supervision procedures, and appropriate
human, technical and financial resources necessary to implement them and maintain supervision over the proper
fulfilment of tax obligations.
For example, we have implemented an instruction specifying the scope of responsibility for the implementation of tasks
related to the Company's settlement of tax liabilities. The procedure specifies the processes for identifying economic
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events giving rise to specific tax consequences, guidelines used to fulfill the obligations of XTB as a taxpayer and payer,
as well as the tasks of individual Employees employed in the Company's organizational units in the process of fulfilling
obligations arising from tax law. The Company also has an internal procedure for preventing failure to comply with
the obligation to provide information on tax schemes. It establishes uniform rules for the application
of the requirements specified in the Tax Ordinance in XTB related to the obligation to submit information on tax
schemes to the Head of the National Tax Administration.
XTB's tax strategy assumes striving to create and maintain an effective, efficient and transparent tax function
in the enterprise, which ultimately ensures compliance with tax regulations and certainty in tax risk control.
In accordance with applicable law, we prepare and publish information on the implemented tax strategy.
Our utmost attention to tax matters is also reflected in our transparency in tax matters and openness to multi-level
cooperation with tax authorities. In 2019, we submitted an application to the Head of the National Tax Administration
to issue a Unilateral Prior Pricing Agreement. The subject of the application was a transaction involving the purchase
of sales support services by XTB from related entities. The Company received a decision regarding the Unilateral
Advance Pricing Agreement at the beginning of 2023 covering the years 2019 - 2023. In mid-2023, we submitted another
application, as a result of which another decision was issued for the years 2024 - 2028.
To sum up, within the XTB Group we have implemented and are constantly developing an advanced and effective,
multi-level compliance system, focused on compliance with the principles and rights expressed, inter alia, in the acts
referred to in Article 18 of the EU Non-Financial Taxonomy Regulation. The compliance supervision system is based on
such key solutions as the adoption of the Code of Ethics, the adoption and implementation of the Compliance
Regulations, and the introduction of the Organisational Regulations of the Legal and Compliance Department.
In addition, we have created and are developing a risk management system, which also covers legal and regulatory
risks. The above activities allow us to conclude that the vast majority of the Company meets the minimum safeguards
requirements referred to in Article 18 of the EU Non-Financial Taxonomy Regulation, subject to Area VIII of the OECD
Guidelines. The areas in which we plan to increase our activity in the development of the compliance system based on
the guidelines indicated in this provision are deepening the structured dialogue with Stakeholders and broadening
the spectrum of supply chain analysis.
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6. Corporate Governance
6.1. XTB’s regulations and procedures
We operate in a strictly regulated surrounding, with major obligations imposed on it in the form of many
international and local regulations and laws.
XTB Group is subject to regulation regarding, inter alia:
• sale practice, including acquisition of Clients and marketing activities;
• maintenance of capitals at a specific level;
• practice in the scope of counteracting money laundering and terrorism financing as well as know
your customer (KYC) procedures;
• obligations regarding reporting to regulators;
• obligations regarding protection of personal data and professional secrecy;
• obligations in the scope of protection of investors and supplying them with information regarding the risk
related to provided brokerage services; and
• supervision over the Group's business;
• confidential information and its use, preventing unlawful disclosure of confidential information, preventing
manipulations on the market;
• disclosing information as an entity listed on the regulated market.
The Group is subject to supervision by competent regulatory oversight authorities and public administration authorities
in the jurisdictions where it operates. Within the Capital Group, we have established a compliance function for each
of the Group companies providing brokerage services to ensure compliance with the law and regulatory requirements
it is subject to.
The Legal and Compliance Department at the XTB Group level is managed by the Department Director who, at the same
time, is the Member of the Management Board for Legal Affairs and reports directly to the President of the Management
Board. The Legal and Compliance Department is divided into the following four teams:
• Internal Control Team,
• Legal Compliance Team,
• Operating Support Team,
• Counteracting Money Laundering and Terrorism Financing Team.
For the purpose of risk management, compliance regulations and a procedure connected with management of legal
and regulatory risk were adopted in the above area. Detailed information on the description and management
of regulatory risk is described in the Management Board's Report on the Operations of the Group and the Company.
