Management Report of XTB Group and XTB S.A. in 2024
/ Table of Contents
MANAGEMENT REPORT OF
XTB GROUP AND XTB S.A.
IN 2024
2
Management Report of XTB Group and XTB S.A. in 2024
/ Disclaimer
DISCLAIMER
This document is an unofficial translation of the Polish version of Consolidated Annual Report for 2024 and does not constitute a current or periodical report as
defined under the Regulation of the Minister of Finance on the current and periodical information provided by issuers of securities and the conditions for
considering the information required by the provisions of law of the state not being a member state as equivalent thereto that was issued in accordance with the
Polish Act on Public Offering, the Conditions Governing the Introduction of Finance Instruments to Organised Trading, and Public Companies dated 29 July
2005 (amended and restated: Journal of Laws of 2020, item 2080 with subsequent amendments).
This document is for informational purposes only. Neither the Company, its shareholders, nor any of their advisors are responsible for translation errors, if any,
or for any discrepancies between the original report and this translation into English. If there are any discrepancies between the English translation and the
Polish version, the latter shall prevail.
3
Management Report of XTB Group and XTB S.A. in 2024
/ Table of Contents
Table of contents
Introduction ..........................................................................................................................4
Letter from the Chairman of the Management Board ...............5
Selected consolidated financial data ........................................8
Selected standalone financial data ........................................ 10
Synthetic summary of data concerning the Company and the
Capital Group for the year 2018-2024 .................................... 12
Summary of 2024 ................................................................... 15
XTB Group .......................................................................................................................... 17
General information ............................................................... 18
Organizational structure of the XTB S.A. Capital Group ........ 19
Board ..................................................................................... 25
History of development .......................................................... 29
Mission, vision, and values .................................................... 30
Brand ..................................................................................... 31
Products ................................................................................. 34
Employees and employment .................................................. 37
XTB on the stock market ........................................................ 39
Business model .................................................................................................................. 43
Business model ...................................................................... 44
Operating markets ................................................................. 46
Clients .................................................................................... 47
Marketing – Reach Channels ................................................. 50
Factors that affect the operations of the Group and the
Company................................................................................ 51
Strategy and operations ................................................................................................... 61
Development strategy and its implementation in 2024 ........... 62
Product plan in 2024 .............................................................. 65
Significant Achievements in the Field of Research and
Development .......................................................................... 68
ESG Strategy and Management ............................................ 70
Stakeholder relations ............................................................. 73
Financial results and dividend ........................................................................................ 74
Description of the consolidated financial result achieved in
2024 and the factors affecting it ............................................ 75
Structure of assets and liabilities of the balance sheet .......... 86
Discussion of the separate financial result achieved in 2024
and the factors affecting it ..................................................... 98
Structure of separate assets and liabilities of the balance sheet
............................................................................................ 103
Selected financial and operational ratios of XTB S.A. ......... 105
Risk management ........................................................................................................... 111
The main features of internal control and risk management in
relations to the process of preparing separate and
consolidated financial statements ....................................... 112
Risk management and internal audit system ....................... 112
Risk factors and threats....................................................... 114
Corporate governance .................................................................................................... 128
Statement on the applied corporate governance rules in 2024
............................................................................................ 129
Shares and shareholding structure ..................................... 132
XTB Statutory Bodies .......................................................... 135
Corporate culture and key policies for business conduct .... 171
Other information ........................................................................................................... 173
Audit company authorized to audit the financial statements 174
The information on the significant court proceedings,
arbitration authority or public administration authority ........ 175
Court proceedings ............................................................... 175
Administrative and control proceedings............................... 176
Sustainability Statement of the XTB S.A. Capital Group .............................................. 178
General information ............................................................. 183
Environment ........................................................................ 246
Society ................................................................................ 287
Governance ......................................................................... 312
Statement of the Management Board ........................................................................... 351
Statement and information of the Management Board ........ 352
4
Management Report of XTB Group and XTB S.A. in 2024
/ Table of Contents
Introduction
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
5
Management Report of XTB Group and XTB S.A. in 2024
/ Letter from the Chairman of the Management Board
Letter from the Chairman of the
Management Board
“One of the most important business goals is for XTB to become a global
brand and the first choice for people who are interested in managing their
finances effectively. Achieving this plan requires expanding our offer with
new products and improving our platform and mobile application. I believe
this will lead to exceeding 2 million clients in the coming year. We want to
strengthen our position not only in areas we are already a leader, but also
in very competitive markets in the United Kingdom, France and Germany.
At the same time, we are preparing to enter completely new regions, such
as Indonesia and Brazil. Realizing of these ambitious plans requires
a significant increase in marketing costs - up to 80% y/y. This is necessary
to consciously build the brand image and increase our market share."
Dear All,
In 2024, we celebrated our 20th anniversary – it was a time of summaries
and celebrating successes. Within two decades, we have become
a technologically independent, modern, and international organization.
As a person who has been in XTB almost from the beginning, I know how much
effort and commitment these changes required, and how many ideas have
been implemented over these 20 years. There were also challenges and
difficulties, which were a valuable lesson for us.
We are a fintech company, but the most important capital for us is people:
employees, clients, investors. This is reflected in our business goals – we want to
become a global brand and a most frequently chosen investment application
in the world. We increase the potential and scale of business – we are constantly
expanding our product offer to reach clients from other market segments.
2024 was also the year of records. In the first quarter, we exceeded 1 million
clients, and within the entire year, we acquired another nearly 500,000.
At the end of February 2025, nearly 1.5 million investors used our mobile
application and online platform. These figures are a source of pride for us
and proof that, due to the skills and experience of our employees, we can fully exploit
the potential for further intensive growth in the coming years.
6
Management Report of XTB Group and XTB S.A. in 2024
/ Letter of the Chairman of the Management Board
In 2024, we launched a record number of new products. We have enabled clients to
build the habit of regularly investing even small amounts, thanks to
the auto-investment function as part of the Investment Plans. Thus, we refuted
the often raised argument that investing requires having large funds.
We have also strengthened the security of our clients' accounts by launching two-
factor authentication (2FA). Thanks to this, we were able to implement further
product innovations, such as the eWallet service, i.e. a virtual wallet with a multi-
currency card. It appeared in the XTB app in October 2024 and is now available
to clients in Poland, the Czech Republic, Portugal, Romania, Slovakia, Germany,
and France. eWallet provides investors with convenient access to their funds and
payments in the seven most important currencies. Although this service has not been
widely advertised so far, the number of its users is systematically growing – at the
end of February 2025, over 17,000 clients used eWallet.
In October last year, we added to our offer the product that our clients asked about
most often – Individual Pension Accounts (IKE). Thanks to them, Poles can invest
long-term, bearing in mind their future retirement and achieving additional tax
benefits (after meeting certain conditions). As the data at the end of 2024 shows,
XTB clients own 40% of IKE accounts opened throughout the year through
brokerage houses and offices. This is a signal to us that the segment of long-term,
passive investment still has great potential for development. A similar account type,
enabling long-term investing in shares under a tax umbrella, has been launched
for our UK clients. We are talking about an ISA, or Individual Savings Account.
The second pillar of our activity is technology, which is why we are constantly
developing our own xStation platform and XTB mobile application. We are working
on making our technology reliable, friendly, and easy to use, so we have refreshed
and simplified the application interface to give clients access to all investments in
one place. We actively use technologies based on Artificial Intelligence (AI), thanks
to which we have significantly improved the onboarding of new clients, preparing for
the increase in the scale of operations in the coming years.
Acquiring new clients and market success of our products would not be possible
without marketing support. XTB wants to be the most frequently chosen investment
application in the world, and effectively conducted promotional and advertising
activities support the achievement of the goal we have set ourselves.
We successfully build global recognition of our brand, thanks to cooperation with the
most famous athletes. Zlatan Ibrahimovic, a world-class footballer, became an
ambassador of XTB in 2024. Thanks to an international advertising campaign
including him, in the last quarter of 2024 the number of new clients increased by over
45% compared to the previous quarter. It is very important that our stakeholders
understand the need to increase marketing expenses. We strive to take the lead
among the world's market leaders, therefore we must be ready to compete with
global players whose business, like ours, is not limited to one country. In order to
achieve this, we are constantly expanding geographically and acquiring new
licenses, e.g. in Indonesia (thanks to which we can offer stocks and ETF products to
the clients) and in the United Arab Emirates, where in Dubai, outside the enterprise
zone, we opened a new office (the license will allow the Company to improve cost
and operational efficiency, broaden the service offer presented to the clients in the
region, and increase employment).
All the aforementioned activities contributed to the fact that in 2024, we achieved
record financial results: PLN 1,873.4 million in consolidated operating revenues
(+15.8% y/y), PLN 856.9 million in net profit (+8.3% y/y), and PLN 986.7 million
in EBIT (+6.8% y/y). For us, it is a confirmation that our efforts on a daily basis
are a right way to go.
7
Management Report of XTB Group and XTB S.A. in 2024
/ Letter of the Chairman of the Management Board
Taking this opportunity, I would also like to mention a few occurrences
in the corporate area of the XTB Group, where 2024 was also an active time,
e.g. for another year in a row, we paid a dividend, and we also bought treasury
shares for the purposes of the incentive program. Thanks to this, we were able to
additionally appreciate and motivate key employees whose involvement is
necessary to implement the business strategy. We have adopted a new
Sustainability Strategy for 2024-2027, which strengthens XTB's organizational
culture in the area of social responsibility, taking into account environmental and
climate protection and conscious resource management. The work on the strategy
allowed us to look at our activities from a different perspective and to prepare and
implement new procedures, such as Diversity, Equity, and Inclusion (DEI)
Management Policy, or Anti-Mobbing and Anti-Discrimination Policy. I believe they
will contribute to building the friendly and supportive work environment we all create.
We are one of the key financial institutions in our country, which is why
we are actively involved in the financial education of the youth. Through the XTB
Foundation, we are implementing the project "Academy of Tomorrow. Finance with
class", in which over 2.5 thousand students took part in lessons on personal finance
and investment. We also had the honor and pleasure to be the main sponsor of the
Polish national team at the International Economic Olympiad in Greece, from which
the students returned with gold and silver medals, beating all the other teams. We
believe that these activities will contribute to building financial awareness among the
younger generations and prepare them for the challenges of adult life.
The annual report is also a place for expressing gratitude. I thank our shareholders
and clients for the trust they have placed in us. I thank our employees for their daily
commitment and contribution to the success of XTB.
I cordially invite you to read the XTB annual report for 2024. Here you will find
comprehensive information about our achievements, challenges, and plans
for the future.
Omar Arnaout,
Chairman of the Management Board of XTB S.A.
8
Management Report of XTB Group and XTB S.A. in 2024
/ Selected consolidated financial data
Selected consolidated financial data
The selected consolidated financial data presented in this section have been
converted into EUR (euro) in the following manner:
a. items from the consolidated statement of comprehensive income and the
consolidated statement of cash flows – according to the exchange rate
constituting the arithmetic mean of the average exchange rates determined by
the National Bank of Poland on the last day of each month of the reporting
period:
▪ for the current period 01.01.2024 – 31.12.2024: 4.3042;
▪ for the comparative period 01.01.2023 – 31.12.2023: 4.5284.
b. items from the consolidated statement of financial position – according to the
average exchange rate determined by the National Bank of Poland at the end
of the reporting period:
▪ for the current period as of 31.12.2024: 4.2730;
▪ for the comparative period as at 31.12.2023: 4.3480.
9
Management Report of XTB Group and XTB S.A. in 2024
/ Selected consolidated financial data
31.12.2024
31.12.2023
31.12.2024
31.12.2023
Consolidated statement of comprehensive income:
Total operating income
1 873 436
1 618 385
435 258
357 386
Profit on operating activities
986 735
924 154
229 249
204 080
Profit before tax
1 048 451
960 244
243 588
212 049
Net profit
856 856
791 173
199 074
174 714
Net profit and diluted net profit per share attributable to shareholders
of the Parent Company (in PLN/EUR per share)
7.29
6.73
1.69
1.49
Consolidated statement of cash flows:
Net cash from operating activities
828 263
479 253
192 431
105 833
Net cash from investing activities
(22 882)
280 873
(5 316)
62 025
Net cash from financing activities
(602 013)
(568 456)
(139 866)
(125 531)
Increase/(Decrease) in net cash and cash equivalents
203 368
191 670
47 249
42 326
IN THOUSANDS PLN
IN THOUSANDS EUR
31.12.2024
31.12.2023
31.12.2024
31.12.2023
Consolidated statement of financial position:
Total assets
6 645 632
4 688 658
1 555 261
1 078 348
Total liabilities
4 641 991
2 953 995
1 086 354
679 392
Share capital
5 878
5 878
1 376
1 352
Equity capital
2 003 641
1 734 663
468 907
398 957
Number of shares (pcs.)
117 569 251
117 569 251
117 569 251
117 569 251
Book value and diluted book value per share attributable
to shareholders of the Parent Company (in PLN/EUR per share)
17.04
14.75
3.99
3.39
10
Management Report of XTB Group and XTB S.A. in 2024
/ Selected financial data
Selected standalone financial data
The selected standalone financial data presented in this section have been
converted into EUR (euro) in the following manner:
a. items from the standalone statement of comprehensive income and the
standalone statement of cash flows – according to the exchange rate
constituting the arithmetic mean of the average exchange rates determined by
the National Bank of Poland on the last day of each month of the reporting
period:
▪ for the current period 01.01.2024 – 31.12.2024: 4.3042;
▪ for the comparative period 01.01.2023 – 31.12.2023: 4.5284.
b. items from the standalone statement of financial position – according to the
average exchange rate determined by the National Bank of Poland at the end
of the reporting period:
▪ for the current period as of 31.12.2024: 4.2730;
▪ for the comparative period as at 31.12.2023: 4.3480.
IN THOUSANDS PLN
IN THOUSANDS EUR
12 MONTHS PERIOD ENDED
12 MONTHS PERIOD ENDED
31.12.2024
31.12.2023
31.12.2024
31.12.2023
Standalone statement of comprehensive income
Total operating income
1 716 592
1 491 967
398 818
329 469
Profit on operating activities
983 190
919 622
228 426
203 079
Profit before tax
1 045 588
955 816
242 923
211 071
Net profit
855 202
787 136
198 690
173 822
Net profit and diluted net profit per share attributable
to shareholders of the Parent Company (in PLN/EUR per share)
7.27
6.70
1.69
1.48
11
Management Report of XTB Group and XTB S.A. in 2024
/ Selected financial data
IN THOUSANDS PLN
IN THOUSANDS EUR
12 MONTHS PERIOD ENDED
12 MONTHS PERIOD ENDED
31.12.2024
31.12.2023
31.12.2024
31.12.2023
Standalone statement of cash flows
Net cash from operating activities
776 810
433 862
180 477
95 809
Net cash from investing activities
(28 272)
283 004
(6 568)
62 495
Net cash from financing activities
(599 653)
(565 979)
(139 318)
(124 984)
Increase/(Decrease) in net cash and cash equivalents
148 885
150 887
34 591
33 320
IN THOUSANDS PLN
IN THOUSANDS EUR
31.12.2024
31.12.2023
31.12.2024
31.12.2023
Standalone statement of financial position
Total assets
6 411 608
4 498 167
1 500 493
1 034 537
Total liabilities
4 419 060
2 770 237
1 034 182
637 129
Share capital
5 878
5 878
1 376
1 352
Equity capital
1 992 548
1 727 930
466 311
397 408
Number of shares (pcs.)
117 569 251
117 569 251
117 569 251
117 569 251
Book value and diluted book value per share attributable to shareholders
of the Parent Company (in PLN/EUR per share)
16.95
14.70
3.97
3.38
12
Management Report of XTB Group and XTB S.A. in 2024
/ Synthetic summary of data concerning the Company and the Capital Group for 2018-2024
Synthetic summary of data concerning the Company and the Capital Group for
the year 2018-2024
The following table presents selected consolidated and standalone financial and operating data and ratios that provide a picture of the overall financial condition of both XTB S.A. and the XTB S.A.
Capital Group as a whole. A detailed financial analysis from both perspectives is presented in section the Financial Result and dividend of this report.
2024
2023
Change y/y
(‘24/’23)
2022
2021
2020
2019
2018
Selected consolidated financial data
Total operating income
mm PLN
1 873.4
1 618.4
15.8%
1 452.0
625.6
797.8
239.3
288.3
Net profit
mm PLN
856.9
791.2
8.3%
766.1
237.8
402.1
57.7
101.5
Balance sheet total
mm PLN
6 645.6
4 688.7
41.7%
4 114.3
3 147.7
2 283.5
1 138.9
970.1
Own cash + treasury bonds
mm PLN
2 052.6
1 805.7
13.7%
1 584.6
921.3
940.8
499.3
468.0
Equity capital
mm PLN
2 003.6
1 734.7
15.5%
1 506.1
915.6
888.3
490.7
455.2
Earnings per share (EPS)
1
PLN
7.3
6.7
0.6
6.5
2.0
3.4
0.5
0.9
The market value of the Company
2
PLN
70.4
37.8
32.6
31.0
16.8
17.9
4.0
4.4
Total capital ratio (IFR)
3
%
192.3
188.7
3.6 p.p.
218.1
200.1
200.1
165.8
238.5
Selected standalone financial data
Total operating income
mm PLN
1 716.6
1 492.0
15.1%
1 334.4
562.4
748.3
210.6
267.3
Net profit
mm PLN
855.2
787.1
8.6%
761.6
234.8
418.2
54.1
90.9
Balance sheet total
mm PLN
6 411.7
4 498.2
42.5%
3 913.3
2 971.6
2 155.6
1 083.9
928.0
Own cash + treasury bonds
mm PLN
1 854.3
1 677.2
11.2%
1 486.9
882.8
893.4
449.9
413.0
Equity capital
mm PLN
1 992.5
1 727.9
15.3%
1 498.4
912.4
889.0
497.3
463.2
Earnings per share (EPS)
1
PLN
7.3
6.7
0.6
6.5
2.0
3.6
0.5
0.8
Standalone capital ratio (IFR)
3
%
197.8
195.5
2.3 p.p.
