TRANSLATORS’ EXPLANATORY NOTE
The English content of this report is a free translation of the statutory auditor’s report of the below-mentioned Polish Company. In Poland statutory accounts as well as the auditor’s report should be prepared and presented in Polish language and in accordance with Polish legislation, and the accounting principles and practices generally adopted in Poland.
The accompanying translation has not been reclassified or adjusted in any way to conform to the accounting principles generally accepted in countries other than Poland, but certain terminology current in Anglo-Saxon countries has been adopted to the extent practicable. In the event of any discrepancies in interpreting the terminology, the Polish language version is binding.
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp. k. , ul. Polna 11, 00-633 Warsaw, Poland, T: +48 (22) 746 4000,
www.pwc.pl
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp. k. is entered into the National Court Register maintained by the District Court for the Capital City of Warsaw, under KRS number 0000750050, NIP 526-021-02-28. The seat of the Company is in Warsaw at Polna 11.
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Independent Statutory Auditor’s Report
To the General Shareholders’ Meeting and the Supervisory Board of Bank Polska Kasa Opieki S.A.
Report on the audit of consolidated financial statements
Our opinion
In our opinion, the accompanying annual consolidated financial statements:
give a true and fair view of the consolidated financial position of Bank Polska Kasa Opieki S.A. (the “Parent Company”) and its subsidiaries (together the “Group”) as at 31 December 2024 and the Group’s consolidated financial performance and the consolidated cash flows for the year then ended in accordance with the applicable International Financial Reporting Standards as adopted by the European Union and the adopted accounting policies;
comply in terms of form and content with the laws applicable to the Group and the Parent Company’s Articles of Association;
Our opinion is consistent with our additional report to the Audit Committee of the Bank Polska Kasa Opieki S.A. Group issued on the date of this report.
What we have audited
We have audited the annual consolidated financial statements of Bank Polska Kasa Opieki S.A. which comprise:
the consolidated statement of financial position as at 31 December 2024;
and the following prepared for the financial year then ended:
the consolidated statement of profit or loss and other comprehensive income;
the consolidated statement of changes in equity;
the consolidated cash flow statement, and
the notes to consolidated financial statements, comprising material accounting policy information and other explanatory information.
Basis for opinion
We conducted our audit in accordance with the National Standards on Auditing as adopted by the resolutions of the National Board of Statutory Auditors and the resolution of the Council of the Polish Agency for Audit Oversight (“NSA”) and pursuant to the Act of 11 May 2017 on Statutory Auditors, Audit Firms and Public Oversight (the “Act on Statutory Auditors”) and the Regulation (EU) No. 537/2014 of 16 April 2014 on specific requirements regarding the statutory audit of public interest entities (the “EU Regulation”). Our responsibilities under NSA are further described in the Auditor’s responsibilities for the audit of the consolidated financial statements section.
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We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Independence
We are independent of the Group in accordance with “the Handbook of the International code of ethics for professional accountants (including International independence standards) (“Code of ethics”) as adopted by resolution of the National Board of Statutory Auditors and other ethical requirements that are relevant to our audit of the consolidated financial statements in Poland. We have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of ethics. During the audit, the key statutory auditor and the audit firm remained independent of the Group in accordance with the independence requirements set out in the Act on Statutory Auditors and in the EU Regulation.
Our audit approach
Overview
As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the consolidated financial statements. In particular, we considered where the Parent Company’s Management Board made subjective judgements; for example, in respect of significant
The overall materiality threshold adopted for our audit was set at PLN 406 million, which represents 5% of the profit before tax.
We have audited the separate financial statement of the Parent Company and the financial information of subsidiaries, whose financial situation and financial results have, in our opinion, a material impact on the consolidated financial statements.
Estimation of the expected credit losses in the portfolio of loans and advances to customers
Legal risk of mortgage loans in CHF
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Materiality
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Group scoping
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Key audit matters
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accounting estimates that involved making assumptions and considering future events that are inherently uncertain. As in all of our audits we also addressed the risk of management override of internal controls, including among other matters, consideration of whether there was evidence of bias that represented a risk of material misstatement due to fraud.
Materiality
The scope of our audit was influenced by our application of materiality. An audit is designed to obtain reasonable assurance whether the consolidated financial statements are free from material misstatement. Misstatements may arise due to fraud or error. They are considered material if, individually or in aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of the consolidated financial statements.