As part of due diligence, we have adopted regulations, policies and procedures regulating the activities of XTB S.A.
in specific areas. and XTB Groups, which are described in the chapters to which they apply.
In 2023, no sanctions connected with breach of the law in the scope of environmental protection, human rights,
occupational health and safety, corruption incidents, anti-competitive activities or data confidentiality were imposed
on the XTB Group companies. In 2023, within the XTB S.A. Capital Group, one settlement was concluded in labour law
proceedings.
Detailed information regarding significant or potentially significant court proceedings and proceedings before
administrative bodies is described in the Management Board's Report on the Operations of the Group and Company.
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6.2. Business Ethics
Code of Ethics
[G.4.] We act with due diligence to ensure that the conducted activities comply with the law, internal
regulations, standards recommended for the compliance management system in the scope
of corruption counteracting as well as the whistleblower protection system in stock-exchange listed
companies organised by the Warsaw Stock Exchange (Giełda Papierów Wartościowych w Warszawie
S.A.), rules of community life, good market practice and rules of fair competition, and all decisions
regarding the activity of XTB Group are made in the appropriate mode, based on reliable data
and in a manner mitigating the risk of conflicts of interest.
[S.8.] We are committed to respecting and complying with all human rights and to implementing appropriate due
diligence processes towards our business partners. We express our strong opposition to unfair market practices,
unethical behaviour, forced labour and child labour. We do not accept and do not consent to any manifestations
of discrimination and mobbing.
[G.4.1.] Since 2019, XTB has had a Code of Ethics that lays down the basic norms, rules of conduct and values
to be observed by all Employees and associates.
As XTB Group’s Employees, we are obliged to act in a responsible and ethical manner, observe the rules arising from
the Code of Ethics as well as to act fairly in all activities and contacts with other Employees and professionals.
The Code of Ethics contains provisions regarding:
• ethical principles in mutual relations;
• ethical principles regarding loyalty, integrity and conflict of interest;
• ethical principles regarding gifts and loyalty towards Contractors, Business Partners and retail Clients;
Analogous solutions are applied by subsidiaries through common use of developed rules of procedures and corporate
relations within XTB Group.
[G.4.2.] [G.4.3.] [G.4.4.] [G.4.7.] [S.7.3.] In 2023, we did not carry out ethical audits of suppliers
and did not include ethical or human rights clauses in contracts. Due to the nature of the Company's operations and
many long-term cooperation with partners, we do not identify any risk related to violation of ethical standards. When
establishing cooperation with contractors, we pay attention to available opinions about the entity, credibility
and reputation of the potential partner. In 2023, there was no request to conduct ethical audits within the XTB Group.
[G.4.6.] Ethical issues are an important element of induction training for every newly employed Employee. All new
Employees familiarise with internal procedures and regulations, including the Code of Ethics, and undertake to comply
with their provisions.
Reference to respect for human rights within XTB Group are included in Work Regulations and in the Code of Ethics.
Any doubts regarding compliance of conducted activities with aspects related to protection of human rights must
be reported, in accordance with the Code of Ethics, as part of the whistleblowing procedure.
[G.4.5.] In 2023, there were no complaints regarding potential violations of ethical standards.
XTB S.A. Group continuously monitors the activities of the Group's companies in accordance with the applicable ethical
principles contained in the XTB Group Code of Ethics.
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6.3. Counteracting corruption
[S.10.1.] XTB has not adopted an official corruption counteracting policy. Nevertheless, the nature of conducted
business as well as the regulations regarding XTB Group companies as financial market entities (especially regulations
regarding the area of counteracting money laundering and terrorism financing) impose various restrictions
on the Employees, shaping the awareness of specific organisational units in the scope of ethics of conduct, legal
restrictions in relations with partners as well as sanctions connected with breaching them.
Within the XTB Group, we have adopted an Incentives Management Policy and Conflict of Interest Management Regulations.
Furthermore, all centralised purchases (i.e. in Poland) are made according to the dedicated Goods and Services
Procurement Procedure.
[S.10.2.] [S.10.3.] There were no reported/confirmed cases of corruption within the XTB Group in 2023.
Counteracting money laundering and terrorism financing
XTB is the so-called obliged entity within the meaning of the law on counteracting money laundering and financing
of terrorism.