228.0
211.5
213.5
182.3
250.4
1
Attributable to shareholders of the Parent Company.
2
At the end of the period.
3
For the comparability of the presentation in the period until June 25, 2021 the IFR capital ratio was calculated as the capital ratio CRR including buffers * 12.5.
13
Management Report of XTB Group and XTB S.A. in 2024
/ Synthetic summary of data concerning the Company and the Capital Group for 2018-2024
2024
2023
Change y/y
(‘24/’23)
2022
2021
2020
2019
2018
Selected Group indicators
1
EBITDA
mm PLN
1 006.6
941.4
6.9%
897.7
285.7
523.5
72.2
119.7
EBITDA margin
%
53.7
58.2
(4.4) p.p.
62.2
45.7
65.6
30.2
41.5
Net profit margin
%
45.7
48.9
(3.1) p.p.
53.0
38.0
50.4
24.1
35.2
Return on equity – ROE
%
45.8
48.8
(3.0) p.p.
63.3
26.4
58.3
12.2
23.7
Return on assets – ROA
%
15.1
18.0
(2.9) p.p.
21.1
8.8
23.5
5.5
10.9
Selected operational data
1
New clients
k
498.4
312.0
186.5
196.9
189.2
112.0
36.6
20.7
Clients in total
k
1 361.6
897.6
464.0
614.9
429.2
255.8
149.3
116.5
Number of active clients
k
658.5
408.5
250.0
270.6
193.2
108.3
49.6
40.7
Net deposits
mm PLN
8 607.3
3 793.7
126.9%
3 423.2
2 933.4
1 961.2
409.4
332.9
Average operating income per active client
k PLN
4.1
5.8
(1.7)
7.8
5.0
13.0
7.9
12.3
Average cost of acquiring a client
k PLN
0.7
0.8
(0.2)
1.1
0.6
0.8
1.0
1.6
Transaction volume in CFD derivatives
mm lots
6 274.2
6 779.8
(7.5)%
6 592.9
4 045.9
3 113.4
1 638.6
2 126.4
Profitability per lot
PLN
299
239
60
220
155
256
146
136
Turnover of shares and ETPs in nominal value
mm USD
9 574.1
4 512.7
112.2%
3 336.3
4 437.3
1 643.3
178.8
49.7
Transaction volume in CFD derivatives in nominal value
mld USD
2 626.6
2 285.9
14.9%
2 259.6
1 737.4
1 021.8
541.5
773.9
Profitability for 1 million USD transaction volume in CFD
derivatives in nominal value
USD
179
169
10
144
93
200
115
103
1
The definitions of the indicators and selected operational data contained in the table above are presented in section Financial results and dividend.
14
Management Report of XTB Group and XTB S.A. in 2024
/ Synthetic summary of data concerning the Company and the Capital Group for 2018-2024
Key performance indicators 2024 (consolidated)
The foregoing Management Board report on the operations of the Group and
Company for 2024 includes disclosure requirements for the report on the activities
of the Company XTB S.A. pursuant to § 71 item 8 of the ordinance of Minister of
Finance dated 29 March, 2018 on current and periodic information published by
issuers of securities and the conditions for recognition as equivalent the
information required by the laws of a non-member state.
Sustainability Statement
The company prepared the XTB Group Sustainability Statement
for 2024, which constitutes a separate part of this Management
Report of XTB Group and XTB S.A. for 2024, in accordance with
the Art. 63r, section 1, of the Accounting Act.
15
Management Report of XTB Group and XTB S.A. in 2024
/ Summary of 2024
Summary of 2024
16
Management Report of XTB Group and XTB S.A. in 2024
/ Summary of 2024
17
Annual Report 2024
/ About us
XTB Group
B
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
18
Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
General information
XTB S.A. is a Polish brokerage house operating in the fintech sector, listed on the
Warsaw Stock Exchange. The company creates the global XTB Capital Group, which
offers investors from the world constant and immediate access to international
financial markets through its proprietary online investment platform and mobile
application.
XTB, becoming a fintech company, has combined traditional brokerage services with the use
of the latest technologies, providing its clients with easier and competitive access to a wide
range of investment instruments. The company has developed and is developing its own
universal xStation online investment platform and mobile application. Both are All-in-
One tools, allowing investors to actively manage their funds for investment purposes.
In addition, the applications offered by the Group provide clients with useful and diverse tools
including graphs, analyses, research, and online training. Financial education remains one of
the crucial elements of XTB's activity.
XTB offers products that fulfil expectations of various groups of investors: shares, ETP
(including ETF), investment plans, CFD, pension products, interest on free funds, and a virtual
eWallet with a multi-currency card. The full description of the products can be found in section
“Products” of this Report.
XTB offers constantly expanding product offer dedicated to the individual clients, and
simultaneously operates in the segment of institutional clients. These services are run under
the X Open Hub (XOH) brand and consist in providing modern transaction technology and
ensuring the liquidity of many assets for financial institutions from around the world. XTB
offers solutions that meet the specific requirements of institutional clients, including the ability
to integrate with client systems and advanced analytical tools to support investment decision
making processes.
Company name:
XTB S.A.
Registered office and
headquarters address:
Prosta Street 67, 00-838 Warsaw
Website address:
www.xtb.com/en
Date of registration in the NCR:
22.09.2004
NCR:
0000217580
Tax ID:
5272443955
REGON NO:
015803782
The Company is subject to the supervision of the Polish Financial
Supervision Authority and performs regulated activities on the
basis of a license dated November 8, 2005, No. DDM-M-4021-57-
1/2005
19
Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
Organizational structure of the XTB S.A. Capital Group
The XTB Capital Group consists of: XTB S.A., which is the parent company, 7 foreign
branches and 13 subsidiaries. The branches and subsidiaries of the XTB S.A. play a key role
in the implementation of the international expansion strategy and support the operational
activities of the Group. They are located in the strategic financial centers of Europe, Latin
America, and the Middle East, enabling direct client service in these regions. The Group's
structure includes, among others, entities responsible for technology development,
operational support, marketing, and compliance.
Due to the rule of a single passport resulting from the MiFID II Directive, the Company
conducts business in the form of branches on the basis of and within a license issued by the
Polish Financial Supervision Authority in the following European Union countries: Czech
Republic, Spain, Slovakia, Romania, Germany, France, and Portugal.
The activities of the Company are subject to regulation and supervision of appropriate organs
of the markets it conducts its business on, including the markets in other EU members states,
on the basis of the ”single passport”. Additionally, the Company holds shares in entities
currently operating on the basis of separate brokering services licenses issued by the
supervisory authorities in jurisdictions abroad.
subsidiares
7
foreign
branches
13
parent
company
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Information on foreign branches of XTB S.A.
XTB S.A. also operates through 7 foreign branches located in Europe, as shown in the scheme below.
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Branch country
Branch name
Branch information
Czech Republic
XTB S.A. organizačni složka
Branch established on 7 March 2007 and entered in the Commercial Register maintained by the City
Court in Prague under no. 56720. Its tax identification number is CZK 27867102. Date of registration of
the new name in the local register: 6 April 2022;
Spain
XTB S.A. Sucursal en Espana
Branch established on 19 December 2007 and registered on 16 January 2008. Its tax identification
number is ES W0601162A. Date of registration of the new name in the local register: 22 July 2022.
Slovak Republic
XTB S.A. organizačná zložka
Branch established on 1 July 2008 and on 6 August 2008 entered in the Trade Register maintained by
the City Court in Bratislava under no. 36859699. Its tax identification number is SK4020230324. Date of
registration of the new name in the local register: 6 April 2022;
Romania
XTB S.A. Varsovia Sucursala Bucuresti
Branch established on 31 July 2008 and on 4 August 2008 entered into the Commercial Register under
no. 402030. Tax identification number: RO27187343. Date of registration of the new name in the local
register: 22 April 2022;
Federal Republic of
Germany
XTB S.A. German Branch
Branch established on 5 September 2008 and on 24 October 2008 entered into the Commercial Register
under no. HRB 84148. Its tax identification number is DE266307947. Date of registration of the new
name in the local register: 19 December 2022;
French Republic
XTB S.A. Succursale Française
Branch established on 21 April 2010 and on 31 May 2010 entered into the Commercial Register under
no. 522758689. Its tax identification number is FR61522758689. Date of registration of the new name
in the local register: 27 May 2022;
Portugal
XTB S.A. Sucursal em Portugal
Branch established on 7 July 2010 and on the same day entered into the Commercial Register under
no. PT980436613. Date of registration of the new name in the local register: 17 May 2022;
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XTB Subsidiaries Information
As at 31 December 2024, the XTB S.A. Company consisted of 13 subsidiaries, which is presented in the diagram below.
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Name of subsidiary
Country
XTB's share in the subsidiary
Additional information
XTB Limited
United Kingdom
100%
The company provides brokerage services based on the obtained permission issued by the
FCA (Financial Conduct Authority), license no FRN 522157.
X Open Hub Sp. z o.o.
Poland
100%
The main corporate object of the company is offering electronic applications and trading
technology.
XTB Limited
Cyprus
100%
The company provides brokerage services based on the obtained permission issued by the
CySEC (Cyprus Securities and Exchange Commission), license no 169/12.
XTB Agente de Valores SpA
Chile
100%
The company provides services to acquire clients from the territory of Chile.
Since February 2025, the company has been entered in the Register of Stock Brokers and
Securities Agents (Esp. Registro de Corredores de Bolsa y Agentes de Valores) led by the
Financial Market Commission (COMISIÓN PARA EL MERCADO FINANCIERO),
as a Securities Agent. Entry number 216.
XTB International Limited
Belize
100%
The company provides brokerage services based on the obtained permission issued by the
International Financial Service Commission.
XTB MENA LIMITED
UAE
100%
The company provides brokerage services on the basis of a license received from the DFSA
(Eng. Dubai Financial Services Authority).
XTB Services Limited
Cyprus
100%
The company acquires and maintains partnerships, as well as negotiates and enters
agreements with the partners. Moreover, it is responsible for supervision of the partner
onboarding process, audits, and managing payment processes for the partners.
XTB S.C. Limited
Republic of
Seychelles
99.9% directly;
0.1% indirectly through XTB Services
Limited (Cyprus)
The company will provide brokerage services. The company received from the FSA (Eng.
Financial Services Authority) license No. SD148 to conduct business in the Republic of
Seychelles.
As of the date of submission of these consolidated financial statements, the company had no
operations.
XTB Financial Consultation
L.L.C.
UAE
100%
The company will provide brokerage services – financial advice. The Company has received
from the Securities and Commodities Authority (SCA) a Fifth Category License in the field of
financial consulting.
As of the date of submission of this report, the company was in the phase of preparation for
the commencement of operations.
PT XTB Indonesia Berjangka
Indonesia
90%
The company will conduct brokerage activities in the area of futures contracts.
On December 17, 2024, Bappebti Indonesia issued a decision to grant PALN Licence to the
company.
Until the date of submission of this report, the company carried out advanced preparatory
work for the launch of operations.
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Name of subsidiary
Country
XTB's share in the subsidiary
Additional information
XTB Africa (PTY) Ltd.
Republic of South
Africa
100%
Since August 2021, the company has had an FSCA license (Eng. Financial Sector Conduct
Authority) to conduct business in South Africa.
As of the date of submission of this report, the Company had no operations.
XTB Digital Ltd.
Cyprus
100%
As of the date of submission of these consolidated financial statements, the company had no
operations. The winding-up of the company has been underway since January 2025.
Tasfiye Halinde XTB Yönetim
Danışmanlığı A.Ş.
Turkey
100%
In 2024, the company had no operations.
The winding-up of the company has been underway since September 2020.
Lirsar S.A en liquidacion
Uruguay
100%
On 29 May 2024, the entity was liquidated and from that date is no longer part of the XTB
Capital Group.
Consolidation information
All subsidiaries financial results are fully consolidated since the date of foundation/acquisition.
In the reporting periods all subsidiaries have been subject to consolidation. Neither the Parent
Company nor any Group company holds shares in other companies that may have a material
impact on its assets and liabilities, financial condition and profit or loss.
During the reporting period, i.e. from 1 January to 31 December 2024, and until the date of
this Report, there were no changes, other than those described above, in the structure of the
XTB S.A. Group.
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Board
Management Board
The parent company XTB S.A. is headed by a Management Board appointed and dismissed on the basis of the Company's Articles of Association. As of December 31, 2024 and as of the date
of publication of this Report, the Management Board was as follows:
In 2024, the composition of the Management Board of the Company remained unchanged.
Omar Arnaout
Filip Kaczmarzyk
Paweł Szejko
Jakub Kubacki
Andrzej Przybylski
Chairman
of the Management Board
Member of the Management Board
responsible for Trading
Member of the Management Board,
Chief Financial Officer
Member of the Management Board
responsible for Legal
Member of the Management Board
responsible for Risk Management
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Division of competences and responsibility between the
individual Members of the Management Board of XTB
Chairman of the Management Board: directing and supervising the work of the
Management Board and its members; strategic and operational management of the Group's
sales activities; building relationships with stakeholders and management of after-sales
processes, human resources management and CSR activities; building responsible
management practices and corporate governance.
Member of the Management Board responsible for Trading: XTB investment services and
products quality management; IT infrastructure management; XTB investment products
development; building responsible management practices and corporate governance.
Chief Financial Officer: management of the financial area and investor relations of XTB;
management of the area of management information and the circulation of confidential
information; management of the area of sustainability strategy; contact with investors of XTB
S.A. and stock market analysts; building responsible management practices and corporate
governance; CSR activities (XTB Foundation).
Member of the Management Board responsible for Legal: compliance and legal
management; activities related to the Internal Audit System (SIC); support of the Supervision
Inspector in supervising the operation of the Compliance System (SLC); building responsible
management practices and corporate governance.
Member of the Management Board responsible for Risk Management: management and
supervision of the risk area; operational and strategic management of the activities of XTB
S.A.; building responsible management practices and corporate governance.
A detailed description of the competences and professional experience of the Members of the
Management Board and information on the principles of functioning of the Management Board
of the Company can be found in the Corporate Governance section, point XTB Statutory
Bodies of this Report.
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Supervisory Board
As at the date of submission of this Report, the composition of the Supervisory Board was as follows:
Prof. Aleksander Chłopecki
Chairman of the Supervisory
Board
Ewa Stefaniak
Member of the Supervisory
Board
Katarzyna Dąbrowska
Member of the Supervisory
Board
Bartosz Zabłocki
Member of the Supervisory
Board
Grzegorz Grabowicz
Member of the Supervisory
Board
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A detailed description of the competences and professional experience of the Members of the Supervisory Board and information on the principles of functioning of the Supervisory Board of the
Company can be found in the Corporate Governance section, point Supervisory Board of this Report.
Audit Committee
Grzegorz Grabowicz
Ewa Stefaniak
Bartosz Zabłocki
Remuneration Committee
Aleksander Chłopecki
Ewa Stefaniak
Katarzyna Dąbrowska
Bartosz Zabłocki
Grzegorz Grabowicz
Risk Management Commitee
Aleksander Chłopecki
Ewa Stefaniak
Katarzyna Dąbrowska
Bartosz Zabłocki
Grzegorz Grabowicz
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Management Report of XTB Group and XTB S.A. in 2024
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History of development
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Mission, vision, and values
In our daily work, we are guided by the following values:
XTB's mission is to provide clients around the world with
access to an advanced investment platform, professional
service and comprehensive financial education. The Group
strives for sustainable development and excellence in
service delivery, building trust and long-term relationships
with clients to help them succeed in the financial markets.
XTB's vision is to be a leading provider of investment
products, renowned for innovation, transparency and
excellent client service. The Group wants to be perceived
as a trusted partner, enabling it to achieve its clients'
financial goals by providing the All-in-One platform,
knowledge and support needed to invest effectively, while
respecting sustainable development.
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Management Report of XTB Group and XTB S.A. in 2024
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Brand
The XTB brand appeared in the landscape of the Polish capital market in 2009,
as its predecessor X-Trade Brokers rebranded and changed name to XTB Online Trading.
In 2023, the word “trading” was replaced with “investing”, and the full trademark became
“XTB online investing”. The change was connected to the strategic development objective
of the Group and striving towards creation of an universal application dedicated to investment.
Since the beginning of the Company's operations in 2004, the founders of XTB have strived
to build a global organization.
The process of building the XTB image is carried out in a highly thought-out and flexible
manner. In the period of over 20 years of activity, the vision and goals related to the image
were revised, and the brand itself underwent a rebranding twice. These activities have always
been correlated with strategic goals and dedicated to them. Currently, the main values with
which the XTB brand wants to be associated are globalism, modern technology, accessibility,
knowledge, and trust.
The Group strives to acquire a wide group of clients who are interested in the world of
investment, have experience in this area by multiplying their assets or will take their first steps
in this world. In this respect, the Company uses a tailor-made marketing strategy, as part of
which it prepares advertising campaigns in traditional media, such as television or out-of-home
media, e.g. billboards, as well as in online media (information, economic, and social media
portals). An element supporting the building of XTB brand recognition was the invitation to
collaborate with world-class athletes as brand ambassadors, as well as a famous European
actor. Strong personalities were chosen for this role - mainly ones associated with sports,
which requires endurance, discipline, and perseverance.
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In order to increase its share in the global fintech market, XTB undertakes extensive
marketing activities covering many online and offline channels. In 2024, the XTB Group
allocated PLN 342 million for marketing activities, including targeted advertising campaigns
at home and abroad. Compared to the previous year, this represents an increase of 29.6%
y/y. In the opinion of the Management Board of the Company, in 2025 and in subsequent
years, expenditure on marketing activities will increase by up to about 80% per year. The
justification for the increase in these costs is the need to compete for the position of one of
the leaders on the international investment services market. The goal of the Management
Board of the Company is to acquire mass client. It should be borne in mind that in this
perspective, the Company does not refer only to competition in local markets, but to
organizations with a global reach. Moreover, due to the broadening of the product offer and
reaching new client groups, the competition increased as well, when beforehand the
perceived competition included primarily of entities offering CFDs. Along with the
development of the product portfolio, the XTB Group is increasing its share in the overall
market of financial instruments. For example, according to the report "The ETF Savings Plan
Market in Continental Europe 2024" (extraETF.com), from January to the end of August 2024,
individual investors purchased ETFs worth approx. 2 trillion euros, which is an increase of
40% compared to the end of 2023. At the same time, in November last year, brokers
understood as brokerage offices, banks, and investment platforms, administered almost 11
million savings plans of their clients based on ETFs. The annual value of ETF savings plans
increased from EUR 15.0 milliard to EUR 17.6 milliard in 2024. These numbers show the
scale of the market – and these results relate to only one type of products, i.e. ETFs.