Based on our professional judgement, we determined certain quantitative thresholds for materiality, including the overall materiality for the consolidated financial statements as a whole , as set out in the table below. These, together with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and extent of our audit procedures and to evaluate the effect of misstatements, if any, both individually and in aggregate on the consolidated financial statements as a whole.
Overall Group materiality
PLN 406 million
How we determined it
Approx. 5% of profit before tax
Rationale for the materiality benchmark applied
We chose profit before tax as the benchmark because, in our view, it is the benchmark against which the performance of the Group is most commonly measured by users, and is a generally accepted benchmark. We chose 5% because, based on our professional judgment, it falls within the range of acceptable quantitative materiality thresholds.
We agreed with the Audit Committee of the Parent Company that we would report to them misstatements of the consolidated financial statements identified during our audit above PLN 20,3 million, as well as misstatements below that amount that, in our view, warranted reporting for qualitative reasons.
How we tailored our Group audit scope
We tailored the scope of our audit in order to perform sufficient work to enable us to provide an opinion on the consolidated financial statements as a whole, taking into account the structure of the Group, the accounting processes and controls, and the industry in which the Group operates.
We have audited the separate financial statement of the Parent Company and the financial information of subsidiaries, whose financial situation and financial results have, in our opinion, a material impact on the consolidated financial statements. The scope of our audit was appropriately tailored in order to cover all material items included in the consolidated financial statements.
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Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the consolidated financial statements of the current period. They include the most significant identified risks of material misstatements, including the identified risks of material misstatement resulting from fraud. These matters were addressed in the context of our audit of the consolidated financial statements as a whole, and in forming our opinion thereon. We do not provide a consolidated opinion on these matters.
Key audit matter
How our audit addressed the key audit matter
Estimation of the expected credit losses in the portfolio of loans and advances to customers
In accordance with International Financial Reporting Standard 9 Financial Instruments (“IFRS 9”), the Management Board is required to determine the value of expected credit losses (“ECL”) that may occur over a 12-month period or in a lifetime horizon of a financial asset, depending on the classification of individual assets into risk categories (“Stages”), taking into account the impact of future macroeconomic conditions on the level of credit risk provisions.
The Group's credit portfolio includes exposures for which the level of expected credit losses is estimated:
individually for individually significant credit exposures and
using the portfolio method using statistical models, for each of the homogeneous portfolios identified by the Bank.
Expected credit losses as at 31 December 2024 amounted to PLN 5,898 million in the portfolio of loans and advances to customers with a gross value of PLN 180,316 million.
Estimating the level of the allowance for expected credit losses requires the application of a significant judgment with respect to the identification of impaired loans and significant increases in credit risk, the assessment of the customer’s credit quality, the value of collateral, and expected recoveries.
Management monitors the performance of the models by comparing the results estimated by the models to actual credit losses (backtesting procedures) to ensure that the level of the
As part of our procedures, we gained an understanding of the internal control policies and procedures relating to the recognition and calculation of expected credit losses, and we verified the effectiveness of selected key controls implemented by the Group, in particular:
procedures for entering customer data used for the calculation of expected credit losses;
procedures for the timely and complete identification of significant increases in credit risk (Stage 2) and impairment (Stage 3).
We also assessed whether the methodology used by the Group to estimate allowances for expected losses is consistent with the requirements of IFRS 9. In particular, we assessed the Group’s approach to applying the significant increases in credit risk identification criteria, the definition of default, the probability of default (“PD”) parameters, the loss given default (“LGD”) and taking into account forecasted macroeconomic information when calculating expected credit losses.
For individually immaterial loans and advances that are assessed for impairment on a portfolio basis, we performed, in particular, the following procedures:
assessment of the Group’s assumptions and expert adjustments used in the model;
critical analysis of key judgments and assumptions, including macroeconomic scenarios and assumed probabilities of individual scenarios;
independent tests of credit risk parameters;
sample-based verification of the assignment of exposures to the appropriate Stages.
We engaged our internal credit risk modelling
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allowance for expected credit losses on loans and advances to customers is appropriate.