Considering the need to ensure compliance with the above regulations, XTB has adopted the so-called AML Procedure
determining detailed solutions, including obligations of Employees of specific departments in the scope
of counteracting money laundering and terrorism financing.
The AML Procedure lays down, inter alia, the rules of conduct and obligations connected with the area of counteracting
money laundering and terrorism financing for the Employees of the Sale Department, Global Customer Support
Department, Finance and Accounting Department, Legal and Compliance Department, External Partner Cooperation
Department and IT Development Department.
No irregularities with participation of the Employees of XTB Group were identified in 2023 in the area of counteracting
money laundering and terrorism financing.
6.4. Whistleblowing
XTB has a whistleblowing procedure in place which determines the rules of submitting by the Employees of anonymous
reports of actual or potential breaches of the law, including breaches of regulations regarding counteracting money
laundering and terrorism financing, internal procedures and ethical standards. Breaches are reported using a dedicated
electronic form ensuring anonymity. The reports are received by the Member of the Management Board for Legal
Affairs, and if the breach regards the Management Board or is Members - by the Supervisory Board. Concurrently,
if the local laws or regulations are more stringent than the rules provided for in the above procedure, the more stringent
rules apply.
Employees are obliged by internal regulations, including but not limited to the ethical standards provided for in the
Code of Ethics, to react to any irregularities. Every person has the right and can report the above breaches
in a confidential manner and will be protected against retaliation, discrimination or any other types of unfair treatment,
according to the whistleblowing procedure. All reports are considered with due diligence, reliably, fairly and with full
discretion.
The reports are verified by authorised Employees, which allows for reliable and impartial clarification of any objections.
6.5. Public aid
[S.1.1.] In 2023, XTB was the beneficiary of funds allocated for training for Employees from the National Training
Fund (KFS) as part of de minimis aid. In the area of improving Employee qualifications, the following courses were
carried out in 2023:
• "Customer Service" for 7 people and
• "International Accounting and Financial Reporting Standards (IAS, IFRS)" for 5 people.
The amount of co-financing for training from the KFS was PLN 14,872.00, which constituted 80% of the costs
of continuing education, 20% of the costs of continuing education were borne by XTB S.A. as its own contribution.
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6.6. Data protection
For the purpose of protection of privacy and personal data, the following internal procedures have been introduced:
• Regulations of protection of the flow of confidential information and professional secrets in XTB;
• XTB's personal data protection security policy;
• IT security policy.
[S.13.1.] [S.13.2.] The Personal Data Protection Office is considering the complaint of 1 April 2023 regarding the
processing of the Complainant's personal data contained in e-mail correspondence with the Company without a legal
basis. On 12 June 2023, XTB provided a written response to the Personal Data Protection Office to the letter
of 1 June 2023. The Company is waiting for further developments.
In 2023, singular incidents occurred in the XTB Group related to leakage, theft or loss of information about
Customers/Employees/Associates. Measures have been taken appropriate to the level of risk defined. In particular,
corrective measures were implemented and monitored, the Personal Data Protection Office was notified and the
injured parties were informed.
[S.13.3.] In 2023, no financial penalties were imposed on the Company for non-compliance with laws and regulations
in matters related to the protection of personal data.
6.7. Risk Management System
The purpose of the XTB Risk Management System is to ensure conscious and controlled risk-taking within
the Capital Group. Risk management policies are developed to identify and measure the risks taken as
well as to mitigate them and set appropriate limits to limit the scale of exposure to these risks.
In addition to the Risk Control Department dedicated to this area, which reports directly to the Member
of the Management Board for Risk, the Internal Audit Department was also separated within the organisational
structure of XTB S.A. The managing Internal Auditor reports directly to the Management Board and the Audit Committee
in accordance with the principles provided for in the Internal Audit Regulations.
The tasks of the Internal Audit Department include examining and assessing the correctness and effectiveness
of systems, regulations and internal procedures at XTB in its brokerage activities, in particular the internal control
system. In addition to the above, it also plays an advisory role to other organisational units, including the unit
responsible for ESG and reporting.
The Supervisory Board of XTB S.A. has also a Risk Management Committee composed of the Board members. Detailed
information on risk management in the XTB Group can be found in the Management Board's Report on the Operations
of the Group and the Company for 2023.