Indicating the amount of expenditure on marketing activities raises a legitimate question about
the CAC (client acquisition cost) indicator, i.e. the cost of acquiring a client. In 2024, in the
XTB Group, this indicator was 0.7 compared to 0.8 in the previous year. It should be noted
Conor
McGregor
XTB Ambassador 2022-2024
Irish MMA fighter, two-time UFC champion
Iker Casillas
XTB Ambassador 2022-2024
Spanish former football player, received the title of FIFA Golden
Glove for the best goalkeeper in the world 3 times, won the title of
FIFA World Champion 2010 with the Spanish national team, UEFA
Champions League Winner 2000 and 2002 with Real Madrid
Zlatan
Ibrahimovic
XTB Ambassador 2024-2025
Swedish former football player, one of the best strikers of modern
football, 12-time winner of the Footballer of the Year title in
Sweden
Madds
Mikkelsen
XTB Ambassador 2016-2018
Winner of several Best Actor awards in the competitions of the European
Film Festival and the Cannes Film Festival
Jose Murinho
XTB Ambassador 2019-2020
Portuguese former football player, coach of the world's best football clubs
Chelsea, Inter Milan, Real Madrid, Manchester United, as well as AS
Roma.
Jiři Procházka
XTB Ambassador 2022
Czech MMA fighter, UFC Light Heavyweight Champion
Joanna
Jędrzejczyk
XTB Ambassador 2022-2023
One of the most decorated female fighters in mixed martial arts (MMA),
multiple UFC Ultimate Fighting Championship
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Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
here that over the past quarters, this indicator has been stable, which means that the
implemented activities are effective.
In order to verify the effectiveness of the advertising campaigns and achieve the adopted
goals, the Company commissioned brand recognition tests and tests of the offered product in
the form of a mobile application. On the Polish market, the latest expertise performance was
at the end of the fourth quarter of 2024, after conducting the first marketing campaign with the
participation of the new ambassador Zlatan Ibrahimovic. The study was conducted on
a sample of 1 010 respondents aged 18-54 living in households with an average net income
of at least 3 thousand PLN per month. The results clearly indicated that the awareness of the
XTB brand and associating it with the investment application among the respondents is
significantly higher than in the case of other brokerage offices of leading banks and
competitive platforms of a similar nature of services. The XTB brand is more often recognized
by respondents in the higher income range, in the age groups of 25-34 years and 35-44 years,
and living in cities over 500 thousand people.
The respondents most often associated XTB ads with investing and saving money, Zlatan
Ibrahimović and sport in general, the image of the XTB brand as a reliable and professional,
an interesting and humorous advertising format, as well as a warning about the risk of losing
money.
Looking at the recognition of the XTB brand and its attractiveness on the Polish market, it is
worth recalling the data collected monthly by Krajowy Depozyt Papierów Wartościowych
(KDPW) on the number of brokerage accounts opened. In this list, for the third time in a row,
the Company is indicated as the leader, generating the highest annual increase in accounts
recorded in the KDPW statement. In addition, bearing in mind that at the end of 2024 there
were 1,969,689 brokerage accounts in Poland, 19.3% of their owners were XTB clients.
More information on the channels of reaching clients and marketing is presented in the
section: Business model.
Building a strong brand is also supported by the activities of the XTB Foundation, whose main
goal is financial education from scratch and spreading knowledge about investing. Thanks to
this activity, not only does the level of awareness in the field of personal finance increase
among the youth, but also the association of XTB as a reliable and trusted partner in the field
of investment is supported. More details on the Foundation's activities are described in the
Strategy and Activities section, ESG Strategy and Management part of this Report.
When it comes to contact with XTB ads, the respondents most
frequently remembered spots from YouTube and television. The
spot was positively rated by over 61% of respondents.
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Products
XTB, being a fintech company, has created and provides its clients with its own universal
xStation trading platform and mobile application. The implementation of this modern
technology ensures the independence of the XTB Group and allows for the constant
expansion of the product portfolio. The Management Board's ambition is for XTB to be
associated with the leading All-in-One investment application in Europe, offering clients easy,
intelligent and efficient ways to trade, invest and save, while providing immediate access to
their money.
In recent years, the transformation of XTB from a CFD broker to a modern FinTech entity
providing a universal investment application has been progressing. This transformation will
continue in 2025 and beyond. As part of the trading platform, the Company provides
investment instruments that can be divided into 3 categories: products dedicated to active
investment, products allowing for passive investment – including building savings, and
financial management products.
The types of investment products currently available in the XTB Group's offer are briefly
presented below. Full information about individual products is available on the website:
www.xtb.com
Stocks
XTB clients can purchase traditional shares of companies listed on the largest stock
exchanges in the world for their investment portfolio. By purchasing shares of a particular
company, the investor becomes its co-owner and has the right to apply for a share in the
0%
20%
40%
60%
80%
100%
2024 2023 2022 2021 2020 2019 2018 2017
New clients (EU) - first transaction (%)
Shares ETP Investment plans Options CFDs
0
3 000 000
6 000 000
9 000 000
12 000 000
15 000 000
18 000 000
21 000 000
24 000 000
27 000 000
2024 2023 2022 2021 2020 2019 2018 2017
Number of transactions on shares, ETPs
and investment plans (EU clients)
Shares ETP Investment plans
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Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
assets and profits (dividend) of that company. Currently, XTB offers more than 3,600 shares
of companies listed on the 16 largest securities exchanges in the world.
A stock is the most popular financial instrument purchased for investment purposes.
ETPs (Exchange-Traded Products)
This is a broad category, encompassing various investment products that are listed on stock
exchanges, just like stocks. The most famous are ETF (Exchange-Traded Fund) funds listed
on the stock exchange that enable exposure to a number of assets and instruments, such as
stocks, equity indices or bonds, and with the help of Exchange Traded Products (ETP) also
raw materials, precious metals or even cryptocurrencies. Due to the fact that ETFs are traded
on securities exchanges, they can be freely bought and sold during an exchange session,
which means they are characterized by increased liquidity. In addition, some ETFs
periodically share dividends from their shares with their investors. Some ETFs are managed
passively: the primary objective of managers is to map the return on the underlying asset of
the fund as closely as possible (e.g. an equity index or a basket of shares). There are also
actively managed ETF funds that aim to outperform the market.
ETFs can be a whole or complementary investment portfolio for both beginners and
experienced investors.
XTB currently offers more than 1,350 ETFs.
Another example of a product from the ETP category are ETC Exchange Traded
Commodities), based on raw materials such as gold. ETC funds are also listed on stock
exchanges, reflecting the prices of specific raw materials or their groups.
CFDs (Contracts For Difference)
A CFD is a contract between two parties usually referred to as a “buyer” and a “seller”, relating
to the price movement of an asset. CFDs are a type of over-the-counter derivatives. OTC
because transactions are made directly between the parties, and derivatives because their
price depends on the price of the underlying asset. The underlying asset can be: currency
pairs (FOREX), stocks, the most important stock indices, raw materials and commodities,
increasingly popular cryptocurrencies and many more. It is worth emphasizing - when buying
a contract for growth, e.g. EUR/USD or gold, the investor does not actually purchase the
currency or precious metal and does not become their owner. The same is true for stock
CFDs. The investor owns only a specific CFD and, when trading it, only speculates on the
price movement of a given instrument, which can both rise and fall.
CFD trading allows an investor to take a long position (buy) if one thinks the price of a financial
instruments will rise, or a short position (sell) if one predicts the price will fall. Please note that
CFDs are executed on a leveraged basis.
XTB's offers over 2,400 of CFD derivatives, including: over 70 based on currency pairs, over
30 based on index, nearly 30 based on commodity, and 45 based on cryptocurrency, circa
2,100 based on listed shares of 16 different countries, and nearly 210 based on American
and European ETFs.
Investment Plans
XTB Investment Plans is an intelligent solution dedicated to passive investing, which is
becoming more and more popular. It allows to build a low-cost investment portfolio based on
ETF funds. Thanks to the possibility of obtaining a wide market exposure, the investor is able
to achieve a market rate of return with a relatively small commitment of time and energy.
Investment Plans allow to create one's own portfolio of ETFs starting at PLN 50. One client
may launch up to 10 Investment Plans at the same time. The client determines the duration
of the investment independently. Currently, XTB offers nearly 1,326 different ETFs available
as part of the Investment Plans which allow the clients to gain exposure to entire markets,
industries, or geographical areas.
Interest on free funds
XTB pays interest to clients on uninvested funds in their accounts. The interest rate
constituting the basis for determining the amount of interest is calculated on a daily basis, and
the interest itself is paid cyclically, during the first five workdays of the following month. The
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Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
interest rate on the investor's free funds is activated automatically for all clients with
uninvested funds in the account. A minimum or maximum amount of free funds is also not
required. The interest rates on free funds are variable and may be updated once a week. This
means that in the event that the interest rate is reduced within 90 days of the conclusion of
the contract, the lower interest rate will be applied, while in the event of its increase, the rate
will be increased accordingly.
Pension and savings products
Responding to the growing interest of clients, XTB offers products in the category of solutions
dedicated to long-term saving, including for retirement purposes. Currently, these products
are available in two countries: Poland – Individual Pension Account (IKE) and in the United
Kingdom – Individual Savings Account (ISA).
IKE was created to encourage and build the habit of saving for future retirement with tax
exemption. Thanks to the preservation of the nature of the bank account, the investor has
permanent access to the funds accumulated on it and can withdraw them at any time.
However, if the payment is made before the acquisition of pension rights, i.e. before the age
of 55 or 60, the payment will involve the payment of a 19% tax on the profits made.
An IKE account in XTB can be opened by any natural person who is over 18 years of age,
has an investment account in the Company and has a tax residence in Poland. A person can
only have one IKE account and cannot share it with someone else. The Individual Pension
Account in XTB can only be opened and credited in PLN (Polish zloty). Instruments on the
IKE account can also be purchased in other currencies, but there will be a currency
conversion fee (in accordance with the current price list). On the IKE account, the client has
the opportunity to invest in over 5,000 shares and ETPs. In addition, all available funds bear
interest (in accordance with the currently applicable interest rates).
The ISA is intended for individuals aged 18-39 who have an individual social security number
and resident tax payer status. The company offers British clients a variant of the Flexible Cash
and Stocks & Shares ISAs, which allows the account holder to withdraw and re-pay funds
in one fiscal year without affecting the annual contribution limit.
eWallet
It is a digital wallet with a multi-currency card that supports cashless payments in stores,
mobile transactions and contactless cash withdrawals from ATMs around the world. The
eWallet service allows clients to maintain accounts in seven currencies: EUR, USD, GBP,
PLN, HUF, RON and CZK, as well as fast and free transfers of funds between accounts. The
eWallet service provides clients with immediate access to their funds and payments with
a card issued under the Mastercard license by DiPocket UAB, an Electronic Money Institution
registered by the Bank of Lithuania.
The eWallet service is currently available to clients from Poland, the Czech Republic,
Portugal, Romania, Slovakia, Germany, France, Spain, and Italy.
The strategy of introducing new products to the Company's offer is based on a prudential
approach and consists in the responsible selection of the geographical market on which the
new service will be made available. Thanks to this, technology and trading teams have the
opportunity to carefully look at the operation of products and react quickly, implementing
developed procedures to deal with unforeseen situations.
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Employees and employment
As at 31 December 2024, the total number of employees (persons employed under an
employment contract) and persons providing services under other civil law contracts, e.g.
under B2B contracts, of the XTB S.A. Capital Group equaled 1.245 people and was higher by
18.1% y/y.
The employment structure of the Company itself is dominated by employees employed in
technology departments, whose share at the end of 2024 accounted for 57% of the total
number of employees and persons providing services.
The table below presents information on the number of employees and persons providing
services under other civil law contracts, e.g. under B2B contracts of the Parent Company, its
foreign branches and Subsidiaries on the dates indicated therein. The list does not include
employees on maternity leave, parental leave, and benefits (absences over 33 days).
AS AT
31.12.2024
31.12.2023
Change %
XTB S.A.
875
749
16.8
Foreign branches
153
136
12.5
Companies of the Group
217
169
28.4
Total
1 245
1 054
18.1
+18.1%
increase in employment y/y
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Management Report of XTB Group and XTB S.A. in 2024
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Historically, employment in the XTB Group at the end of individual quarters is presented in the chart below:
The number of employees consists of employees employed under a contract of employment and persons providing services under other civil law contracts, e.g. under B2B contracts. The chart does not include employees on maternity leave, parental leave and benefits
(absences over 33 days).
More information on the employment structure in the XTB Group can be found in the Sustainability Statement of the XTB S.A. Capital Group (Section 3.1).
393
403
405
420
447
453
475
470
477
493
515
535
582
595
626
658
716
751
798
860
956
986
1 010
1 054
1 105
1 154
1 175
1 245
1Q
2018
2Q
2018
3Q
2018
4Q
2018
1Q
2019
2Q
2019
3Q
2019
4Q
2019
1Q
2020
2Q
2020
3Q
2020
4Q
2020
1Q
2021
2Q
2021
3Q
2021
4Q
2021
1Q
2022
2Q
2022
3Q
2022
4Q
2022
1Q
2023
2Q
2023
3Q
2023
4Q
2023
1Q
2024
2Q
2024
3Q
2024
4Q
2024
39
Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
XTB on the stock market
Since the beginning of 2024, the XTB share price has been in the upward trend. In the first quarter of 2024, the value of
the shares increased by 54.7% from the minimum level of PLN 36.62 on the first days of January to PLN 57.10 at the
end of March. In the second quarter, the Company's shares continued to raise, reaching PLN 71.64 (+25.5%) at the end
of June. Then, in the third quarter of the year, there was a high volatility of the exchange rate, which resulted
in a reduction from PLN 71.20 to PLN 61.36 per share. The trading volume was also record-breaking, amounting
to 28,887,428 shares. The last quarter of 2024 brought a slight calming of moods, which could be observed on the
gradually increasing share price of the Company, which at the end of December reached PLN 70.40 per share.
In the full 12 months of 2024, the lowest XTB share price was PLN 36.62, and the highest PLN 75.08. The number of
shares that changed hands during this period was 88,814,014. The capitalization of XTB at the end of 2024 was PLN
8,276.9 million (EUR 1,937.0 million).
XTB S.A. debuted on the Warsaw Stock Exchange
on May 6, 2016. All shares of the Company are
listed on the main market. On September 3, 2020,
XTB joined the mWIG40 index. It is a price index
to which 40 companies with the highest (after
WIG20) classification position calculated on the
basis of data after stock exchange sessions on
the third Friday of the month (February, May,
August, November) are qualified. For the
calculation of the position, the turnover for the
last 12 months and the free float value determined
on the basis of a randomly selected closing price
from the last five trading days, counting back
from the date of classification, are taken into
account. More information at gpw.pl.
30 PLN
40 PLN
50 PLN
60 PLN
70 PLN
80 PLN
Quotation of shares of XTB S.A. in 2024
40
Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
Historical quotations of XTB's shares against the background of the quotations of the mWIG40 equity index in the period from the date of the stock exchange debut to the balance sheet date are
presented in the chart below:
Investor relations
The entry of XTB on the regulated market of the Warsaw Stock Exchange contributed to the
separation of a new group of stakeholders with whom the Company began active
communication. XTB's activities are of great interest to individual and institutional stock
exchange investors, both from Poland and abroad.
The area of communication with analysts and stock exchange investors is the responsibility
of the Chief Financial Officer. They cooperate with a team for investor relations, which
consists of senior and middle-level specialists with diverse experience and knowledge in the
field of finance, information obligations and public relations. XTB S.A. remains in regular and
open contact with capital market participants. The principles that the Company follows in the
2 500 pkt
3 000 pkt
3 500 pkt
4 000 pkt
4 500 pkt
5 000 pkt
5 500 pkt
6 000 pkt
6 500 pkt
7 000 pkt
7 500 pkt
8 000 pkt
May 2016
July 2016
September 2016
December 2016
February 2017
May 2017
July 2017
September 2017
December 2017
February 2018
May 2018
July 2018
September 2018
December 2018
February 2019
May 2019
July 2019
September 2019
December 2019
February 2020
May 2020
July 2020
September 2020
December 2020
February 2021
May 2021
July 2021
September 2021
December 2021
February 2022
May 2022
July 2022
September 2022
December 2022
February 2023
May 2023
July 2023
September 2023
December 2023
February 2024
May 2024
July 2024
September 2024
December 2024
2 PLN
12 PLN
22 PLN
32 PLN
42 PLN
52 PLN
62 PLN
72 PLN
XTB share price against the background of mWIG40
XTB mWIG40
41
Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
communication process are reliability, equal access to information, comprehensibility and
transparency. The Company complies with the principle from the collection of "Best Practices
of WSE Listed Companies 2021", which refers to providing information about the Company
without delay, no later than within 14 days. The XTB Investor Relations Team usually
responds within one business day, provided that the preparation of the response to the
investor's question does not require the preparation and aggregation of additional data.
In addition to e-mail communication, the Company actively participates in market events in
Poland and abroad dedicated to institutional and individual investors, as well as organizes
such meetings itself. In 2024, the Company participated in 13 conferences with investors,
including presentations of periodic financial results (recordings of which are made available
on the investor relations website), which are presented in the table.
Date
Event
Additional information
January 2024
Outcome conference – preliminary data for 2023
Online meeting organized by the Company, recording of the meeting is available on the XTB website.