The Group uses large amounts of data in its expected credit loss models, and therefore the completeness and reliability of data can significantly impact the accuracy of the calculation of the allowance for expected credit losses. We considered the estimation of the allowance for expected credit losses for the loan and advances portfolio to be a key audit matter due to:
• the significant judgment applied by Management in modeling future scenarios and forecasting macroeconomic variables, and in assuming the likelihood of each scenario occurring;
• the high degree of uncertainty associated with the estimation of the allowance for expected credit losses;
• the complexity of the audit procedures and audit evidence obtained due to the level of complexity of the calculations and the amount of data used to estimate the allowance for expected credit losses.
Note 11 Net allowance for expected credit losses, Note 22 Loans and advances to customers, Note 45.2. Risk management and fair value – Credit risk in the consolidated financial statements contain detailed information on the methods and models used and the level of expected credit losses in the portfolio of loans and advances to customers.
specialists to perform the above procedures.
As part of the work on exposures analysed individually, we performed the following procedures:
we applied our professional judgment in selecting the sample, taking into account various risk criteria;
for selected loans and advances, we checked the classification into Stages as at the balance sheet date;
for selected impaired loans and advances (Stage 3), we tested the assumptions used in calculating impairment losses, in particular the anticipated scenarios and their assigned probabilities, and the dates and amounts of expected cash flows, including cash flows from repayments and realisation of collateral.
In addition, we performed the following procedures:
reconciled selected input data used to determine default parameters and estimate expected credit losses;
recalculated expected credit losses on a sample of credit exposures;
we performed analytical procedures in the scope of credit portfolio coverage with expected credit losses and their changes during the audited year and transfer of exposures between baskets;
we performed an analysis of events after the balance sheet date in terms of the potential need to make adjustments to the estimates of expected losses at the balance sheet date;
we analyzed the results of the sensitivity analysis conducted by the Management Board of the level of allowances for expected credit losses as a result of deterioration or improvement in risk parameters.
We also assessed the adequacy and completeness of disclosures in the consolidated financial statements in accordance with the applicable accounting standards.
Legal risk of mortgage loans in CHF
As at the balance sheet date, the Group had a portfolio of mortgage loans denominated and indexed to CHF in the total gross amount of PLN 1,470 million before taking into account the
As part of our audit, we assessed whether the accounting approach applied by the Group is consistent with IFRS 9 and IAS 37. Due to the change in the accounting policy regarding the recognition of legal risk, we began our work by understanding and assessing the changes in the
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reduction of contractual cash flows due to legal risk.
As described in Note 45.3 Risk management and fair value – Legal risk related to foreign currency mortgage loans in CHF of the consolidated financial statements, the loan agreements on the basis of which these loans were granted contain clauses challenged by customers in court on charges of abusiveness. At present, a negative trend for banks is observed in relation to court judgments, which affects both the increase in the estimated probability of unfavorable decisions in disputes for banks and the increase in expected future court cases.
As described in Note 45.3, since 2 October 2023, the Group has been entering into voluntary settlements with customers. Settlements with customers result in the setting of a new debt balance, expressed in PLN and calculated as the amount of the loan paid by the Group, increased by contractual interest accrued at a fixed interest rate of 2% per annum and reduced by all repayments made by the borrower until the settlement was concluded.
As at the balance sheet date, the Group estimated the costs to cover legal risk, both for the active portfolio and for loans repaid before the balance sheet date. In the consolidated financial statements, the Group recognized the estimate of these costs, for active loans based on point B5.4.6 of IFRS 9 by adjusting the gross carrying amount of the portfolio by reducing contractual cash flows from mortgage loans in CHF, and in the case where the estimated loss from legal risk exceeds the gross carrying amount of the loan for repaid loans, as well as in relation to costs related to a potential loss of a legal dispute, including statutory interest, by recognizing a provision in accordance with International Accounting Standard 37 Provisions, Contingent Liabilities and Contingent Assets (“IAS 37”). The estimated level of reduction of the gross carrying amount of the active portfolio as at 31 December 2024 amounted to PLN 1,193 million, while the level of provisions created amounted to PLN 1,308 million.
methodology for estimating losses on legal risk of CHF mortgage loans.
We focused on assessing the Group’s approach to estimating the costs of legal risk of CHF mortgage loans, as well as the scope of disclosures included in the consolidated financial statements.
Our procedures were mainly focused on critically assessing the methodology and individual assumptions adopted by the Management Board that have a significant impact on the level of reduction of the gross carrying amount of the portfolio and recognised provisions.