6.8. Risk regarding non-financial issues
[G.3.1.] [G.3.2.] Risk related to non-financial issues
Taking into account the specificity of the XTB Group's operations and its business model, the key non-financial aspects
from the point of view of significance for the Group's operations are the following areas: Employee, human rights and
ethics, and counteracting corruption.
Risk related to the employment area
The XTB Group has an HR Risk Management Procedure defining the principles and mode of Employee risk management
as part of the Operating Risk Management Policy.
Risk identification and assessment as well as risk counteracting methods are carried out and determined by the HR
Management Department on a current basis.
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The identified risk factors in the employee area include:
• key Employee turnover,
• psychosocial factors, i.e. stress at work, intensified by isolation caused by the pandemic and remote work,
• long-term absence caused by sickness,
• high Employee turnover,
• insufficiency of highly qualified specialists,
• fraud, embezzlement, unethical practice.
Determination of the impact of the HR risk consists in determination of the expected effects that will affect performance
of tasks and accomplishment of the goals of the organisation. The detailed description of risk management is provided
in the mentioned procedure.
Risk in the area of respect for ethics and human rights
In addition to potential financial consequences, any breaches of commitments, ethical standards or obligations related
to human rights would result in damage to the Group's image, which could affect future relations with Clients
and prospective Clients.
XTB Group identifies impact on social relations in the following areas:
• educational activities;
• respecting human rights.
XTB Group manages the above relations by means of actions in the area of reliable communication, observance
of provisions of the Code of Ethics, transparent cooperation conditions and compliance.
Risk related to counteracting corruption
XTB Group's reliability and transparency in action is key for the image of XTB Group as a trusted provider of solutions
in the scope of trade in financial instruments.
Any corruption incident could have a negative effect on XTB Group, potentially hindering business contacts in the future
and harming the image of XTB Group as a trustworthy and reliable business partner. The activities connected
with corruption risk management regard, in particular, compliance with the Code of Ethics as well as policies,
procedures and regulations described earlier in this Statement.
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7. About the report
7.1. Legal bases
This Sustainability Report of the XTB S.A. Capital Group (hereinafter: "XTB Capital Group", "Group", "XTB
Group") was prepared in compliance with Article 55(2b)-(2c) and Article 49 of the Accounting Act
of 29 September 1994. This Report includes information on companies belonging to the XTB S.A. Capital
Group for 2023 and was prepared based on the Non-Financial Reporting Standard (NFRS) developed by
the Reporting Standards Foundation.
The Report has not been subject to external verification. All information contained in this report applies to the XTB S.A.
Capital Group and its parent company XTB S.A., unless specified otherwise.
This Non-Financial Statement complies, in principle, with NFRS, subject to incompatibility of sectors provided for in NFRS
with the business conducted by XTB S.A. Capital Group as well as substantially limited operating activities of subsidiaries
functioning within XTB Group, making assignment of certain NFRS indices to the business of a specific subsidiary
inexpedient.
7.2. Significance
Significant issues
The following areas where relations of high significance exist are identified in the business activities and management
processes. In the course of work related to the preparation of this Report, the above areas were reviewed, as a result
of which no discrepancies were identified compared to the previous reporting period.
Table No. 19. Selected areas and examples of impact.
Area of relations
Examples of impact
Client relations
● supply of reliable software
● marketing communication
● educational and training activities
Relations with Employees
● ensuring good work conditions
● development of Employees' competences
● educational activities
Relations with regulators
● ensuring compliance of conducted business with local
regulations
● preventing breaches of effective regulations
● prevention of unethical conduct
Occupational health and safety
● ensuring a safe work environment
Impact on the environment
● energy consumption
● environmental education
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Identification of Stakeholders
Considering the nature of the business activity conducted by XTB Group, the following key groups of Stakeholders
are identified for the purpose of management processes:
• Employees of the XTB S.A. Capital Group
• Retail and institutional Clients
• Prospective Clients - persons interested in education regarding financial markets
• Suppliers
• State institutions, including local supervisory authorities
• Media representatives
• Shareholders, Analysts and prospective Investors.