February 2024
London – meetings with investors as part of the
Non-Deal Roadshow
A stationary event for foreign investors.
February 2024
TOP PICKS 2024 BY TRIGON
An annual event organized by Trigon Brokerage House, which is held to present selected investment
companies and their strategies for institutional and individual investors.
April 2024
BM PEKAO 3rd Financial Conference
The aim of the conference was to enable investors and representatives of companies to exchange views and
discuss important topics related to the financial market.
April 2024
Outcome conference – preliminary data for the
first quarter of 2024
Online meeting organized by the Company, recording of the meeting is available on the XTB website.
MAY 2024
MBank Conference
Meeting with investors
June 2024
Future in CEE – ERSTE Consumer & Technology
Conference 2024
The three-day conference is divided into thematic blocks: Consumer Day, Technology Day and Online Day.
During the event, one-on-one meetings and networking sessions were held, enabling direct interaction
between company representatives and investors. The most interesting companies on the market with a
technological and consumer profile were invited to participate. The aim was to enable the exchange of
experiences and insights on trends and challenges in these industries
August 2024
Outcome conference – preliminary data for the
first half year of 2024
Online meeting organized by the Company, recording of the meeting is available on the XTB website.
September 2024
21st Emerging Europe Investment Conference
An annual event organized by Pekao Brokerage Office. During the conference, representatives of various
companies met with investors, presenting their strategies and financial results.
October 2024
The Finest CEElection Equity Investor
Conference 2024
An international investment event organized by Erste Group in Vienna. The conference brought together
about 60 of the largest companies from the Central and Eastern Europe region, offering investors the
opportunity to meet directly and exchange information on current market trends and challenges.
42
Management Report of XTB Group and XTB S.A. in 2024
/XTB Group
Date
Event
Additional information
October 2024
Trigon Investor Week 2024 conference
An annual event organized by Trigon Brokerage House, which was held at the Warsaw Stock Exchange.
The conference program included group meetings, moderated by Trigon DM analysts, and individual
meetings, allowing investors to contact the company directly.
October 2024
Outcome conference – preliminary data for the
third quarter of 2024
Online meeting organized by the Company, recording of the meeting is available on the XTB website.
November 2024
WSE Innovation Day
A cyclical conference organized by the WSE and its partners, during which the most interesting and
innovative companies listed on the stock exchange are presented. The November edition was held under
the slogan "All Stars Summit" – emphasizing the uniqueness of the invited companies with above-average
development potential.
XTB is a participant in the mWIG40 index, which also contributed to attracting the attention of
many capital market analysts in Poland. Recommendations and analyzes regarding XTB are
issued by: Brokerage Office of Bank Pekao S.A., Brokerage Office of mBank, Noble Securities
Brokerage House, Trigon Brokerage House. In 2024, analysts prepared and published
10 analyzes and recommendations, of which 7 were the "buy" recommendation, and the
remaining 3 the "keep" recommendation. The price range for the Company's shares indicated
in these analyzes ranged from PLN 47.95 (February 2024) to PLN 88.60 (November 2024).
Full information about the historical and current recommendations can be found on the XTB
investor relations website.
Currently, as part of further improvement of communication with investors, XTB is preparing
a new version of the investor relations website. The changes will concern not only the
appearance, but also the introduction of new functionalities. The implementation of the new
service is planned for 2025.
43
Annual Report 2024
/ About us
Business model
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
44
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
Business model
The Group performs its services, diversifying revenue generation, to two classes of clients:
individual and institutional. The percentage of institutional business income in the operational
revenues equaled 4.4% in the current year and 6.7% in the previous year.
XTB Group's revenues include:
▪ spreads (the difference between the sale price – offer and the purchase price – bid);
▪ accrued swap points (representing the cost of holding a position over time) and;
▪ net result (profits less losses) from the Group's market making activities.
Moreover, within its operational activity, XTB Group generates revenue on clients’ funds
interest rate.
CATEGORY
2024
2023
2022
2021
2020
2019
2018
Spreads
53%
46%
54%
83%
54%
62%
64%
Swaps, commission and fees
42%
41%
26%
40%
16%
15%
12%
Market making
5%
13%
20%
(23%)
30%
23%
24%
Gross gain on transactions
in financial instruments
100%
100%
100%
100%
100%
100%
100%
INSTITUTIONAL (legal entities)
▪ ensuring the liquidity of trading in financial instruments;
▪ provision of transaction infrastructure to other entities, legal
entities that provide trading services in financial instruments
to their own clients and under their own brand;
▪ the services are provided by X Open Hub
INDIVIDUAL (natural and legal persons)
▪ trading services in financial
instruments;
▪ access to a wide range of
investment products.
CLIENTS
The business model of the XTB Group focuses on the human being
as a recipient of services and closely corresponds to the
directions and objectives of the sustainability strategy. It is based
on building solutions enabling the implementation of clients'
investment goals through immediate access to financial markets
from around the world. This is done with the help of the XTB
proprietary investment platform and mobile application, which are
key technology products helping to reach mass clients.
45
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
The XTB business model includes high volatility of revenues from period to period.
The operating and financial results are primarily influenced by:
▪ number of active clients;
▪ the volume of their transactions in financial instruments;
▪ deposit sums;
▪ volatility in financial and commodity markets;
▪ general market, geopolitical and economic conditions;
▪ competition in the FX/CFD market and
▪ the regulatory environment.
The business model used by the Group combines the features of the agency model and the
market making principal model in which the Group is a party to a transaction concluded and
initiated by the client. The Group does not engage in proprietary trading awaiting changes
in prices or values of the underlying instruments. The hybrid business model used by XTB
also uses the agency model. For example, on most CFD instruments based on
cryptocurrencies, XTB secures these transactions with external partners, practically is no to
be the other party to the transaction (of course, from a legal point of view, it is still XTB). The
fully automated risk management process adopted by the Company limits exposure to
market changes and forces the Group to hedge its positions in order to maintain appropriate
levels of capital requirements. Additionally, XTB realize directly on regulated markets or in
alternative trading systems, all transactions on shares and ETFs as well as on CFD
instruments based on these assets. XTB is not a market maker for this class of instruments.
As a rule, the Group's revenues are positively affected by higher activity of financial markets
due to the fact that in such periods, a higher level of turnover is realized by the Group's
clients and higher profitability per lot. The periods of clear and long market trends are
favorable for the Company and it is at such times that it achieves the highest revenues.
Therefore, high activity of financial markets and commodities generally leads to an
increased volume of trading on the Group's trading platforms. On the other hand, the
decrease in this activity and the related decrease in the transaction activity of the Group's
clients leads predominantly to a decrease in the Group's operating income.
Due to the above, operating income and the Group's profitability may decrease in periods
of low activity of financial and commodity markets. In addition, there may be a more
predictable trend in which the market moves within a limited price range. This leads to
market trends that can be predicted with a higher probability than in the case of larger
directional movements on the markets, which creates favorable conditions for transactions
concluded in a narrow range trading. In this case, a greater number of transactions that
bring profits to clients is observed, which leads to a decrease in the Group's result
The volatility and activity of markets results from a number of external factors, some of which
are characteristic for the market, and some may be related to general macroeconomic
conditions, which can significantly affect the revenues generated by the Group in the
subsequent quarters. This is characteristic of the Group's business model.
46
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
Operating markets
XTB is a broker that operates in international markets, which is why the revenues generated
by the Group are also geographically diverse. The xStation trading platform and the XTB
mobile application are available to clients from Central and Eastern Europe,
Western Europe, the Middle East, and Latin America.
One of XTB's strategic goals is international expansion and reaching mass
clients from around the world. It is a continuous process, but its effects are
spread over time. As part of the expansion, the Group allows organic
development by creating new subsidiaries from scratch, as well as through
mergers and acquisitions, especially with entities that would allow the Group
to achieve geographical synergy (complementary markets). The Management
Board intends to carry out such transactions only if they are associated with
tangible benefits for the Company and its shareholders.
In 2024, XTB expanded its license in the United Arab Emirates, which will
enable it to strengthen its market position in this rapidly growing region of the
Middle East.
As announced by the Management Board of the Capital Group, in 2025,
starting business is planned, among others, on the Indonesian market and in
Brazil. The implementation of these plans was confirmed, among others, by
the fact that in December 2024 the subsidiary XTB from Indonesia obtained
a PALN license from the local regulator, thanks to which Indonesians gained
access to investments in shares and ETFs offered by XTB.
Main operating markets of the XTB Capital Group in the world
47
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
Brazil remains a promising development market for the XTB Group. In 2024, its nominal
Gross Domestic Product (GDP) amounted to USD 2.331 trillion, making the country's
economy the 10th largest in the world. Forecasts indicate that by 2029 the value of Brazil's
GDP will increase up to USD 3.058 trillion (according to the International Monetary Fund,
World Economic Outlook Database). In addition, as indicated by the market data from the
last year, the Brazilian market, starting from 2021, dominated the other Latin American
geographic markets in terms of the development of fintech companies. Another important
criterion for the attractiveness of this country is the number of inhabitants amounting to over
203 million people, which may be reflected in the potential number of new clients.
In the reporting year, there were no significant changes in the business model of the XTB
Group.
Clients
XTB has a solid foundation in the form of a constantly growing base and the number of
active clients. Along with the strong development of the Company and the Group and its
international expansion, it was necessary to revise the structure of clients and their
expectations regarding the XTB product portfolio. In order to implement the strategy to
create a global brand which is the first choice of people interested in investment instruments,
the Management Board decided to enter new client segments. Hence, there was a need to
develop and implement new products, and the Company began the process of transforming
from a broker specializing in CFDs into a fintech entity, providing a high-tech and
comprehensive tool in the form of an online trading platform. Thanks to these activities and
the constant expansion of the product offer, XTB has become a broker attracting the largest
number of clients in Poland, and has also attracted strong attention in Europe, the Middle
East and Latin America.
Numbers
The number of XTB clients exceeded its first million in the first quarter of 2024, and since
then until the end of last year XTB have acquired another 368,691 clients, finally reaching a
record number of 498,438 new clients at the end of 2024 (+59.8% y/y). Similarly to the
number of new clients, the number of active clients was also record-breaking and increased
from 408,528 to 658,520, i.e. by 61.2% y/y.
NEW CLIENTS
498 438
31.12.2024
311 971
31.12.2023
ACTIVE CLIENTS
658 520
31.12.2024
408 528
31.12.2023
48
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
The priority of the Management Board is to further increase the client base leading to
strengthening the market position of XTB in the world by reaching mass client with the
product offer. These activities are and will be supported – in addition to the constant
expansion of the product portfolio – by targeted promotional campaigns or financial
education dedicated to the Company's clients and people interested in the world of
investment.
The expansion of the product portfolio has a significant impact on the growth of the client
base, which attracts clients with a different profile of interests in relation to financial
instruments. For example, data published by the Polish Financial Supervision Authority
show that in 2024, 169,547 new Individual Pension Accounts were opened. Of this number,
over 42% (72,264) are accounts maintained by entities conducting brokerage activities. Of
the 72,000 newly opened IKE accounts in 2024, 29,000 belong to XTB clients,
representing more than 40% of this number and more than 17% of the total number
of open accounts.
Further, according to the data of Krajowy Depozyt Papierów Wartościowych (KDPW) at the
end of 2024, XTB Group was the second entity with the highest number of open brokerage
accounts, amounting to over 380,000. The number of all accounts of this type at the end of
December 2024 reached 1,969,589.
The ambition of the XTB Management Board in 2025 is to acquire at least 150,000 - 210,000
new clients on a quarterly basis. As a result of the activities carried out in the first two months
of 2025 XTB Group acquired a total of 137,752 new clients (January: 75,674, February:
62,078).
Client assets
At the end of 2024, the value of XTB clients' financial means was over PLN 3.7 billion and
was higher by 65.5% y/y. The nominal value of instruments deposited by clients in XTB
accounts increased by 122.6% y/y and amounted to PLN 13.7 billion, while the nominal
value of derivatives increased by PLN 1.1 billion.
At the end of 2024, the value of clients' assets by category is shown in the table below:
(in million PLN)
31.12.2024
31.12.2023
Clients funds
3 751
2 267
Nominal value of instruments deposited by clients in
brokerage house accounts
13 682
6 148
Nominal value of client derivative transactions
10 027
8 911
TOTAL
27 460
17 326
3 445
6 148
13 682
31.12.2022 31.12.2023 31.12.2024
Value of shares, ETP products, allotment certificates registered on
clients' securities accounts
(mln PLN)
12 738
17 326
27 460
2022 2023 2024
Client assets of XTB clients
(PLN mln)
49
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
Statistics
The presented analysis of the activity of a statistical retail investor was prepared on the
basis of all open, closed and held positions in 2024.
Age: The largest age range is represented by clients aged 25-44. The youngest
investor was 18 years old and the oldest one was 95 years old.
Looking at the chart, it can be concluded that clients from younger age groups
stay with XTB for longer, moving on to the next age categories. At the same time, clients
from older groups lose interest in investing (which may be related to the cessation of
professional activity) or naturally cease to be clients of the Company.
Geographical breakdown: Considering XTB clients in terms of the declared
country of residence, most investors come from European countries (87.3%),
Asia, and Latin America.
82,9%
8,4%
7,3%
1,4%
Geographical breakdown of the Company's clients
in 2023
Europe
Asia
Latin America
Other
17,4%
35,7%
27,5%
13,7%
4,3%
1,2%
0,2%
17,1%
36,3%
27,4%
13,7%
4,1%
1,1%
0,2%
18-24
25-34
35-44
45-54
55-64
65-74
>= 75
The age structure of clients in 2023 and 2024
2024 2023
87,3%
6,4%
5,2%
1,2%
Geographical breakdown of the Company's clients in
2024
Europe
Asia
Latin America
Other
50
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
Which financial instruments are most popular in clients' portfolios?
Looking at the most frequently chosen classes of instruments by investors, in 2024 CFDs
were the most frequently chosen, but their share in terms of numbers, i.e. opened, closed,
and maintained positions in the analyzed year was lower y/y by 12.9 pp. One can notice an
increase in the share of shares by more than 6 pp, as well as an increase in interest in the
Investment Plans service by more than 4 pp.
The average time of holding a position in 2024 by clients on products such as stocks, ETPs
or Investment Plans was 180 days. For CFDs, more than 80% of positions were held for
less than 1 day.
Marketing – Reach Channels
As previously indicated in this Report, the business objective of the XTB Group remains
a further, consistent transformation into a global brand. The implementation of this goal is
supported by targeted marketing activities. In order to reach mass client, the Company
builds brand recognition in international markets through the appropriate selection of XTB
Ambassadors, planned and implemented advertising campaigns in traditional and digital
media, sharing added value in the form of information and educational materials in the field
of finance and economics.
In January 2024, XTB launched an international campaign promoting the new product
Investment Plans. In September of the same year, a new Ambassador was announced, who
became Zlatan Ibrahimovic, and another campaign was launched. XTB understands that in
order to achieve their goals, clients need a lot of opportunities and diversification, which is
why the application created by the Company is a universal tool to effectively multiply money.
Of course, with a reminder that investing is associated with risk and you should invest wisely.
The campaign with the new Ambassador, promoting the brand and products, took place in
the period from the end of September to the end of December 2024 on the following markets:
Poland, the Czech Republic, Slovakia, Romania, Germany, France, Portugal, Spain, the
United Kingdom, Italy, Latin America, and Asia. As part of the campaign, television spots,
billboards and out-of-home media appeared in selected countries, as well as advertisements
on the Internet and on social media. The XTB communication team prepared and distributed
press releases to selected media, obtaining 162 publications of articles in domestic and
foreign media. Videos posted on YouTube have reached a total of over 1.5 trillion views,
achieving a viewing result better by half than in the case of campaigns with previous
Ambassadors. Social media channels reached 400 million views of the posts related to the
campaign. The activities carried out contributed to a 35% increase in the number of new
clients in the fourth quarter of 2024 compared to the previous quarter.
0,2%
2,1%
9,3%
88,3%
0,3%
4,3%
4,6%
15,3%
75,5%
Individual Pension
Account (IKE)
Investment Plans ETP Shares CFDs
The asset classes most frequently chosen by investors in 2023 and 2024
2023 2024
51
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
Factors that affect the operations of the Group and the Company
Economy of Poland
In 2024, Polish GDP increased by 2.9% compared to the previous year. In the opinion of
economic analysts, this may mean that Poland is gradually starting to emerge from the
phase of stagnation associated with the events of recent years: the pandemic, the war in
Ukraine and the energy crisis. The main supporting factors are export growth and the
recovery of internal consumption, which increased by more than 3% y/y.
Inflation in Poland in 2024 was higher than the National Bank of Poland (NBP) target of
2.5%. The highest level of inflation was recorded in March 2024, and the average annual
price increase amounted to 4.7%. In the following months, inflation remained above the
target, which influenced the Monetary Policy Council's (MPC) decisions to keep interest
rates unchanged at 5.75%.
This situation was conducive to the activity of XTB in such a way that the interest of individual
clients was growing, who were actively looking for the opportunity to multiply their funds
through selected financial instruments.
A moderate economic recovery and a possible reduction in interest rate may foster an
increase in the number of accounts opened and trading volumes, especially while continuing
the strategy of "zero commissions" (on specific instruments) and further expansion of the
product offer.
In 2024, the unemployment rate in Poland, calculated on the basis of the Population
Economic Activity Survey (BAEL), was as follows:
▪ Q1 2024: 3.1%
▪ Q2 2024: 2.7%
▪ Q3 2024: 2.9%
▪ Q4 2024: 2.8%
These data indicate an overall downward trend in the unemployment rate in the first half of
2024, with a slight increase in the third quarter. These data reflect positive trends on the
Polish labor market in the final months of 2024, with persistently low levels of
unemployment.
Forecasts for 2025
Economic forecasts for Poland for 2025 indicate further economic development, with
simultaneous challenges related to inflation and the need for structural reforms. The
International Monetary Fund (IMF) predicts that Poland will achieve GDP growth of 3.4%.