In particular, we carried out the procedures listed below:
we assessed the design and implementation of monitoring and internal controls as part of legal risk management and in the process of estimating the reduction of the gross carrying amount of the portfolio and recognised provisions;
we conducted discussions with the Management Board and specialists, including the Group’s lawyers, on the adopted assumptions taking into account historical observations;
we analysed the documentation and legal opinions as well as historical data concerning previous court judgments for the purposes of estimating the probability of losing court disputes;
we analysed the methodology documentation;
we analysed the results of the backtesting of the methodology for estimating the costs of legal risk of mortgage loans in CHF;
credibility procedures:
o we verified on a sample the restatements in connection with the change in the methodology for recognising the impact of legal risk;
o we analysed the results of the settlement programme conducted;
o we verified the assumptions adopted by the Group regarding the expected resolutions of court cases, together with the estimation of the probability of these resolutions based on the current line of court case law;
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The costs of legal risk of CHF mortgage loans were estimated using a statistical method, taking into account the forecast of future disputes, the probability of losing the cases and the financial effects of current and future cases in the time horizon in which the Group is exposed to such risk and taking into account the settlement program.
Estimates of the costs of legal risk of CHF mortgage loans are complex and require a significant judgment, in particular with respect to the assumptions regarding:
the forecasted number of future lawsuits for both active and repaid loans, due to the significant historical variability of the number of lawsuits received and the uncertainty as to the willingness of customers to file a lawsuit in the future;
the financial effects of the resolutions of current and future lawsuits;
the forecasted duration of lawsuits, which is the basis for estimating the level of statutory interest.
Due to the change in accounting policy regarding the recognition of the impact of legal risk resulting from court proceedings, the significant impact on the Group's result, the complexity and uncertainty of the assumptions adopted to estimate the costs of legal risk of CHF mortgage loans, we considered this area to be a key audit matter.
Note 45.3 Risk management and fair value – Legal risk related to CHF mortgage loans, Note 19 Loans and credits loans granted to customers contain detailed information on the assumptions used to calculate the adjustment to the gross carrying amount of the CHF mortgage loan portfolio and the provisions made, as well as the possible alternative outcomes presented in the sensitivity analysis of the estimate.
o we verified the method of calculating the value of potential losses under the scenario assumed by the Group of losing court cases (cancellation);
o we verified the data entered into the statistic model used to estimate the probability of future lawsuits in relation to active loans and repaid loans;
o we verified the assumptions for estimating the provisions for statutory interest;
o we checked the correctness and completeness of the data constituting the basis for the calculations performed in the Group's methodology (by applying detailed testing regarding the completeness and correctness of the input data to the model);
o we confirmed on a sample, the mathematical correctness of the model calculations;
o we verified on a sample the correctness of the settlement of the concluded settlements and final;
o we analyzed the methodology for determining the impact of CHF loans on future tax liabilities and the calculation of the deferred tax asset.
We also assessed the adequacy and completeness of the disclosures in the consolidated financial statements in accordance with the applicable accounting standards, including disclosures regarding the restatement of comparative data.
Responsibility of the Management of the Parent Company for the consolidated financial statements
The Management Board of the Parent Company is responsible for the preparation of the annual consolidated financial statements that give a true and fair view of the Group’s financial position and results of operations, in accordance with International Financial Reporting Standards as adopted by the European Union, the adopted accounting policies, the applicable laws and Parent Company’s Articles of Association, and for such internal control as the Parent Company’s Management Board determines is necessary to enable the preparation of consolidated financial statements that are free from material misstatement, whether due to fraud or error.
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In preparing the consolidated financial statements, the Parent Company’s Management Board is responsible for assessing the Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Parent Company’s Management Board either intends to liquidate the Parent Company or to cease operations, or has no realistic alternative but to do so.
The Parent Company’s Management Board and members of the Supervisory Board are obliged to ensure that the consolidated financial statements comply with the requirements specified in the Accounting Act of 29 September 1994 (“the Accounting Act”). Members of the Supervisory Board are responsible for overseeing the financial reporting process.
Auditor’s responsibility for the audit of the consolidated financial statements
Our objectives are to obtain reasonable assurance about whether the consolidated financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with the NSA will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in aggregate, they could reasonably be expected to influence economic decisions of users taken on the basis of these consolidated financial statements.