Information about individual groups of Stakeholders of the XTB S.A. Capital Group are included in point 4.1 Relations
with Stakeholders.
The needs and expectations of stakeholders are regularly identified, including identification of legal requirements
and feedback obtained from specific groups of stakeholders.
In the course of work on the preparation of this non-financial report, the list of identified Stakeholders was analysed
and no changes were made compared to the previous reporting period.
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7.3. Performance tables - Non-financial taxonomy
Table No. 20. Turnover ratio.
2023
Year
Criteria pertaining to substantial contribution
Criteria pertaining to DNSH
(“do not do significant harm”) (h)
Economic activity (1)
Code or codes (a) (2)
Turnover (in PLN
thousand) (3)
Part of turnover, year
2023 (4)
Climate change
mitigation (5)
Climate change
adaptation (6)
Water and marine
resources (7)
Pollution (8)
Circular economy (9)
Biodiversity (10)
Climate change
mitigation (11)
Climate change
adaptation (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportion of taxonomy-
aligned activity (A.1.) or
taxonomy-eligible activity
(A.2.) Turnover, year N-1
(18)
Enabling activity category
(19)
Transitional activity
category (20)
Content
Currency
%
Y; N;
N/EL
(b) (c)
Y; N;
N/EL
(b)
(c)
Y; N;
N/EL
(b) (c)
Y; N;
N/EL (b)
(c)
Y; N;
N/EL (b)
(c)
Y;
N;
N/E
L
(b)
(c)
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
%
E
Y
A. TAXONOMY-ELIGIBLE ACTIVITY
A.1. Types of environmentally sustainable activity (taxonomy-aligned)
Turnover on the
environmentally
sustainable
activity
(taxonomy-
aligned) (A.1)
0
0%
N/EL
N/EL
N/EL
N/EL
N/EL
N/E
L
N
N
N
N
N
N
Y
0%
Including enabling
0
0%
0%
0%
0%
0%
0%
0%
N
N
N
N
N
N
Y
0%
E
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Including transitional
0
0%
0%
N
N
N
N
N
N
Y
0%
Y
A.2 Taxonomy-eligible but not environmentally sustainable activity (not taxonomy-aligned activity) (g)
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL (f)
EL;
N/EL (f)
EL;
N/E
L (f)
Turnover on
taxonomy-eligible
but not
environmentally
sustainable
activity (not
taxonomy-aligned
activity) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
A. Turnover on
taxonomy-eligible
activity (A.1+A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
B. NOT TAXONOMY-ELIGIBLE ACTIVITY
A. Turnover on
not taxonomy-
eligible activity
1,588,305
100%
TOTAL
1,588,305
100%
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Table No. 21. CapEx ratio.
2023
Year
Criteria pertaining to substantial contribution
Criteria pertaining to DNSH (“do not do significant
harm”) (h)
Economic activity (1)
Code or codes (a) (2)
Capital expenditure (in PLN
thousand) (3)
Percentage of capital
expenditure, year 2023 (4)
Climate change mitigation
(5)
Climate change adaptation
(6)
Water and marine resources
(7)
Pollution (8)
Circular economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change adaptation
(12)
Water and marine resources
(13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportion of taxonomy-
aligned activity (A.1.) or
taxonomy-eligible activity
(A.2.) Capital expenditure,
year N-1 (18)
Enabling activity category
(19)
Transitional activity category
(20)
Content
Currency
%
Y; N;
N/EL
(b)
(c)
Y; N;
N/EL
(b)
(c)
Y; N;
N/EL
(b) (c)
Y; N;
N/EL
(b) (c)
Y; N;
N/EL
(b) (c)
Y;
N;
N/
EL
(b)
(c)
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
%
E
Y
A. TAXONOMY-ELIGIBLE ACTIVITY
A.1. Types of environmentally sustainable activity (taxonomy-aligned)
Capital
expenditure due to
environmentally
sustainable
activity
(taxonomy-
aligned) (A.1)
0
0%
N/EL
N/EL
N/EL
N/EL
N/EL
N/
EL
N
N
N
N
N
N
Y
0%
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Including enabling
0
0%
0%
0%
0%
0%
0%
0%
N
N
N
N
N
N
Y
0%
E
Including transitional
0
0%
0%
N
N
N
N
N
N
Y
0%
Y
A.2 Taxonomy-eligible but not environmentally sustainable activity (not taxonomy-aligned activity) (g)
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL (f)
EL;
N/EL (f)
EL;
N/
EL
(f)
Capital expenditure
due to taxonomy-
eligible but not
environmentally
sustainable activity
(not taxonomy-
aligned activity) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
A. Capital
expenditure due to
taxonomy-eligible
activity (A.1+A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
B. NOT TAXONOMY-ELIGIBLE
ACTIVITY
A. Capital
expenditure due to
not taxonomy-
eligible activity
25,121.8
100%
TOTAL
25,121.8
100%
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Table No. 22. Operating expense ratio.