At the same time, the Polish government announced investments worth PLN 650 billion to
stimulate economic growth, supporting the defense, green energy, IT and transport
infrastructure sectors.
According to the OECD (Organization for Economic Co-operation and Development),
inflation in Poland may rise to 5% this year, before falling to 3.9% in 2026. The organization
Marketing is the second driving force behind XTB. In order to
strengthen its market position and recognition in the world, the
Group cooperates with titled athletes who are XTB brand
ambassadors.
52
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
recommends Poland to reduce expenditures and increase taxes in order to meet the
growing budget deficit.
Since October 2023, the Monetary Policy Council has maintained interest rate at 5.75%. As
announced, the MPC will start the cycle of interest rate cuts in the second half of 2025, but
the pace of these cuts will be moderate due to inflationary risks.
According to the IMF, global economic growth in 20205 could reach 3.3%. The United States
is expected to grow at 2.7%, while the eurozone is expected to grow at 1.0%, mainly due to
the weakening of industry in Germany and France.
At the same time, the United Nations indicates that Europe's economy is expected to grow
to 1.3%. The potential recession in Europe, caused by the weakening of industry and
consumption, may affect the valuation of companies and limit the growth of stock markets.
World economy
After recessions and slowdowns in 2022 and 2023, the global economy began to show signs
of recovery in 2024. Economic growth in the world in 2024 was about 2.5-3%, which was
a reflection of the previous crises related to the COVID-19 pandemic and the war in Ukraine.
The economies of highly developed countries such as the United States and Germany
began to record stable growth.
Global inflation declined in 2024, but remained one of the main economic challenges. In
developed countries, such as the USA, the European Union, or the United Kingdom, its level
began to gradually decline, amounting to about 4-6%.
In developing countries, inflation was higher, and some of them struggled with increased
costs of living, especially in regions that were affected by food crises or declining foreign
aid.
The inflation was mostly countered by using high interest rate. However, in 2024, some
Central Banks (e.g. in the US and Europe) began to consider lowering interest rates in the
second half of the year, when inflation began to decline and the economies showed signs
of slowing down. Interest rates of 5-6% in many developed countries may have caused
a decline in investment, especially in the real estate and consumption sectors.
Unemployment in the world in 2024 was at a relatively low level, especially in developed
countries, where the labor market has largely recovered from the COVID-19 crisis. In
developing countries, the situation was more diverse.
53
Management Report of XTB Group and XTB S.A. in 2024
/Business Model
War in Ukraine and its impact on economies
The war in Ukraine continued to have a huge impact on the economies of Europe and the
world. Primarily, it led to an increase in the prices of energy resources, including gas and
oil, which increased inflation. The conflict also affected global supply chains. As a result,
many countries began to intensively strive to diversify their energy sources and supply of
raw materials, which had a long-term impact on energy policies around the world.
Green transition
In 2024, an increase in investments in green energy and technologies related to combating
climate changes was still observed. Many countries, especially in Europe and Asia, have
taken further steps to achieve their CO2 reduction targets.
As part of the energy transition, many developed countries have invested in renewable
energy sources (RES), as well as in technologies such as energy storage, hydrogen and
electric vehicles.
New technologies and innovation
Digital technologies and artificial intelligence were still crucial for the development of the
global economy. In 2024, the development of the IT, e-commerce and automation sectors
continued. Technology companies played a key role in post-crisis recovery and fueled
innovation.
It was also the year in which artificial intelligence systems began to play an even greater
role. In the United States, artificial intelligence was the main area of interest for venture
capitalists. As many as 49 AI startups received funding of at least USD 100 million. The
development of AI technology has given rise to the need to adapt and adopt legal
regulations. For example, the Artificial Intelligence Act was introduced in the European
Union.
Fintech sector
According to reports, the global fintech market is growing at a rapid pace, averaging 20%
per year, driven by technological innovation, the increasing digitization of financial services,
and the demand for convenient, secure, and accessible solutions.
In 2024, there was a noticeable increase in interest in the area of sustainable development
of the fintech industry. FinTech has started to play an important role in promoting green
solutions, contributing to the creation of a more environmentally friendly financial ecosystem
The growing integration of AI in financial services was also observed, which allowed for
better personalization of offers, automation of processes and improvement of risk
management.
In 2025, the market expects further integration of fintechs with traditional financial
institutions. Open banking models that allow for the secure sharing of financial data between
banks and fintechs will support the development of more innovative services:
▪ development of new payment methods, such as biometric payments, payments
based on geolocation or instant transfers between banks;
▪ new financial products, such as common investment platforms, that will enable the
use of blockchain technology in traditional financial institutions;
▪ offering faster and more flexible credit products that will be adapted to the current
financial situation of clients.
Development of the fintech sector in Poland in 2024 and 2025
According to the report of the FinTech Poland Foundation, "How to do FinTech in Poland?",
the number of domestic fintech companies increased in 2023 to 417, 188 of which were
based in Warsaw. Most fintechs operate in three market segments: payments, treasury
management, and software.
In 2024, the value of investments in the Polish fintech sector reached EUR 775 mln, which
is an increase of 2114% compared to 2018. In Poland, the number of venture capital funds
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that invest in promising fintech startups is growing. In addition, Poland is becoming an
attractive place for global investors who see the potential of the market in this region.
Based on the forecasts of the largest analytical companies in Poland, this year the value of
the Polish fintech market may reach about USD 2.5 billion, which is an increase of about
20-25% per year compared to previous years. This increase will result from the growing
number of users of fintech services, new investments and the introduction of innovative
financial products.
Investors and financial instruments market
As predicted by investment funds, in 2025, faster normalization of monetary policy by the
Monetary Policy Council (MPC) can be expected. This normalization, consisting in a gradual
reduction of interest rate, may increase the attractiveness of debt instruments, such as
domestic and foreign bonds.
At the same time, as a result of this normalization of monetary policy, an increase in the
availability of capital on the financial market is also expected, which may support an increase
in investments in financial instruments with a medium and long maturity.
The interest in the capital market and investing in financial instruments is increasing year by
year, among others, due to the growing investment awareness in Poland related to financial
education. Poles are increasingly willing to invest on their own, using easily available tools.
This is confirmed by the gradual increase in the number of investment accounts in Poland,
which at the end of 2024 reached 1.97 million.
Geopolitical environment
Bearing in mind that the XTB Group is an entity operating in international markets, its
activities may be affected by changes related to geopolitics. The armed conflict in Ukraine
is currently taking place in the region of Central and Eastern Europe.
On February 24, 2022, Russian troops crossed the eastern, southern and northern borders
of Ukraine, attacking the territory of Ukraine. In connection with Russia's warfare,
representatives of the European Union and many other countries imposed severe sanctions
on Russia, which mainly affect strategic sectors of the Russian economy by blocking access
to technology and markets. This situation does not have a significant direct impact on the
Group, however, it caused high volatility in financial and commodity markets around the
world, which had an impact on the transaction activity of XTB clients and the Group's results
in previous years. This allows us to predict that subsequent changes during this conflict will
also indirectly affect the activities of XTB, affecting the situation on the capital markets of
Europe and the world.
Legal and regulatory environment
The XTB Group operates in a strictly regulated environment, imposing certain important
obligations on the Group in the field of many international and local regulations and legal
regulations.
The Group is subject to regulations regarding, among others:
▪ sales practices, including client acquisition and marketing activities;
▪ maintaining capitals at a certain level;
▪ practices in the prevention of money laundering and financing of terrorism and
client identification procedures;
▪ obligations of reporting to regulatory authorities and reporting to transaction
repositories;
▪ obligations regarding the personal data protection and the observance of
professional secrecy;
▪ obligations to protect investors and provide them with relevant information on the
risks associated with the brokerage services provided;
▪ supervision over the Group's activities;
▪ confidential information and its use, prevention of unlawful disclosure of
confidential information, prevention of market manipulation;
▪ publishing information as an issuer.
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The XTB S.A. Capital Group is subject to the supervision of certain regulatory supervisory
authorities and public administration bodies in the jurisdictions in which the Group operates.
In Poland, conducting brokerage activity requires the permission of the Polish Financial
Supervision Authority and is subject to many regulatory requirements. The Company is
a brokerage house operating on the basis of a brokerage license and is subject to regulatory
supervision by the Polish Financial Supervision Authority.
Thanks to the principle of a single European passport resulting from the MiFID II Directive,
the Company operates in the form of a branch on the basis of and under the authorization
granted by the Polish Financial Supervision Authority in the following EU Member States:
the Czech Republic, Spain, Slovakia, Romania, Germany, France and Portugal.
In addition, XTB S.A. and its subsidiaries are entitled to:
▪ conducting cross-border brokerage activities without opening a branch in the territory
of many jurisdictions, focusing mainly on the Italian and Hungarian markets;
▪ conduct cross-border activities on the territory of Austria, Belgium, Bulgaria, Greece,
the Netherlands, Sweden, Hungary and Italy;
▪ in addition, the Company holds 100% of shares in the following entities currently
operating on the basis of separate brokerage permits issued by the supervisory
authorities in: the United Kingdom, Cyprus, Belize, the United Arab Emirates,
Indonesia, the Republic of Seychelles, and the Republic of South Africa.
The XTB Group has established a compliance function for each Group Company providing
brokerage services to ensure compliance with the laws and regulatory requirements to
which the Group is subject.
The regulatory environment in which the Group operates is subject to constant evolution.
In recent years, the financial services sector has been subject to increasingly
comprehensive regulatory supervision. The supervisory and public administration bodies
regulating and supervising the Group's activities have introduced a number of changes to
the regulatory requirements to which the Group is subject and may take additional initiatives
in this regard in the future.
Changes in the regulatory environment of the Group
Below are described the most significant regulatory changes, from the Company's
perspective, that have occurred recently, as well as changes that will come into effect in the
upcoming periods.
Regulation of the European Parliament and of the Council on the digital
operational resilience of the financial sector and amending Regulations (EC)
No. 1060/2009, (EU) No. 648/2012, (EU) No. 600/2014 and (EU) No. 909/2014
(Digital Operational Resilience Act "DORA")
On December 27, 2022, a regulation was published in the Official Journal of the EU, the
provisions of which are aimed at ensuring the resilience of financial sector entities to threats
related to the use of digital and information and communication technologies (ICT)
The key issues of the Regulation are:
▪ rules for managing ICT risks, including the use of third-party technology providers.
▪ obligations to periodically conduct digital resilience testing of systems;
▪ requirement for detailed classification and reporting of incidents;
▪ introduction of information exchange systems between financial entities regarding
methods and techniques of effective defense against ICT-related threats.
The Regulation entered into force on 16 January 2023. Financial sector entities must comply
with its requirements by 17 January 2025 at the latest.
The Company exercised its due diligence to prepare and comply with its obligations under
the regulation.
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Draft Act Amending Certain Acts in Connection with Ensuring the Operational Digital
Resilience of the Financial Sector of 5 April 2024
On April 18, 2024, a draft act amending certain acts in connection with ensuring the
operational digital resilience of the financial sector was published on the website of the
Government Legislation Center. The project aims to implement into the Polish legal system
and ensure the application of the DORA Regulation.
The key issues of the Act are:
▪ confirmation of the function and competence of the PFSA as the competent
authority for supervision in ensuring the operational digital resilience of the
financial sector;
▪ the need to provide the PFSA with information on ICT contracts by 31 January
each year;
▪ changes in the field of bank outsourcing (including an extended catalogue of
entrustment bases, additional obligations of the bank and the entrepreneur in
relation to ICT systems) and the right to examine the results of operational
resilience tests by the Polish Financial Supervision Authority;
▪ in the case of violations – penalties for financial institutions up to approx. PLN 21
million (or 10% of revenues), penalties for persons responsible up to PLN 3
million or a ban on performing the function of a member of the management
board, supervisory board or other managerial function for up to 1 year.
Currently, the project is at the stage of the Legal Committee.
Regulation of the Minister of Finance of 20 September 2024 on the provision of
information to the Polish Financial Supervision Authority by investment companies,
state banks conducting brokerage activities, banks referred to in art. 70 section 2 of
the Act on Trading in Financial Instruments, and fiduciary banks
On September 28, 2024, the Regulation of the Minister of Finance of September 20, 2024,
regarding the submission of information to the Polish Financial Supervision Authority (KNF)
by investment firms, state-owned banks conducting brokerage activities, banks referred to
in Article 70, Section 2 of the Act on Trading in Financial Instruments, and custodian banks,
took into effect. The new provisions of the regulation are more detailed and require more
comprehensive reporting, in line with modern standards and EU requirements. Compared
to the previous version of the regulation, new definitions have been introduced, expanded
requirements regarding risk management, stricter reporting rules, as well as compliance
with regulations related to digital resilience (DORA), aiming to enhance the safety and
financial stability of the investment market.
The Act of 6 December 2024 amending the Act on Accounting, the Act on Statutory
Auditors, Audit Companies and Public Supervision and certain other acts
On April 19, 2024, a draft act amending the Accounting Act, the Act on Statutory Auditors,
Audit Companies and Public Supervisory Officers, and certain other acts, was published on
the website of the Government Legislation Center. The purpose of the amendment is to
implement into national law Directive (EU) 2022/2464 of the European Parliament and of
the Council of 14 December 2022 amending Regulation (EU) No 537/2014, Directive
2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as regards corporate
sustainability reporting, and Commission Delegated Directive (EU) 2023/2775 of 17 October
2023 amending Directive 2013/34/EU of the European Parliament and of the Council, as
regards the adaptation of the size criteria of an enterprise to micro, small, medium and large
entities or groups. The key objective of Directive 2022/2464 is to ensure that a larger group
of companies report relevant, comparable and reliable information on sustainable
development – more useful for investors and other stakeholders.
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The key issues of the Act are:
▪ facilitating accounting for small and micro-units;
▪ introduction of the obligation to report on sustainable development regarding
large entities, listed entities and certain financial institutions and the obligation to
attest to this type of reporting;
▪ simplifying reporting in capital groups.
The Act of December 6, 2024, signed by the President of the Republic of Poland on
December 12, 2024, came into force 14 days after its announcement. The changes
regarding revenue thresholds and criteria for the size of enterprises came into effect on
January 1, 2025, while the provisions related to sustainable development reporting were
broken down and will come into force gradually between 2024 and 2027.
Act of 26 April 2024 on ensuring compliance with the requirements for the availability
of certain products and services by business entities
On 26 April 2024, at the meeting of the Sejm, the Act on ensuring compliance with the
requirements for the availability of certain products and services by business entities was
adopted. It implements Directive (EU) 2019/882 of the European Parliament and of the
Council of 17 April 2019 on accessibility requirements for products and services. The law
aims to ensure that all websites, mobile applications and other digital services are
accessible to people with various disabilities by adapting digital content to accessibility
standards.
The Act will enter into force on June 28, 2025. At the same time, contracts for the offer or
provision of services concluded before the date of entry into force of the Act may continue
to apply unchanged until their expiry, but not longer than until 28 June 2030, as well as the
service provider may offer or provide services until 28 June 2030 using products that do not
meet the accessibility requirements that he used to offer or provide services of the same
type before the date of entry into force of the Act.
Competitive Environment
XTB Group is among the leading brokerage houses on the international market and remains
one of the leaders of the sector in Poland. In its competitive environment, three groups of
entities may be distinguished:
▪ brokers offering access to investment products via trading platforms and All-in-One
mobile applications,
▪ fintech companies, and
▪ brokers offering only CFDs.
Within the indicated groups, XTB identified the most important market
competitors. The first category are entities operating as a trading platform,
through which their clients can trade.
▪ eTorro is an investment platform of the social trading type, which offers trading
assets such as shares, currencies, raw materials, cryptocurrencies and ETFs. One
of the key functions of eToro is CopyTrader™, which allows users to automatically
copy transactions of other investors in real time. The paltfrom is available both via
a website and a mobile application. eTorro has international reach and operates in
countries such as the United States, United Kingdom, Israel, Cyprus, Australia,
Germany, and United Arab Emirates.
▪ Trading 212 offers a platform for trading in stocks, ETFs, CFDs and
cryptocurrencies. The company was established in 2006. Trading 212 attracts
investors with the lack of commission on transactions on shares, ETFs and parts
of CFDs. The platform gives access to shares on major exchanges, such as the
NYSE, NASDAQ, or LSE. Trading 212 offers a mobile application available for
Android and iOS as well as a web platform. The company is regulated by the
Financial Conduct Authority (FCA) in the United Kingdom. Trading 212 offers
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educational materials such as instructional videos, articles, and tutorials that help
users understand financial markets and the platform.
▪ Robinhood Markets, Inc. is an American company offering their clients a trading
platform allowing to invest in shares, ETFs, options and cryptocurrencies without any
commission. Robinhood operates primarily online, through mobile apps and
a website.
The second crucial sector of the competition are fintech companies. This
group includes entities interesting clients due to the innovativeness of the
tools they offer users.
▪ Trade Republic is a German online broker founded in 2015 in Munich, offering
trading in stocks, bonds, derivatives and cryptocurrencies via a mobile app. After
the introduction of investment services, Trade Republic started offering current
accounts with interest rates on deposits and plans to introduce savings plans and
other financial products such as PEA or Livret A in France.
▪ Scalable Capital is a German company specializing in automated investment
management. It has been operating on the market since 2014 and is one of the
leading providers of robo-advisory services in Europe. The company offers
investing in ETFs and portfolio management using modern algorithms, tailored to
the individual risk preferences of clients. Scalable Capital is also available in the
United Kingdom, Austria, Switzerland, as well as in other European Union
countries. Users can manage their investments through both a mobile application
and a web platform.
The last group of competitors of XTB are entities of international reach,
brokers specializing in CFD derivatives.
▪ Plus500 is a brokerage platform that specializes in trading CFDs, allowing
investors to trade in stocks, forex, raw materials, indices, cryptocurrencies and
many other financial instruments. The company was established in 2008. Plus500
offers its services in more than 50 countries. The company is listed on the London
Stock Exchange and is regulated by numerous financial supervisory authorities,
including the Financial Conduct Authority (FCA) in the United Kingdom, ASIC in
Australia, and other institutions in international markets. Plus500 Platform: The
platform offers trading tools on both desktop and mobile versions. The Plus500
platform offers analytical tools such as charts, technical indicators and risk
management tools. Plus500 offers educational materials including tutorials,
articles, videos and other resources to help novice traders understand the market
and the platform.