The scope of the audit does not include an assurance on the Group’s future profitability nor the efficiency and effectiveness of conducting its affairs by the Parent Company’s Management Board, now or in future.
As part of an audit in accordance with NSA, we exercise professional judgement and maintain professional scepticism throughout the audit. We also:
identify and assess the risks of material misstatement of the consolidated financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control;
obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Group’s internal control;
evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by the Parent Company’s Management Board;
conclude on the appropriateness of the Parent Company’s Management Board’s use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Group’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the consolidated financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the Group to cease to continue as a going concern;
evaluate the overall presentation, structure and content of the consolidated financial statements, including the disclosures, and whether the consolidated financial statements represent the underlying transactions and events in a manner that achieves fair presentation;
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plan and perform the Group audit to obtain sufficient appropriate audit evidence regarding the financial information of the entities or business units within the Group as a basis for forming an opinion on the consolidated financial statements. We are responsible for the direction, supervision and review of the audit work performed for the purpose of the Group audit and we remain solely responsible for our audit opinion.
We communicate with the Audit Committee of the Parent Company regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide the Audit Committee of the Parent Company with a statement that we have complied with relevant ethical requirements regarding independence, and communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, actions taken to eliminate threats or safeguards applied.
From the matters communicated to the Audit Committee of the Parent Company, we determine those matters that were of most significance in the audit of the consolidated financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor’s report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.
Other information
Other information
Other information comprise:
a Report on the operations of the Bank Pekao S.A. Group for the financial year ended 31 December 2024 prepared together with the report on the operations of Bank Pekao S.A. (“the Report on the operations”) and the corporate governance statement which is a consolidated part of the Report on the operations,
other documents comprising the Annual Report for the financial year ended 31 December 2024 (“the Annual Report”),
(together “Other Information”) .
Other information does not include the financial statements and our auditor’s report thereon.
Responsibility of the Management and Supervisory Board of the Parent Company
The Management Board of the Parent Company is responsible for the preparation of the Other Information in accordance with the law.
The Parent Company’s Management Board and the members of the Supervisory Board are obliged to ensure that the Report on the operations including its consolidated part complies with the requirements of the Accounting Act.
Statutory auditor’s responsibility
Our opinion on the consolidated financial statements does not cover the Other Information.
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In connection with our audit of the consolidated financial statements, our responsibility under NSA is to read the Other Information and, in doing so, consider whether the Other Information is materially inconsistent with the information in the consolidated financial statements, our knowledge obtained in our audit, or otherwise appears to be materially misstated. If, based on the work performed, we identified a material misstatement in the Other Information, we are obliged to inform about it in our audit report.
In accordance with the requirements of the Act on the Statutory Auditors, we are also obliged to issue an opinion on whether the Report on the operations, to the extent not related to sustainability reporting, has been prepared in accordance with the law, is consistent with information included in annual consolidated financial statements and to issue a statement as to whether, in the light of the knowledge about the Group and its environment obtained during the audit, any material misstatements have been identified in the Report on the operations to the extent not related to sustainability reporting, and an indication of what any such material misstatement is.
Moreover, we are obliged to issue an opinion on whether the Group provided the required information in its corporate governance statement .
In addition, we are required to audit the financial information included in item 8 of the Report on the operations in accordance with the scope described in this audit report and the requirements of the act of 29 August 1997 on the banking law (“the Banking Law”).
Statement on the Other information
We declare, based on the knowledge of the Group and its environment obtained during our audit, that we have not identified any material misstatements in the Report on the operations, to the extent not related to sustainability reporting, and in the remaining Other information.
The Report on the operations, to the extent related to sustainability reporting, for the financial year ended 31 December 2024 was the subject of a consolidated limited assurance engagement, from which a report was issued on 26 February 2025, containing unmodified opinion.
As part of our procedures under the NSA, we also have not identified any material misstatements in the Report on the operations, to the extent related to sustainability reporting.
Opinion on the Report on the operations to the extent not related to sustainability reporting
Based on the work we carried out during our audit, in our opinion, the Report on the operations, to the extent not related to sustainability reporting:
has been prepared in accordance with the requirements of Article 49 of the Accounting Act and para. 71 of the Regulation of the Minister of Finance dated 29 March 2018 on current and periodical information submitted by issuers of securities and conditions for considering as equivalent the information required under the legislation of a non-Member State (“Regulation on current information”) and Article 111a(1–2) of the Banking Law;
is consistent with the information in the consolidated financial statements.