2023
Year
Criteria pertaining to substantial contribution
Criteria pertaining to DNSH (“do not do significant
harm”) (h)
Economic activity (1)
Code or codes (a) (2)
Operating expenses (in PLN
thousand) (3)
Percentage of operating
expenses, year 2023 (4)
Climate change mitigation
(5)
Climate change adaptation
(6)
Water and marine resources
(7)
Pollution (8)
Circular economy (9)
Biodiversity (10)
Climate change mitigation
(11)
Climate change adaptation
(12)
Water and marine resources
(13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum safeguards (17)
Proportion of taxonomy-
aligned activity (A.1.) or
taxonomy-eligible activity
(A.2.) Operating expenses,
year N-1 (18)
Enabling activity category
(19)
Transitional activity category
(20)
Content
Currency
%
Y; N;
N/EL
(b)
(c)
Y; N;
N/EL
(b)
(c)
Y; N;
N/EL
(b) (c)
Y; N;
N/EL
(b) (c)
Y; N;
N/EL
(b) (c)
Y;
N;
N/
EL
(b)
(c)
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
%
E
Y
A. TAXONOMY-ELIGIBLE ACTIVITY
A.1. Types of environmentally sustainable activity (taxonomy-aligned)
Operating
expenses due to
environmentally
sustainable
activity
(taxonomy-
aligned) (A.1)
0
0%
N/EL
N/EL
N/EL
N/EL
N/EL
N/
EL
N
N
N
N
N
N
Y
0%
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Including enabling
0
0%
0%
0%
0%
0%
0%
0%
N
N
N
N
N
N
Y
0%
E
Including transitional
0
0%
0%
N
N
N
N
N
N
Y
0%
Y
A.2 Taxonomy-eligible but not environmentally sustainable activity (not taxonomy-aligned activity) (g)
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL (f)
EL;
N/EL (f)
EL;
N/
EL
(f)
Operating expenses
due to taxonomy-
eligible but not
environmentally
sustainable activity
(not taxonomy-
aligned activity)
(A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
A. Operating
expenses due to
taxonomy-eligible
activity
(A.1+A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
B. NOT TAXONOMY-ELIGIBLE
ACTIVITY
Operating expenses
due to not
taxonomy-eligible
activity
89,792.5
100%
TOTAL
89,792.5
100%
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Table No. 23. Summary of key performance indicators to be disclosed by investment companies.
Total environmentally
sustainable assets –
turnover ratio
Total
environmentally
sustainable assets –
capital expenditures
(CAPEX)
KPI – turnover ratio
KPI – capital
expenditures (CAPEX)
% of coverage
in total assets)
Main key performance
indicator
(for the purpose of
trading on own
account)
Green assets ratio
0
0
0%
0%
0%
Total revenues on
environmentally
sustainable activities and
services – turnover ratio
Total revenues on
environmentally
sustainable activities
and services – capital
expenditures (CAPEX)
KPI – turnover ratio
KPI – capital
expenditures (CAPEX)
% of coverage
(in total revenues)
Main key performance
indicator
(for the purpose of
other services and
activities)
Key performance
indicator pertaining to
income
0
0
0%
0%
0%
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Table No. 24. Key performance indicators of investment companies: services of trading on own account.
a
b
c
d
e
f
g
h
i
j
k
l
m
n
Total
(EUR
million)
Including
covered by
key
performance
indicators
(EUR million)
Climate change mitigation (CCM)
Climate change adaptation
Total
Including assets covered by EU taxonomy (%) (taxonomy-
eligible)
Including assets covered by EU taxonomy (%)
(taxonomy-eligible)
Including assets covered by EU taxonomy (%)
(taxonomy-eligible)
Including taxonomy-aligned activity (%)
Including taxonomy-aligned activity
(%)
Including taxonomy-aligned activity
(%)
Including
transitional
(%)
Including enabling (%)
Including
transitional
(%)
Including
enabling (%)
Including
transitional
(%)
Including
enabling (%)
1.