▪ IG Group is a global broker based in the UK that offers trading in Forex, CFDs,
Shares, Commodities and Cryptocurrencies. The company operates in many
international markets, offering its services in more than 17 countries , including
Europe, the United States, Australia, Canada and Asia. IG Group offers trading
platforms that allows to trade in different markets. In addition, the company offers
mobile applications that allows to invest anywhere and anytime. IG Group is
regulated by several financial supervisory authorities, including the Financial
Conduct Authority (FCA) in the United Kingdom. The company, like XTB, offers a
wide range of educational materials for investors, including webinars, guides and
analytical tools.
▪ CMC Markets is a British company offering financial services and specializing in
online trading of CFD derivatives, e.g. contracts for difference. The broker has
additional operational centers in Sydney and Singapore. The company is present on
international markets, including Poland. CMC Markets is regulated by the Financial
Conduct Authority (FCA) in the United Kingdom and by Bundesanstalt für
Finanzdienstleistungsaufsicht (BaFin) in Germany.
▪ Saxo Bank is a Danish investment bank and online broker that offers trading in
stocks, forex, CFDs, bonds, mutual funds as well as portfolio management. The
company has been established in 1992. Saxo Bank offers its services in more than
180 countries around the world. The company offers trading platforms for online
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trading including: SaxoTraderGO mobile and desktop application and
SaxoTraderPRO tool for experienced traders with advanced analytical options. Saxo
Bank is regulated by the Financial Conduct Authority (FCA) in the United Kingdom,
the Danish Financial Supervisory Authority (FSA) in Denmark, and other regional
regulatory authorities. The company provides educational materials for its users.
As mentioned before, in Poland XTB Group is a leader among the brokerage houses,
primarily due to the broad offer of investment products sharing its own, innovative trading
platform and mobile application. In its closest environment, the competition remains with
other domestic brokers focusing their services on the market of basic financial instruments
such as stocks, bonds, funds, but also offering access to ETFs, raw materials, or
cryptocurrencies. In Poland, there are several brokerage houses operating at the largest
banks that offer brokerage services on the financial market. Below is a list of the most
important banking brokers in Poland:
▪ mBank Brokerage. It offers trading in stocks, bonds, ETFs, CFDs,
cryptocurrencies. Access via mTrader (online platform), mInvestor (mobile
application).
▪ Santander Brokerage. It offers services for individual and institutional investors:
stocks listed on the WSE and foreign markets, bonds, ETFs, investment funds.
Access via Santander Broker platform.
▪ Brokerage House of the Environmental Protection Bank. It offers trading in stocks,
bonds, mutual funds and derivatives. Access via BOSSA.pl (online platform),
BOSSAFX (forex platform).
▪ PKO BP Brokerage House. It offers services for individual and institutional
investors: stocks listed on the WSE and foreign markets, bonds, ETFs, investment
funds. Access via IBI Trader (investment platform).
▪ ING Securities (ING Brokerage Office). It offers trading in stocks, bonds, ETFs,
futures, mutual funds. Access via ING Broker platform.
▪ Bank Pekao S.A. - Pekao Brokerage. It offers trading in stocks, bonds, ETFs,
mutual funds, futures. Access via Pekao Trader platform.
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The main competitive advantages of the XTB Group
A wide range of financial instruments: XTB competes with other brokers and entities offering a variety of financial products, such as stocks, ETPs, Investment
Plans, CFDs. XTB offers also interest rates on free funds, e-Wallet with a multi-currency card, long-term investment accounts IKE (Poland) and ISA (United Kingdom).
Trading platform: XTB offers its own xStation platform, which is considered one of the best on the market. It is constantly being improved to make it even more
intuitive to use.
Favorable trading conditions: XTB offers competitive trading conditions, including low spreads, no commissions up to EUR 100k of turnover on stocks and ETPs,
and no hidden fees. For some instruments, such as CFDs, spreads are one of the lowest on the market, which gives investors better conditions to earn. XTB does
not charge fees for depositing or withdrawing funds from one's account, which makes the use of the platform more transparent in terms of costs.
Global presence: XTB operates in many international markets, offering its services in more than 15 countries. Global reach means that XTB can attract investors
from different parts of the world.
Strong regulation: XTB is regulated by 9 prestigious financial supervisory authorities, such as the FCA (Financial Conduct Authority) in the United Kingdom, the
KNF (Polish Financial Supervision Authority) in Poland, and others in the countries in Europe, Middle East and Latin America.
Security of client funds: XTB uses segregation of client funds, which means that investors' funds are kept separate from the company's assets, thus increasing
security.
Professional service: XTB offers support for its clients 24 hours a day, 5 days a week, both by phone and via live chat. The company focuses on professional
service and quick problem solving, which translates into a high level of user satisfaction.
Education: The company offers a range of educational materials through its XTB Academy platform, including webinars, video courses, articles and guides. This
makes XTB attractive not only for professional investors, but also for beginners who want to learn the basics of investing. XTB organizes regular educational sessions
and market analyses that help investors keep track of current events and make informed investment decisions.
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Strategy
and operations
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
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Development strategy and its realisation in 2024
Business and Sustainability Strategy
Currently, responsible and modern business understands and can identify its impact on the surrounding environment, communities and regulations. XTB Group, being a dynamically developing
fintech, has incorporated ESG (Environmental, Social, and Governance) sustainability criteria into its business strategy, integrating both areas. In 2024, the Company adopted the ESG Strategy
for 2024-2027.
SUSTAINABILITY
▪ Responsible management practices
▪ Regulated activities
▪ Risk management
▪ Responsible payment practices
▪ Technology and Product Portfolio Development
▪ Responsible marketing
▪ Transparent communication
▪ Financial education
▪ Business ethics
▪ Fair competition
▪ Mature organizational culture
▪ Human rights and competitive employment conditions
▪ Employee development and competence building
▪ Diversity and flexibility
BUSINESS OBJECTIVES
Strengthening our position in European markets
Further geographic expansion into new markets, including Latin
America and Asia
Further development and strengthening of the segment of institutional
clients through the X Open Hub
Expanding the offer of the Group's products and services, developing
technological innovations
Development through acquisitions, mergers and joint ventures
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The detailed sustainability goals include and reinforce the main directions of the Group's
strategic development. At the same time, the desire to build and share solutions that will allow
every person interested in the subject of investment to achieve their goals, regardless of their
experience in this area, remains an important point of pursuit.
Supporting the awareness and education of Investors, XTB offers access to free, professional
courses and conferences XTB Investing Masterclass, daily market analysis, and
InvestResponsibly.com platform. As a Polish FinTech company, XTB is constantly developing
its own technologies, employing experts for this purpose.
In 2024, the implementation of the adopted business goals was as follows:
▪ Development of business and strengthening of market position in Central and
Eastern Europe and Western Europe
In the past year, the Company was constantly looking for opportunities to expand its
client base. To this end, it introduced new, attractive products to the offer, as well as
conducted marketing campaigns aimed at building brand recognition and its offer.
▪ Expanding the Group's international presence by expanding into new markets
The Group is increasingly boldly building its presence in non-European markets,
consistently pursuing the strategy of creating a global brand. The Management
Board of XTB puts the main emphasis on organic growth, on the one hand increasing
the penetration of European markets, and on the other successively building its
presence in Latin America, Middle East and Asia.
In 2024, the Group obtained a new license to operate in Indonesia and a license to
expand its business in the United Arab Emirates. Moreover, the Company’s efforts
focused on obtaining the necessary licenses and permits and preparing the
necessary infrastructure to start operations in Brazil.
▪ Development of the institutional business segment (X Open Hub)
In 2024, the Management Board focused on further developing cooperation with
institutional clients as part of the X Open Hub by offering them two categories of
products and services: liquidity and transaction technology. The technologies
provided by the Group enable its institutional clients to build a trading environment
to offer the same or similar products and services as are available in the Group's
product and service portfolio and therefore potentially compete with XTB.
The development of the institutional business segment depends to a large extent on
the acquisition of new clients. Unlike the retail business segment, acquiring
a potential institutional client is a relatively long process, usually lasting up to a year.
As of December 31, 2024, the number of institutional clients was 31, compared to
33 the previous year.
▪ Expanding the offer of the Group's products and services and developing new
technologies
The Group is continuously develop its business by offering clients new products
and services. I n 2024, the Group introduced several new products, including a long-
term savings account (IKE) in Poland and an ISA in the United Kingdom. The eWallet
service was also launched – a virtual wallet for managing payments, linked to a multi-
currency card. A detailed description of the introduced products can be found in this
section, under the Product Plan point (below).
The company is constantly working to improve the functionality of the trading
platform and mobile application available to clients. In the past year, the application
interface was improved, simplifying its appearance in order to increase the
intuitiveness of using this tool.
Technologies developed by the Group on its own are to ensure its competitive
advantage over other suppliers of transactional systems in terms of system quality,
as well as to enable it to offer clients more competitive products and services in
terms of price.
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▪ Development through combinations and acquisitions of other entities
attractive to the Group, as well as joint ventures
The Group allows investments in attractive companies offering products and
services similar to the Group's products and services, which may complement its
product, service and geographical offer. However, it is assumed that the main driver
of XTB's growth will be organic development.
In 2024, the Group obtained shared in an Indonesian company, which allowed it to
enter the Indonesian and obtain the license for the conduct of brokerage activities.
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Product plan in 2024
In 2024, XTB expanded its product portfolio with the following products and
services:
▪ Investment Plans, i.e. based on ETP funds, a key product from the passive
investment segment, has been equipped with an auto-investment function that
allows the user to build the habit of regularly, systematically investing - even with
small amounts. The feature enabled clients to make fixed, recurring payments to
their individual portfolios of ETP funds. The amounts are then automatically invested
in accordance with the client's predetermined allocation of funds.
▪ XTB Social, a social service that allowed users to follow the best investors in XTB,
receive notifications about transactions and the most important statistics about their
investment portfolios. Client data was fully anonymized and classified solely on
the basis of the achieved rate of return and the accepted level of risk. In June 2024,
The Company decided on suspension of this service in the European Union in
relation to the statement of the Polish Financial Supervision Authority of 29 May
2024 regarding the conditions for the provision of social trading services by
investment firms. The Company is in dialogue with the regulator about the potential
further implementation of the XTB Social service and its future shape.
▪ In the third quarter of 2024, XTB has significantly strengthened the security of its
clients' accounts with the introduction of two-factor authentication (2FA). The
XTB publishes the product plan, providing clients and investors with more complete information about its current and future offer. The
Group is constantly carrying out work related to the introduction of further investment products that are expected and tailored to the needs
of clients, while taking into account current trends and changes in the investment instruments market.
The introduction of each new product is preceded by many months of development and research and development works, including ones
using technologies based on artificial intelligence. These activities improve the functionality and increase the comfort of using the xStation
investment platform and mobile application. These changes are supervised by a specialized and highly professional Technology and
Product Department, which is one of the most dynamically developing departments in the Company. It is worth noting that simplifying the
service and adapting the application home screen to the way clients use it is part of the development of the Company's main tool – which
will support the achievement of the strategic goal of building a global brand with the leading All-in-One investment application.
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introduction of 2FA was one of the important elements of the product plan, preparing
XTB to implement further product innovations.
▪ eWallet, a virtual wallet with a multi-currency card that supports cashless payments
in stores, mobile transactions and contactless cash withdrawals from ATMs around
the world. The product allows clients to maintain accounts in seven currencies: EUR,
USD, GBP, PLN, HUF, RON and CZK, as well as fast and free transfers of funds
between accounts. The eWallet service provides clients with immediate access to
their funds and payments with a card issued under the Mastercard license by
DiPocket UAB, an Electronic Money Institution registered by the Bank of Lithuania.
This service debuted on the Czech and Portuguese markets at the beginning of
October 2024. Since the beginning of 2025, it has been available to clients from the
Czech Republic, Portugal, Romania, Slovakia, Germany, Italy, Spain, France, and
Poland.
▪ In parallel with eWallet, at the beginning of October 2024, XTB clients in Poland
gained the opportunity to long-term invest their savings for the retirement. IKE
accounts offering investors tax benefits were added to the XTB offer initially only for
new clients, and at the end of the year, the Company also enabled the gradual
transfer of IKE accounts held at other financial institutions.
▪ Then, at the beginning of December, XTB offered clients in the United Kingdom the
opportunity to invest in an ISA (Individual Savings Account). This is another product
with a tax benefit for investors interested in long-term investment of funds. Along
with the launch of ISA, XTB also introduced a new, refreshed portfolio view in the
application. Thanks to this, users can see all their investments and transaction
history in one place. In subsequent markets, the refreshed portfolio view will appear
with the launch of the eWallet service.
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Management Report of XTB Group and XTB S.A. in 2024
/ Strategy and operations
In 2025 and beyond, XTB plans to further broaden its product offer. The following are planned for introduction this year: options, cryptocurrencies, and new long-term investment products: IKZE
accounts in Poland and PEA in France
.
The presented product plan corresponds to the current state of knowledge and resources. It may be subject to changes and modifications, e.g. due to possible changes in the regulatory and legal
environment of the Company, as well as due to reasons resulting from the cooperation of XTB with external suppliers.
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Management Report of XTB Group and XTB S.A. in 2024
/ Strategy and operations
Significant Achievements in the Field of Research and Development
Building competitive advantages in the fintech segment
As a technological entity operating in the financial sector, XTB is constantly working on the
development of highly innovative, comprehensive solutions in the field of transactions and
online investments in financial instruments (research and development). This makes the
Company a FinTech organization. The aim of the above works is to develop innovative
technologies and solutions allowing, in particular, for the further development of the product
offer. XTB is the owner of a number of proprietary technological solutions, including the
modern xStation trading platform.
The research and development works carried out in 2024 were aimed at the development of
tools necessary for the efficient functioning of XTB transaction systems, effective execution
of orders, an efficient process of acquiring new clients (onboarding) and the further
development of tools supporting internal processes in the company as a result of the identified
development needs. The research areas focused on the functionality and security of systems,
processes and databases. Research and development works aimed at the development of
new electronic trading systems were also carried out.
Due to the adopted business strategy based on the development of new technologies,
the XTB structure has separated the Product and Technology Department, in which majority
of the staff are employees involved in research and development. The works in question have
a significant, almost strategic impact on the business activity conducted by XTB. Not only do
they translate into the level of revenues generated by XTB, but they are also crucial in the
process of building and maintaining the Company's highly competitive position on the global
capital market.
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Management Report of XTB Group and XTB S.A. in 2024
/ Strategy and operations
The table below shows the number of employees in the Product and Technology Department and the costs associated with the development of highly innovative, comprehensive solutions in the
field of transactions and online investments:
12-MONTH PERIOD ENDED
31.12.2024
31.12.2023
31.12.2022
31.12.2021
31.12.2020
31.12.2019
31.12.2018
Costs of the Product and Technology Department (in thousands PLN)
166 250
94 770
58 381
36 616
27 159
21 151
18 974
Number of employees in the Product and Technology Department
1
498
429
282
176
129
116
106
1
Persons employed under a contract of employment, contract of mandate, and providing services under a B2B contract.
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Management Report of XTB Group and XTB S.A. in 2024
/ Strategy and operations
Name:
XTB Foundation
Registered Address:
Prosta Street 67, 00-838 Warsaw
Date of NCR registration:
23.12.2020
NCR:
0000861567
REGON:
38778254000000
Tax ID:
5272945208
ESG Strategy and Management
In 2024, XTB Group adopted an updated ESG Sustainability Strategy. As part of the
conducted Double Materiality Assessment, a list of relevant topics on climate change and
circular economy was selected. A project was undertaken to identify key climate opportunities
and risks which will allow the Group to comprehensively manage the area of climate change.
In the environmental field, the strategic objective of the XTB is a responsible approach to the
management of e-waste, environmental education of Employees, effective resource
management and actions to enable the setting of greenhouse gas emission reduction targets
in the Group.
In the social field, the strategic goal of XTB is a safe and inspiring working environment,
building lasting social relations, active dialogue with the Stakeholders and offering services
and products that meet the expectations of clients.
In the field of corporate governance, the strategic objective of the XTB is to build long-term
value through the transparent and responsible management of environmental, social and
corporate governance aspects in the XTB S.A. Group.
Detailed information on the activities undertaken in 2024 in the indicated areas can be found
in the Sustainable Development Statement section of this Report.
Education
In its business activities, the XTB Group also recognizes the possibility of building the image
of a professional partner on the financial instruments market by implementing educational
activities. The company develops and provides content on investment instruments, market
analyses, online courses for beginners and more experienced investors. During the cyclical
webinars, experts and renowned XTB analysts share their reviews and analyses of current
macroeconomic events and the situation of selected financial instruments.
An additional level of educational activities is provided by the XTB Foundation established
within the Group. In the perspective of its activity, there are initiatives aimed at children and
young people, through which basic financial education is spread.
Sponsorship and charity
In 2020, on the initiative of the Management Board of XTB S.A., the XTB Foundation was
established. Since 14 February 2024, the Chairman of the Foundation's Management Board
has been Sylwia Kozoń.
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Management Report of XTB Group and XTB S.A. in 2024
/ Strategy and operations
The Foundation was established to support and organize all initiatives related to the promotion
of financial institutions and new technologies, thereby influencing the growth of trust
and respect for these institutions. In its activities, it works to raise financial and technological
awareness, while realizing activities in the area of corporate social responsibility and
sustainable development.