Opinion on the corporate governance statement
In our opinion, in its corporate governance statement, the Group included information set out in para. 70.6 (5) of the Regulation on current information. In addition, in our opinion, information specified in paragraph 70.6 (5)(c)–(f), (h) and (i) of the said Regulation included in the corporate governance statement are consistent with the applicable provisions of the law and with information included in the consolidated financial statements.
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Report on other legal and regulatory requirements
Report on the compliance of the marking up of consolidated financial statements with the requirements of the European Single Electronic Format (“ESEF”)
In connection with the audit of consolidated financial statements we have been engaged by the Parent Company’s Management Board as part of our audit engagement letter to conduct a reasonable assurance engagement to express an opinion whether the consolidated financial statements of the Group as at and for the year ended 31 December 2024 prepared in the single electronic format contained in the file named SSF_Grupy_Banku_Pekao_31.12.2024.zip (the “consolidated financial statements in the ESEF format”) was marked up in accordance with the requirements in the article 4 of the Commission Delegated Regulation (EU) 2019/815 of 17 December 2018 supplementing Directive 2004/109/EC of the European Parliament and of the Council with regard to regulatory technical standards on the specification of a single electronic reporting format (the “ESEF Regulation”).
Description of a subject matter and applicable criteria
The consolidated financial statements in the ESEF format were prepared by the Parent Company’s Management Board to comply with the technical requirements regarding the specification of a single electronic reporting format and marking up, which are set out in the ESEF Regulation.
The subject matter of our assurance engagement is the compliance of the consolidated financial statements in the ESEF format with the requirements of the ESEF Regulation and the requirements of this regulation, in our view, constitute appropriate criteria to form an opinion.
Responsibility of the Management Board and the Supervisory Board of the Parent Company
The Parent Company’s Management Board is responsible for the preparation of the consolidated financial statements in the ESEF format in accordance with the technical requirements regarding the specification of a single electronic reporting format which are set out in the ESEF Regulation. This responsibility includes the selection and application of appropriate markups in iXBRL using taxonomy specified in the ESEF Regulation. The responsibility of the Management Board of the Parent Company also includes designing, implementing and maintaining internal controls relevant for the preparation of the consolidated financial statements in the ESEF format which are free from material non-compliance with the requirements of the ESEF Regulation and their marking-up in compliance with these requirements.
Members of the Parent Company’s Supervisory Board are responsible for overseeing the financial reporting process, which also includes the preparation of the consolidated financial statements in accordance with the format that is compliant with legal requirements.
Our responsibility
Our objective was to express an opinion, based on the conducted reasonable assurance engagement, whether the consolidated financial statements prepared in the ESEF format were marked up, in all material respects, with the requirements of the ESEF Regulation.
We conducted our engagement in accordance with the National Standard on Assurance Engagements other than Audit and Review 3001PL – “Audit of financial statements prepared in the single electronic reporting format” (“KSUA 3001PL”) and where relevant with the National Standard on Assurance Engagements 3000 (R) in the wording of the International Standard on Assurance Services 3000 (Revised) - ‘Assurance Engagements other than Audits and Reviews of Historical Financial Information’ (“KSUA 3000(R)”).
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These standards require that we plan and perform procedures to obtain reasonable assurance whether the consolidated financial statements in the ESEF format were marked up, in all material respects, in compliance with the specified criteria.
Reasonable assurance is a high level of assurance, but it does not guarantee that the engagement performed in accordance with KSUA 3001PL and, where relevant, in accordance with KSUA 3000 (R) will always detect the material misstatement (significant non-compliance with the requirements).
The selection of the procedures depends on the auditor's judgement, including the auditor's assessment of the risk of material misstatements, whether due to fraud or error. In performing the assessments of this risk, the auditor shall consider the internal control related to the preparation of the consolidated financial statements in the ESEF format in order to plan appropriate procedures to provide the auditor with sufficient evidence appropriate to the circumstances. The assessment of the functioning of the internal control system was not carried out in order to express an opinion on the effectiveness of its operation.