Total assets
invested as part
of operation of
investment
companies
regarding
trading on own
account*
115.45
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2.
including:
on own behalf
115.45
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
3.
including:
on behalf of the
Clients
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
* except for treasury bonds
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Table No. 25. Performance table – key performance indicators of investment companies – other services
a
b
c
d
e
f
g
h
i
j
k
l
m
n
Total
(EUR
million)
Includin
g
covered
by key
perform
ance
indicato
rs (EUR
million)
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Total (CCM+CCA)
Including revenues (fees, commissions and other monetary
benefits) on services and activities for the benefit of sectors
covered by the EU taxonomy (%) (taxonomy-eligible)
Including revenues (fees, commissions and other
monetary benefits) on services and activities for
the benefit of sectors covered by the EU
taxonomy (%) (taxonomy-eligible)
Including revenues (fees, commissions and
other monetary benefits) on services and
activities for the benefit of sectors covered by
the EU taxonomy (%) (taxonomy-eligible)
Including due to activities and services connected
with taxonomy-aligned activity (%)
Including due to activities and
services connected with taxonomy-
aligned activity (%)
Including due to activities and
services connected with taxonomy-
aligned activity (%)
Including
transitio
nal (%)
Including
enabling (%)
Including
transitio
nal (%)
Including
enabling (%)
Including
transitio
nal (%)
Including
enabling (%)
1.
Revenues (i.e. fees,
commissions, and other
monetary benefits) from
investments and
activities and services
other than trading on
own account
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2.
Acceptance and transfer
of orders in connection
with one or more
financial instruments
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
3.
Execution of orders on
behalf of the Client
2.44
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
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4.
Portfolio management
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
5.
Investment advising
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
6.
Underwriting the issue
of financial instruments
or underwriting financial
instruments with a
guarantee of taking over
the issue
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
7.
Placing of financial
instruments without a
guarantee of takeover of
the issue
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
8.
Operating multilateral
trading facilities
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
9.
Operating organised
trading facilities
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
Revenues on commissions regard: fixed fees from institutional partners, regulatory commissions (e.g. for withdrawals below the threshold amount, issuing PIT, etc.), inactivity
fees, for transferring client securities from/to another brokerage house, fee for storing securities of Clients.
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The tables below concern the ratio of total assets invested as part of the activities of investment companies related to trading on own account and
the ratio of revenues related to the execution of orders on behalf of the Client.
Table No. 26. Nuclear energy and fossil gas related activities – scope of activities.
Nuclear energy related activities
1.
The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce
energy from nuclear processes with minimal waste from the fuel cycle.
no
2.
The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for
the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.
no
3.
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes
of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.
no
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.
no
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation
facilities using fossil gaseous fuels.
no
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil
gaseous fuels.
no
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Table No. 27. Nuclear energy and fossil gas related activities – taxonomy-aligned economic activity.
Row
Types of economic activity
Amount and proportion (the information is to be presented in monetary amounts
and as percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI.
0%
0
0%
0
0%
0%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred to in rows
1 to 6 above in the denominator of the applicable KPI
0
0%
0
0%
0
0%
8.
Total applicable key performance indicator
0
0%
0
0%
0
0%
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Table No. 28. Nuclear energy and fossil gas related activities – taxonomy-aligned economic activity (numerator).
Row
Types of economic activity
Amount and proportion (the information is to be presented in monetary amounts
and as percentages)
CCM + CCA
Climate change mitigation (CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred to in
Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
numerator of the applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy-aligned economic activity referred to in
Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
numerator of the applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy-aligned economic activity referred to in
Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the
numerator of the applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy-aligned economic activity referred to in
Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the
numerator of the applicable KPI
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy-aligned economic activity referred to in
Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the
numerator of the applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy-aligned economic activity referred to in
Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the
numerator of the applicable KPI
0%
0
0%
0
0%
0%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred
to in rows 1 to 6 above in the numerator of the applicable KPI
0
0%
0
0%
0
0%
8.