According to its statutory objectives, the Foundation's corporate object is:
▪ increasing entrepreneurship and innovation, particularly in the area of new
technologies and the financial market;
▪ raising awareness and knowledge of economic, financial and new technology-
related issues, as well as increasing trust and respect for financial institutions;
▪ scientific and research activities and promotion of solutions developed
within the XTB capital group's operations, particularly in the field of new technologies
and the financial market;
▪ supporting and organizing all initiatives related to the promotion of financial
institutions and new technologies;
▪ financial support, transfer of knowledge or business consulting for the benefit of
selected entrepreneurs;
▪ acting in the fields of corporate social responsibility, sustainable development, and
animal and nature conservation;
▪ promotion of employment and education and equalization of development
opportunities;
▪ initiating and supporting activities of XTB Capital Group employees related to the
statutory objectives of the Foundation, employee volunteerism and all social,
educational and sports activities;
▪ charitable and social activities.
In 2024, the Foundation led and was involved in the following projects:
1. Academy of Tomorrow. Finances with class
An educational program for secondary school students, implemented in cooperation with
the Trampki na Giełdzie Foundation. The first edition was carried out from October 2024
to the end of February 2025. The program concerns personal finance, introduces
concepts related to the capital market and financial instruments, discusses the underlying
markets. It consists of 3 modules: 2 hours of workshop classes in schools, classes
conducted by capital market practitioners, the second module is a question and answer
session with XTB experts, during which students can directly inquire about aspects of the
stock market and investment that interest them. The third module is a visit to the WSE
building combined with workshops and the announcement of the winners of the
competition and the awarding of prizes.
2. Cooperation with the Polish Economic Society
A three-year cooperation agreement under which the Polish Economic Society conducts
workshops on management for teachers of the Business and Management subject and
camps for secondary school students. XTB also makes its representatives and experts
available as part of these workshops. In addition, as part of this agreement, XTB became
the official sponsor of the Polish national team for the International Economic Olympiad
(the organizer of the Polish Olympiad is the Polish Economic Society). In 2024, the
national team achieved the historic result of two gold and three silver medals.
3. Earth Day
Cleaning up the Kabacki Forest organized as part of volunteering together with the
Company's employees and in consultation with the Municipal Forests.
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Management Report of XTB Group and XTB S.A. in 2024
/ Strategy and operations
4. School starter kits for orphanages
The Foundation, together with XTB employees, organized assistance in the preparation
of school supplies for children from two orphanages in Warsaw. The necessary items
were collected in accordance with the list provided by the person managing the facilities
in Warsaw.
5. Real-time projects
The Foundation also tries to respond to current situations. In this regard, in 2024, XTB
joined the collection organized by the city of Warsaw for the flood victims. According to
the organizers' guidelines, the items needed at that time for the flood victims were
purchased and handed over to the place of the main collection, from where they were
taken to the flood areas.
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Management Report of XTB Group and XTB S.A. in 2024
/ Strategy and operations
Stakeholder relations
The activities of the XTB Group are closely related to its stakeholders who are affected by
these activities. The Stakeholders also influence the Group's activities. XTB has identified
several key categories of its stakeholders:
▪ Individual and institutional clients;
▪ Regulatory environment (supervisory authorities, i.e. PFSA, local supervisors
in the relevant markets);
▪ Employees and collaborators;
▪ Social environment (e.g. people interested in financial education);
▪ Market environment (partners, suppliers, market environment);
▪ Capital market representatives (shareholders, investors, analysts);
▪ Media representatives
Each of these groups has a different nature and expectations, which makes it necessary to
choose the right form of communication and its channels. However, the common
denominator for building relationships with stakeholders remains professionalism, mutual
respect, and noticing the expectations of each group.
The company strives to maintain an individual approach to each group of stakeholders,
treating the feedback received from them as a guide to verifying actions for sustainable and
transparent relations.
In the case of clients, based on their expressed expectations and general market trends,
XTB is building its offer of products and services, as well as improving the functions available
within the trading platform and mobile application.
In dialogue with financial market regulators, XTB strives to maintain its business objectives
with strict regard to the applicable law in the field of trading in financial instruments and
financial advice.
For employees and collaborators, XTB strives to create a supportive, diverse and
knowledge-based work environment. In connection with operating in international markets,
the Group tries to take into account cultural differences, take care of proper internal
communication. In addition, XTB also cares about the sphere of well-being by offering many
activities and training related to shaping positive attitudes and habits.
As a company listed on the Warsaw Stock Exchange, XTB also develops a dialogue with
representatives of the capital market, including shareholders and market analysts. The
Company communicates with them in a transparent and reliable manner, providing the
necessary information and ensuring its quality and comprehensibility. An important aspect
of communication with this group of stakeholders is to ensure equal access to information.
XTB also tries to respond to the demand raised by journalists of industry and economic
media, providing comments and interviews, and answering current questions. The presence
of the Company's representatives in the media supports the building of the Group's image
in Poland and in the world.
In the social and market environment, the activity of the XTB Group consists, e.g. tasks
related to financial education, external exposure during various market events (industry
conferences, job fairs) and sponsorship and charity projects.
More information on the area of stakeholders and relationship building can be found
in the Sustainability Statement of the XTB S.A. Capital Group, which is part of this Report.
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Financial results
and dividend
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
75
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Description of the consolidated financial result achieved in 2024 and the factors
affecting it
Operating profit in 2024 amounted to PLN 986.7 million and was higher by 6.8% compared to the result in 2023.
The amount of operating profit was influenced in particular by:
▪ higher result of operations on financial instruments by PLN 226.1 million, which
was influenced by the consistently increased number of active clients (increase
by 61.2% y/y), combined with their high trading activity expressed, among others,
transaction volume in CFDs in nominal value (increase by 14.9% y/y) and increase
in profitability for 1 million USD transaction volume in CFD instruments in nominal
value up to USD 179 USD (2023: USD 169);
▪ higher net interest income on clients cash by PLN 28.9 million, connected mainly
to an increase in the balance of cash and other cash assets of clients by 65.1% at
the end of the year and a decrease in the interest rate in 2024 compared to 2023;
302 746
302 814
160 300
118 183
203 826
121 127
192 560
249 049
Net profit on a quarterly basis
Q1 Q2 Q3 Q4
2024
2023
In 2024, consolidated net profit amounted to PLN 859.4 million compared to PLN 791.2 million a year earlier (increase by 8.6% y/y).
Consolidated operating income reached PLN 1,873.4 million (2023: PLN 1,618.4 million) with operating expenses equal PLN 883.5 million
(2023: PLN 694.2 million).
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
▪ increase in operating expenses by PLN 192.5 million, i.e. by 27.7% y/y (including
mainly marketing costs, increase by 38.0% y/y, costs of remuneration and
employee benefits, change by 37.3% y/y, other external services, increase by 9.2%
y/y and commission costs, change by 8.9% y/y).
The table below presents selected items from the consolidated statement of comprehensive income in the given periods.
(in thousands 000)
12 MONTHS PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Result of operations on financial instruments
1 800 575
1 574 491
14.4
Net interest income on clients cash
58 946
30 079
96.0
Income from fees and charges
12 291
11 730
4.8
Other income
1 624
2 085
(22.1)
Total operating income
1 873 436
1 618 385
15.8
Marketing
(344 808)
(263 924)
30.6
Salaries and employee benefits
(311 574)
(259 140)
20.2
Other external services
(79 226)
(64 141)
23.5
Commission expenses
(97 289)
(61 816)
57.4
Amortization and depreciation
(19 905)
(17 197)
15.7
Taxes and fees
(13 109)
(9 712)
35.0
Other expenses
(12 791)
(10 773)
18.7
Costs of maintenance and lease of buildings
(7 999)
(7 528)
6.3
Total operating expenses
(886 701)
(694 231)
27.7
Operating profit (EBIT)
986 735
924 154
6.8
Finance income
62 845
71 988
(12.7)
Finance costs
(1 129)
(35 898)
(96.9)
Profit before tax
1 048 451
960 244
9.2
Income tax
(191 595)
(169 071)
13.3
Net profit
856 856
791 173
8.3
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Consolidated operating profit
In 2024, XTB achieved a record operating income of PLN 1,873.4 million (increase by 15.8% y/y). Important factors determining the revenue were: consistently increased number of active clients
(increase by 61.2% y/y), combined with their high trading activity expressed e.g. transaction volume in CFDs in nominal value (increase by 14.9% y/y) and increase in profitability for 1 million USD
transaction volume in CFD instruments in nominal value up to USD 179 USD (2023: USD 169).
2024 2023
STRUCTURE OF OPERATING INCOME (IN PLN MLN)
Result of operations on financial instruments Net interest income on clients cash Income from fees and charges Other income
1 800,6
1 574.5
58.9
12.3
1.6
30.1
2.1
11.7
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
12-MONTH PERIOD ENDED
31.12.2024
31.12.2023
31.12.2022
31.12.2021
31.12.2020
31.12.2019
31.12.2018
Total operating income
(in thousands PLN)
1 873 436
1 618 385
1 451 954
625 595
797 750
239 304
288 301
Transaction volume in CFDs in lots
1
6 274 177
6 779 816
6 592 928
4 045 882
3 113 375
1 638 595
2 126 422
Profitability per lot (in PLN)
2
299
239
220
155
256
146
136
Transaction volume in CFDs in nominal value
(in USD mln)
2 626 577
2 285 891
2 259 588
1 737 351
1 021 835
541 510
773 899
Profitability for 1 million USD transaction volume
in CFDs in nominal value (in USD)
3
179
169
144
93
200
115
103
1
) Lot is a unit of trading in financial instruments. The amount of the lot varies between specific financial instruments. In the case of transactions in CFD instruments based on currencies, including cryptocurrencies, a lot corresponds to 100,000 units of the base currency.
In other cases, the lot value is specified in the instrument specification table, which is available here. Presented value does not include CFD turnover on shares and ETPs, where 1 lot equals 1 share. In connection with the unification of the definition of a lot for CFD
instruments based on cryptocurrencies with the definition used for CFD instruments based on currencies, where the value of 1 lot is 100,000 units of the base currency, the data were adjusted accordingly in comparative periods.
2
) Total operating income divided by the transaction volume in CFDs in lots.
3
) Total operating income converted into USD by the arithmetic average of exchange rates published by the National Bank of Poland on the last day of each month of the reporting period, divided by turnover of CFDs in nominal value (in USD’000000).
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
When considering the structure of revenues achieved in terms of the classes of instruments, it can be seen that in 2024, CFDs (contracts for difference) based on commodity were
in the lead. Their share in revenues in the analyzed period was 48.0% (2023: 39.9%). This is a consequence of, among others, high profitability on CFD instruments based on
quotations of gold, natural gas and cocoa prices.
The second most profitable asset class was index-based CFDs. Their share in the revenue structure reached 33.3% compared to 47.8% a year earlier. It was related to the high
profitability of trading in CFD instruments based on the US 100 index, the German DAX index (DE40) or the US 500 index. Revenues on CFD instruments based on currencies
accounted for 14.6% of all revenues, compared to 10.1% a year earlier. The most profitable financial instruments in this class were CFDs based on the bitcoin cryptocurrency and
the USDJPY currency pair.
2 126
1 639
3 113
4 046
6 593
6 780
6 274
100
300
500
700
900
1 100
1 300
1 500
1 700
1 900
1 000
2 000
3 000
4 000
5 000
6 000
7 000
2018 2019 2020 2021 2022 2023 2024
(in mln PLN)
(in thousands)
Operating income vs. CFD turnover in lots
Operating income CFD turnover (in thousands)
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
THE STRUCTURE OF REVENUE BY ASSETS CLASS (IN %)
(in thousands PLN)
12-MONTH PERIOD ENDED
Change %
31.12.2024
31.12.2023
Commodity CFDs
896 672
650 847
37.8
Index CFDs
622 728
781 285
(20.3)
Currency CFDs
272 276
165 161
64.9
Stock CFDs and ETPs
44 762
24 261
84.5
Bond CFDs
735
1 079
(31.9)
Total CFDs
1 837 173
1 622 633
13.2
Shares and ETPs
30 654
11 050
177.4
Gross gain on transactions in financial
instruments
1 867 827
1 633 683
14.3
Bonuses and discounts paid to clients
(12 629)
(9 428)
34.0
Commission paid to cooperating brokers
(54 623)
(49 764)
9.8
Net gain on transactions in financial instruments
1 800 575
1 574 491
14.4
33,3%
14,6%
48,0%
4,1%
2024
CFD na indeksy
CFD na waluty
CFD na towary
Pozostałe
47,8%
10,1%
39.9%
2,2%
2023
48.0%
Share in the structure of revenues on
CFDs based on commodities
299 PLN
Profitability per lot
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below presents percentage share of income categories in gross gain on transactions in financial instruments.
CATEGORY
2024
2023
2022
2021
2020
2019
2018
Spread
53%
46%
54%
83%
54%
62%
64%
Swap, commission and fees
42%
41%
26%
40%
16%
15%
12%
Market making
5%
13%
20%
(23%)
30%
23%
24%
Gross gain on transactions in financial
instruments
100%
100%
100%
100%
100%
100%
100%
53%
42%
5%
Share of revenue categories in
the gross result of operations on
financial instruments in 2024
Spread
Swap, commission and fees
Market making
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The Group shares its revenues by geographic area according to the country of the XTB office in which the client was acquired. The exception is the Middle East region, which also presents clients
from this market who were acquired by the subsidiary XTB International Ltd. with registered office in Belize.
(in thousands PLN)
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Central and Eastern Europe
1 196 513
983 343
21.7
- of which: Poland
956 542
756 104
26.5
Western Europe
355 868
369 588
(3.7)
Latin America
1
117 930
147 695
(20.2)
Middle East
2
203 117
117 759
72.5
Asia
8
-
100.0
Total operating income
1 873 436
1 618 385
15.8
1
) The subsidiary XTB International Ltd., with its registered office in Belize, acquires clients from Latin America and the rest of the world (without Europe). The item excludes revenues from clients acquired by this company from the Middle East region.
2
) Revenue from clients from the Middle East, acquired by XTB International Ltd. with registered office in Belize and XTB MENA Limited with registered office in the United Arab Emirates.
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Segmental revenue diversification is also important for XTB. To this end, the Group develops, apart from the retail segment, institutional activities under the X Open Hub (XOH) brand, as part of
which it provides liquidity and technology to other financial institutions. Revenues from this segment can be subject to significant fluctuations from period to period, similarly to the retail segment,
which is a phenomenon typical of the business model adopted by the Group.
Net interest income on clients cash
The profit due to interest in 2024 amounted to PLN 58.9 million, which
constituted 3.1% of the Group's revenue source (in 2023: 1.9%) and was
higher by PLN 28.9 million y/y. In 2024, compared to 2023, interest income
on client cash was higher by PLN 71.5 million, i.e. by 209.9%, with
a simultaneous increase in interest costs paid to clients by PLN 42.6 million, i.e. by
1 070.8%. A product consisting of generation of interest on free funds on clients' accounts
was added to the service offer in November 2023.
Result of financial activities
The result of financial activities in 2024 amounted to PLN 61.7 million and increased by PLN
25.6 million, i.e. 71.0% y/y as compared to the previous year.
The following indicators had the greatest impact on the level of the above-mentioned result:
• interest income on own funds and bonds held in total in the amount of PLN 52.4
million and decreased by PLN 19.4 million y/y, which was mainly due to lower
interest rates on deposits and lower bond yields;
• positive exchange rate differences in the amount of PLN 10.3 million (increase by
PLN 44.5 million y/y), mainly due to the strengthening of PLN against EUR.
(in thousands PLN)
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Retail business
1 791 144
1 510 016
3.9
Institutional business (X Open Hub)
82 292
108 369
456.3
Total operating income
1 873 436
1 618 385
10.0
PLN 1 791.1 mln
Revenue from retail business
PLN 82.3 mln
Revenue from institutional business
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Consolidated operating expenses
Operating expenses in 2024 equalled PLN 886.7 million and were PLN 192.5 million higher
than in the previous year (2023: PLN 694.2 million). The most important changes occurred
in:
▪ marketing costs, an increase of PLN 80.9 million resulting mainly from higher
expenditures on online and offline marketing campaigns;
▪ costs of remuneration and employee benefits, increase by PLN 52.4 million, mainly
due to the increase in employment caused by rapid growth of the Group;
▪ commission costs, an increase of PLN 35.5 million resulting from larger amounts
paid to payment services providers, through which clients deposit their funds in
trading accounts;
▪ other external services, increase by PLN 15.1 million as a result of incurring mainly
higher expenditures on IT systems and licenses (increase by PLN 12.9 million y/y).
(in thousands PLN)
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Marketing
344 808
263 924
30.6
Salaries and employee benefits
311 574
259 140
20.2
Commission expenses
97 289
61 816
57.4
Other external services
79 226
64 141
23.5
Amortisation and depreciation
19 905
17 197
15.7
Other expenses
12 791
10 773
18.7
Taxes and fees
13 109
9 712
35.0
Costs of maintenance and lease of buildings
7 999
7 528
6.3
Total operating expenses
886 701
694 231
27.7
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Due to the dynamic development of XTB, the Management Board estimates that in 2025,
the total costs of operating activities may be up to about 40% higher than what was observed
in 2024. The priority of the Management Board is to further increase the client base and
build a global brand. As a consequence of the implemented activities, marketing outlays
may increase by about 80% in relation to the previous year, while assuming that the average
cost of acquiring a client should be comparable to that observed in the years 2023 - 2024.
The final level of operating costs will depend in particular on: the rate of employment growth
and the amount of variable remuneration components paid to employees, the level of
marketing expenditure, the rate of geographical expansion into new markets and the impact
of possible new regulations and other external factors on the level of revenues generated
by the Group.
The level of marketing expenditure will depend on the assessment of their impact on the results and profitability of
the Group, the pace of international expansion and the degree of responsiveness of clients to the activities
undertaken. Its dynamic development, both in new and existing markets, will contribute to the growth of employment
in the Group. In turn, the Group's results will affect the amount of variable remuneration components.
An example billboard from an advertising campaign in Poland. The slogan is:
„I start my day with good coffee, and investing with IKE.”
86
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Structure of assets and liabilities of the balance sheet
On December 31, 2024, the total assets of the XTB Group amounted to PLN 6 645.6 million and were PLN 1 957.0 million higher compared
to the end of 2023, i.e. by 41.7%.