Quality management and ethical requirements
We apply the National Standard on Quality Control 1 in the wording of the International Standard on Quality Management (PL) 1 – “Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements” as issued by the International Auditing and Assurance Standards Board and adopted by the resolution of the Council of the Polish Agency for Audit Oversight (“NSQC 1”). In accordance with the requirements of NSQC 1, we operate a system of quality management including documented policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.
When performing the engagement, we have complied with the independence and other ethical requirements in the Code of ethics. The Code of ethics is founded on fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour. We also complied with other independence and ethical requirements that apply to this assurance engagement in Poland.
Summary of the work performed
Our planned and performed procedures were aimed at obtaining reasonable assurance whether the consolidated financial statements in the ESEF format were marked-up, in all material respects, in compliance with the applicable requirements. Our procedures included in particular:
obtaining an understanding of the process of preparation of the consolidated financial statements in the ESEF format, including the process of selection and application by the Group of the XBRL tags and ensuring the compliance with the ESEF Regulation, including understanding the mechanism of the internal control system related to this process;
reconciliation, on a selected sample, of the marked-up information contained in the consolidated financial statements in the ESEF format to the audited consolidated financial statements;
evaluating of compliance with the technical standards regarding the specification of a single electronic reporting format, including the use of XHTML, using a specialised IT tool;
evaluating the completeness of marking up the consolidated financial statements in the ESEF format using the iXBRL tags;
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evaluating the appropriateness of the use of XBRL tags selected from the taxonomy defined in the ESEF Regulation and whether the extension markups were used appropriately where no suitable element in taxonomy defined in the ESEF Regulation has been identified;
evaluating the appropriateness of anchoring of the extension elements to the ESEF taxonomy from the ESEF regulation.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Opinion
In our opinion, based on the procedures performed, the consolidated financial statements in the ESEF format were marked-up, in all material respects, in compliance with the requirements of the ESEF Regulation.
Information on compliance with prudential regulations
The Management Board of the Parent Company is responsible for complying with the applicable prudential regulations set out in consolidated legislation, and in particular, for correct determination of the capital ratios.
The capital ratios as at 31 December 2024 have been presented in Note 45.8 of the consolidated financial statements and include core Tier 1 capital ratio, Tier 1 capital ratio and the total capital ratio.
We are obliged to inform in our report on the audit of the consolidated financial statements whether the Group has complied with the applicable prudential regulations set out in consolidated legislation, and in particular, whether the Group has correctly determined its capital ratios. For the purposes of the said information, the following legal acts are understood as consolidated legislation: Regulation (EU) no. 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012, as amended (“CRR”), the Banking Law and the Act of 5 August 2015 on macro-prudential supervision over the financial system and on crisis management in the financial system (“the Act on macro- prudential supervision”).
It is not the purpose of an audit of the consolidated financial statements to present an opinion on compliance with the applicable prudential regulations specified in the consolidated legislation specified above, and in particular, on the correct determination of the capital ratios, and therefore, we do not express such an opinion.
Based on the work performed by us, we inform you that we have not identified:
any cases of non-compliance by the Group with the applicable prudential regulations set out in consolidated legislation referred to above, in the period from 1 January to 31 December 2024;
any irregularities in the determination by the Group of the capital ratios as at 31 December 2024 in accordance with the consolidated legislation referred to above;
which would have a material impact on the consolidated financial statements.
Statement on the provision of non-audit services
To the best of our knowledge and belief, we declare that the non-audit services prohibited under Article 5(1) of the EU regulation and Article 136 of the Act on Statutory Auditors were not provided and the non-audit services that we provided to the Parent Company and its controlled entities within the European Union are in accordance with the applicable laws and regulations in Poland.
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The non-audit services which we have provided to the Parent Company and its controlled entities within the European Union during the period from the beginning of the audited period to the date of issuing this report are disclosed in the Report on the operations.
Appointment
We have been appointed to audit the annual consolidated financial statements of the Group by the Resolution of the Supervisory Board of the Parent Company of 7 November 2023. The consolidated financial statements of the Group were audited by us for the first time.
The Key Statutory Auditor responsible for the audit on behalf of PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k., a company entered on the list of audit firms with the number 144., is Agnieszka Accordi.
Original report is signed in Polish language
Agnieszka Accordi
Key Statutory Auditor
No. in the registry 11665
Warsaw, 26 February 2025