Total amount and proportion of taxonomy-aligned economic activities in the
numerator of the applicable KPI
0
0%
0
0%
0
0%
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Table No. 29. Nuclear energy and fossil gas related activities – taxonomy-eligible but not taxonomy-aligned activity.
Row
Types of economic activity
Amount and proportion (the information is to be presented in monetary amounts
and as percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI.
0%
0
0%
0
0%
0%
7.
Amount and proportion of other taxonomy-eligible but not taxonomy-aligned
economic activities not referred to in rows 1 to 6 above in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned
economic activities in the denominator of the applicable KPI
0
0%
0
0%
0
0%
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Table No. 30. Taxonomy non-eligible economic activities - data for the ratio of total assets investment as part of operation of investment companies regarding trading
on own account.
Row
Types of economic activity
Amount
(EUR million)
%
1.
Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
115.45
100%
2.
Amount and proportion of economic activity referred to in row 2 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
115.45
100%
3.
Amount and proportion of economic activity referred to in row 3 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
115.45
100%
4.
Amount and proportion of economic activity referred to in row 4 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
115.45
100%
5.
Amount and proportion of economic activity referred to in row 5 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
115.45
100%
6.
Amount and proportion of economic activity referred to in row 6 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
115.45
100%
7.
Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above
in the denominator of the applicable KPI
115.45
100%
8.
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable
KPI
115.45
100%
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Table No. 31. Taxonomy non-eligible economic activities - data for the performance indicator of investment companies - other services Commissions and fees regarding
execution of orders on behalf of the Client.
Row
Types of economic activity
Amount
(EUR million)
%
1.
Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-
non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
2.44
100%
2.
Amount and proportion of economic activity referred to in row 2 of Template 1 that is taxonomy-
non-eligible in accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
2.44
100%
3.
Amount and proportion of economic activity referred to in row 3 of Template 1 that is taxonomy-
non-eligible in accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
2.44
100%
4.
Amount and proportion of economic activity referred to in row 4 of Template 1 that is taxonomy-
non-eligible in accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
2.44
100%
5.
Amount and proportion of economic activity referred to in row 5 of Template 1 that is taxonomy-
non-eligible in accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
2.44
100%
6.
Amount and proportion of economic activity referred to in row 6 of Template 1 that is taxonomy-
non-eligible in accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
2.44
100%
7.
Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows
1 to 6 above in the denominator of the applicable KPI
2.44
100%
8.
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of
the applicable KPI
2.44
100%
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7.4. Compliance table
In response to the requirements of the Accounting Act regarding sustainable development reporting, we included
the following information in the XTB Group Report:
Table No. 32. Table of compliance with the Accounting Act.
Issue
Chapter numbers
1. Business model
Chapters no.: 1.2, 2, 4.2, 4.3
2. 2. Key performance indicators
Chapters no.: 2.1, 3.4, 3.5, 3.6, 5.3, 5.5
3. Description of risks and risk management
Chapters no.: 6.7, 6.8
4. Main policies, procedures and significant
documents regulating the operation of the XTB
Group
Chapters no.: 3, 6.1
5. Impact of implemented policies in non-financial areas:
5.1. Personnel issues
Chapter no.: 3
5.2. Social issues
Chapters no.: 3, 4, 4.5, 4.6
5.3. Environmental issues
Chapter no.: 5
5.4. Respecting human rights
Chapters no.: 6.2, 6.4
5.5. Counteracting corruption
Chapter no.: 6.3
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7.5. Approval for publication by the members of the Management Board
of XTB S.A.
This Sustainability Report of XTB S.A. Capital Group for 2023 was approved for publication by the Management Board
of XTB S.A. on 27 March 2024 in Warsaw.
_________________________________________
Omar Arnaout
President of the Management Board
_________________________________________ _________________________________________
Filip Kaczmarzyk Paweł Szejko
Member of the Management Board Member of the Management Board
_________________________________________ _________________________________________
Jakub Kubacki Andrzej Przybylski
Member of the Management Board Member of the Management Board
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