ASSETS
(in thousands PLN)
31.12.2024
31.12.2023
Change y/y
k PLN
%
ASSETS
Own cash
1 627 867
1 409 897
217 970
15.5
Clients' cash
3 742 948
2 266 859
1 476 089
65.1
Financial assets at fair value through P&L
1 123 923
903 255
220 668
24.4
Financial assets at amortized cost
55 026
31 407
23 619
75.2
Prepayments and deferred costs
19 686
15 486
4 200
27.1
Intangible assets
2 009
1 167
842
72.2
Property, plant and equipment
65 334
50 386
14 948
29.7
Income tax receivables
131
129
2
1.6
Deferred income tax assets
8 708
10 072
(1 364)
(13.5)
Total assets
6 645 632
4 688 658
1 957 974
41.7
The most important asset item, both at the end of 2023 and 2024, were funds plus bonds
(presented in financial assets at fair value through financial result), which accounted for
87.2% and 86.9% of assets, respectively, in 2024 and 2023. Funds include the Group's own
funds and the clients' funds. Clients' funds are deposited in bank accounts separately from
the Group's funds. XTB invests part of its funds cash in bank deposits and financial
instruments, i.e. treasury bonds, bonds guaranteed by the State Treasury, and corporate
bonds guaranteed by banks. As at 31 December 2024, the total value of bonds in the Group
amounted to PLN 424.7 million (as at 31 December 2023: PLN 395.8 million). At the end of
2024, own funds plus bonds increased by 13.7% y/y, with a simultaneous increase in clients'
funds by 65.1% y/y.
87
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The most significant increase in value, i.e. by PLN 1 476.1 million in assets, took place in
clients' funds.
10.4% of assets (compared to 10.4% at the end of 2023) were financial assets valued
at fair value through financial result, less the value of bonds. They amounted to PLN 694.3
million and were PLN 192.3 million higher than at the end of 2023. The increase was mainly
due to the higher value of shares and ETPs held by XTB.
88
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
LIABILITIES
31.12.2024
31.12.2023
Change y/y
k PLN
%
EQUITY AND LIABILITIES
Liabilities
Amounts due to clients
4 164 895
2 638 122
1 526 773
57.9
Financial liabilities at fair value through P&L
208 193
110 358
97 835
88.7
Liabilities due to lease
33 935
29 603
4 332
14.6
Other liabilities
156 884
86 080
70 804
82.3
Provisions for liabilities
3 530
3 892
(362)
(9.3)
Income tax liabilities
13 316
22 991
(9 675)
(42.1)
Deferred income tax provision
61 238
62 949
(1 711)
(2.7)
Total liabilities
4 641 991
2 953 995
1 687 996
57.1
Equity
Share capital
5 878
5 878
-
-
Supplementary capital
71 608
71 608
-
-
Other reserves
1 059 614
863 166
196 448
22.8
Foreign exchange differences on transaction
(4 074)
(6 595)
2 521
(38.2)
Retained earnings
870 495
800 606
69 889
8.7
Equity capital attributable to the owners of the Parent Company
2 003 521
1 734 663
268 858
15.5
Non-controlling interests
120
-
120
100.0
Total equity
2 003 641
1 734 663
268 978
15.5
Total equity and liabilities
6 645 632
4 688 658
1 957 013
41.7
89
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
With regard to the structure of liabilities, the most significant item as at 31 December 2024
were amounts due to clients (62.7% of liabilities in 2024 and 56.3% in 2023, respectively).
Amounts due to clients result from transactions concluded by clients (including cash
deposited in clients' accounts).
The Group's equity as at the end of December 2024 amounted to PLN 2 003.5 million
and increased compared to 31 December 2023 by 15.5%, i.e. by PLN 269.0 million. The
share of total equity capital in the total liabilities and equity capital of the Group amounted to
30.1% at the end of December 2024 (compared to 37.0% at the end of 2023).
The rate of return on assets, calculated as the ratio of the Group's net profit and the balance
sheet total, as at 31 December 2024 was 12.9%, and as at 31 December 2023 was 16.9%.
Selected financial and operational ratios of the XTB Group
The financial ratios presented in the following table are not a measure of the financial result in accordance with the IFRS nor should they be treated as a measure of the financial result or cash
flow from operating activities or considered an alternative to a profit. These indicators are not uniformly defined and may not be comparable to ratios presented by other companies, including
companies operating in the same sector as the Group.
12-MONTH PERIOD ENDED
CHANGE
31.12.2024
31.12.2023
EBITDA (in thousands PLN)
1
1 006 640
941 351
6.9%
EBITDA margin (%)
2
53.7
58.3
(4.4) p.p.
Net profit margin (%)
3
45.7
48.9
(3.1) p.p.
Return on equity –ROE (%)
4
45.8
48.8
(3.0) p.p.
Return on assets – ROA (%)
5
15.1
18.0
(2.9) p.p.
Aggregate capital adequacy ratio (IFR) (%)
192.3
188.7
3.6 p.p.
1
) EBITDA calculated as operating profit, including amortization and depreciation.
2
) Calculated as the quotient of operating profit, including amortization and depreciation, and operating income.
3
) Calculated as the quotient of net profit and operating income.
4
) Calculated as the quotient of net financial result and average balance of equity capital (calculated as the
arithmetic mean of the total equity capital as at the end of the prior period and as at the end of the current
reporting period).
5
) Calculated as the quotient of net financial result and average balance of total assets (calculated as the arithmetic
mean of the total assets as at the end of the prior period and as at the end of the current reporting period).
53.7%
EBITDA margin
15.1%
Return on assets – ROA
90
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below presents:
▪ the number of new clients in individual periods;
▪ the aggregate number of clients;
▪ the number of clients who have made at least one transaction and/or had at least
one open position during the individual periods;
▪ the average quarterly number of clients who have made at least one transaction
and/or had at least one open position during the individual periods;
▪ the amount of net deposits in the individual periods;
▪ average operating income per one active client;
▪ the transaction volume in lots;
▪ profitability per lot;
▪ transaction volume of CFD derivatives at nominal value (in USD million);
▪ profitability for 1 million USD transaction volume in CFD derivatives in nominal
value (in USD) and;
▪ the volume of share transactions at nominal value (in USD million).
▪ The information presented in the table below is related to the aggregate operations
in the retail and institutional operations segments.
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
New clients
1
498 438
311 971
59.8
Clients in total
1 361 564
897 573
51.7
Number of active clients
2
658 520
408 528
61.2
Average number of active clients
3
458 393
277 684
65.1
Net deposits (in thousands PLN)
4
8 607 311
3 793 729
126.9
Average operating income per active client (in thousands PLN)
5
4.1
5.8
(29.3)
Transaction volume in CFDs in lots
6
6 274 177
6 779 816
(7.5)
Profitability per lot (in PLN)
7
299
239
25.1
Transaction volume in CFDs in nominal value (in USD million)
2 626 577
2 285 891
14.9
Profitability for 1 million USD transaction volume in CFDs in nominal value (in USD)
8
179
169
5.9
Turnover of shares in nominal value (in USD million)
9 574
4 513
112.1
1
) The number of new Group’s clients in the individual periods.
2
) The number of clients who have made at least one transaction and/or had at least one open position during the individual periods.
3
) The average quarterly number of clients who have made at least one transaction and/or had at least one open position during the individual periods.
4
) Net deposits comprise deposits placed by clients less amounts withdrawn by the clients in a given period.
5
) The Group’s operating income in a given period divided by the average quarterly number of clients who at least one transaction has been concluded over the last three months.
6
) A lot is a unit of trading in financial instruments; in the case of foreign currency transactions, a lot corresponds to 100,000 units of the base currency; in the case of instruments other than CFDs based on currencies, the amount is specified in the instruments table
and varies for various instruments. Presented value does not include CFD turnover on shares and ETFs, where 1 lot equals 1 share.
7
) Total operating income divided by the transaction volume in CFDs in lots.
8
) Total operating income converted into USD by the arithmetic average of exchange rates published by the National Bank of Poland on the last day of each month of the reporting period, divided by turnover of CFDs in nominal value (in USD million).
91
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below shows data on the Group’s transaction volumes (in lots) by geographical area for the periods indicated.
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Retail operations segment
5 568 398
5 525 229
0.8
Central and Eastern Europe
2 395 088
2 409 275
(0.6)
Western Europe
1 094 773
1 172 637
(6.6)
Latin America
1
1 008 238
1 189 208
(15.2)
Middle East
2
1 070 299
754 108
41.9
Institutional operations segment
705 779
1 254 587
(43.7)
Total
6 274 177
6 779 816
(7.5)
1)
The subsidiary XTB International Ltd., with its seat in Belize, acquires clients from Latin America and the rest of the world (without Europe). The item excludes lots from clients acquired by this company from the Middle East region.
2)
Lots from clients from the Middle East, acquired by XTB International Ltd. with its registered office in Belize and XTB MENA Limited with its registered office in the United Arab Emirates.
Group turnover in lots by segments
81,5%
18,5%
2023
88,8%
11,2%
2024
Retail operations
segment
Institutional operations
segment
92
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below shows data on the Group’s transaction volumes (in nominal value) by geographical area for the periods indicated.
(in USD mln)
12 MONT PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Retail operations segment
2 542 078
2 173 885
16.9
Central and Eastern Europe
1 064 018
953 444
11.6
Western Europe
506 814
474 143
6.9
Latin Amerrica
1
466 770
467 654
(0.2)
Middle East
2
504 476
278 644
81.0
Institutional operations segment
84 499
112 006
(24.6)
Total
2 626 577
2 285 891
14.9
1
)
The subsidiary XTB International Ltd., with registered office in Belize, acquires clients from Latin America and the rest of the world (without Europe). The item excludes nominal value from clients acquired by this company from the Middle East region.
2
)
Nominal value from clients from the Middle East, acquired by XTB International Ltd. with registered office in Belize and XTB MENA Limited with registered office in the United Arab Emirate.
Group turnover in nominal value by segments
95,1%
4,9%
2023
96,8%
3,2%
2024
Retail operations
segment
Institutional operations
segment
93
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below shows data on the Group’s revenue by geographical area for the periods indicated. The Group shares its revenues by geographic area according to the country of the XTB office
in which the client was acquired. The exception is the Middle East region, which also presents clients from this market who were acquired by the subsidiary XTB International Ltd. with registered
office in Belize.
(in thousands PLN)
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Result from operations on financial instrument:
1 800 575
1 574 491
14.4
Central and Eastern Europe
1 140 563
944 581
20.7
Western Europe
340 378
365 618
(6.9)
Latin America
1
116 518
146 534
(20.5)
Middle East
2
203 116
117 758
72.5
Result of interest on client funds
58 946
30 079
96.0
Central and Eastern Europe
45 166
27 228
65.9
Western Europe
13 766
2 851
382.8
Latin America
1
14
-
100.0
Income from commission and fees:
12 291
11 730
4.8
Central and Eastern Europe
9 160
9 449
(3.1)
Western Europe
1 724
1 118
54.2
Latin America
1
1 398
1 162
20.3
Middle East
2
1
1
-
Asia
8
-
100.0
Other income:
1 624
2 085
(22.1)
Central and Eastern Europe
1 624
2 085
(22.1)
Total operating income
1 873 436
1 618 385
15.8
Central and Eastern Europe
1 196 513
983 343
21.7
- of which Poland
3
956 542
756 104
26.5
Western Europe
355 868
369 588
(3.7)
Latin America
1
117 930
147 695
(20.2)
Middle East
2
203 117
117 759
72.5
Asia
8
-
100.0
1
) The subsidiary XTB International Ltd., with its registered office in Belize, acquires clients from Latin America and the rest of the world (without Europe). The item excludes revenues from clients acquired by this company from the Middle East region.
2
) Revenue from clients from the Middle East, acquired by XTB International Ltd. with registered office in Belize and XTB MENA Limited with registered office in the United Arab Emirates.
3
) The country from which the Group derives more than 20% of its revenue each time is Poland with a share of 51.1% (2023: 46.7%). Due to the overall share in the Group's revenues, Poland was presented as the largest market in the Group in terms of revenue.
94
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Group revenues by geographical area
60,8%
22,8%
9,1%
7,3%
2023
63,9%
19,0%
6,3%
10,8%
2024
Central and Eastern
Europe
Western Europe
Latin America
Middle East
95
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Retail operations segment
The table below presents key operational data in the retail operations segment of the Group for the respective periods indicated.
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
New clients
1
498 435
311 966
59.8
Clients in total
1 361 533
897 540
51.7
Number of active clients
2
658 496
408 501
61.2
Average number of active clients
3
458 376
277 664
65.1
Number of transactions
4
167 669 072
142 056 400
18.0
Transaction volume in CFDs in lots
5
5 568 398
5 525 229
0.8
Net deposits (in thousands PLN)
6
8 563 290
3 670 943
133.3
Average operating income per active client (in thousands PLN)
7
3.9
5.4
(28.1)
Average client acquisition cost (in thousands PLN)
8
0.7
0.8
(18.1)
Profitability per lot (in PLN)
9
322
273
17.7
Transaction volume in CFDs in nominal value (in USD mln)
2 542 079
2 173 885
16.9
Profitability for 1 million USD transaction volume in CFDs in nominal value (in USD)
10
177
166
6.5
Turnover of shares in nominal value (in USD million)
9 574
4 513
112.2
1
) The number of new Group’s clients in the individual periods.
2
) The number of clients who have made at least one transaction and/or had at least one open position during the individual periods.
3
) The average quarterly number of clients who have made at least one transaction and/or had at least one open position during the individual periods.
4
) Total number of open and closed transactions in a given period.
5
) A lot is a unit of trading in financial instruments; in the case of foreign currency transactions, a lot corresponds to 100,000 units of the base currency; in the case of instruments other than CFDs based on currencies, the amount is specified in the instruments table
and varies for various instruments. Presented value does not include CFD turnover on shares and ETFs, where 1 lot equals 1 share.
6
) Net deposits comprise deposits placed by clients less amounts withdrawn by the clients in a given period.
7
) The average revenue per one client is defined as the total operating income in the segment in a given period divided by the average quarterly number of clients who have concluded at least one transaction in the last three months.
8
) Average cost of obtaining a client comprise total marketing costs of the Group divided by the number of new clients in given period.
9
) Total operating income in retail segment divided by the transaction volume in CFDs in lots.
10
) Total operating income converted into USD by the arithmetic average of exchange rates published by the National Bank of Poland on the last day of each month of the reporting period, divided by turnover of CFDs in nominal value (in USD mln).
96
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The following table presents data by geography on the number of the Group's active retail clients who conducted at least one transaction and/or held an open position in the period. The locations
of active clients have been determined based on the location of the Group’s office (that maintains the client). The exception is the Middle East region, which also presents revenues from clients
from this market acquired by the subsidiary XTB International Ltd. with registered office in Belize.
12-MONTH PERIOD ENDED
31.12.2024
31.12.2023
Central and Eastern Europe
397 590
60%
244 530
60%
Western Europe
174 493
27%
92 330
23%
Latin America
1
59 463
9%
53 589
13%
Middle East
2
26 950
4%
18 052
4%
Total
658 496
100%
408 501
100%
1
) The subsidiary XTB International Ltd., with its registered office in Belize, acquires clients from Latin America and the rest of the world (without Europe). The item excludes clients acquired by this company from the Middle East region.
2
) Clients from the Middle East, acquired by XTB International Ltd. with its seat in Belize and XTB MENA Limited with its seat in the United Arab Emirates.
97
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Institutional operations segment
The Group also provides services to institutional clients under the X Open Hub (XOH) brand, under which it provides liquidity and technology to other financial institutions as part
of the institutional business segment.
The table below presents information regarding the number of clients in the Group’s institutional operations segment in the periods indicated.
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
New clients
1
3
5
(40.0)
Number of active clients
2
24
27
(11.1)
Clients in total
31
33
(6.1)
Transactions in CFDs in lots
3
705 779
1 254 587
(43.7)
Net deposits (in thousands PLN)
4
44 021
122 786
(64.1)
Transaction volume in CFDs in nominal value (in USD million)
84 498
112 006
(24.6)
Profitability for 1 million USD transaction volume in CFDs in nominal value (in USD)
5
244
231
5.6
1
) The number of new Group’s clients in the individual periods.
2
) The number of clients who have made at least one transaction and/or had at least one open position during the period.
3
) Lot is a unit of trading in financial instruments. The amount of the lot varies between specific financial instruments. In the case of transactions in CFD instruments based on currencies, including cryptocurrencies, a lot corresponds to 100,000 units of the base currency.
In other cases, the lot value is specified in the instrument specification table, which is available here. Presented value does not include CFD turnover on shares and ETPs, where 1 lot equals 1 share. In connection with the unification of the definition of a lot for CFD
instruments based on cryptocurrencies with the definition used for CFD instruments based on currencies, where the value of 1 lot is 100,000 units of the base currency, the data were adjusted accordingly in comparative periods.
4
) Net deposits comprise deposits placed by clients less amounts withdrawn by the clients in a given period.
5
) Total operating income converted into USD by the arithmetic average of exchange rates published by the National Bank of Poland on the last day of each month of the reporting period, divided by turnover of CFD derivatives in nominal value (in USD mln).
98
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Discussion of the separate financial result achieved in 2024 and the factors
affecting it
The amount of operating profit was influenced in particular by:
▪ higher result from operations on financial instruments by PLN 196.0 million, which
was influenced by the consistently increased number of active clients, combined
with their high trading activity expressed, among others, in the number of
concluded CFDs in lots and an increase in lot profitability;
▪ higher profit due to interest on clients' funds by PLN 28.6 million, mainly due to an
increase in the balance of funds and other financial assets of clients by 66.9% at
the end of the year and a decrease in the interest rate in 2024 compared to 2023;
▪ increase in operating expenses by PLN 161.1 million, i.e. by 28.1% y/y (including
mainly marketing costs, increase by 27.6% y/y, costs of remuneration and
employee benefits, change by 25.1% y/y, commission costs, change by 74.4% y/y
and other external services, increase by 21.1% y/y).
In 2024, XTB S.A. generated a net profit of PLN 855.2 million, PLN 68.1 million higher than that achieved in 2023. Separate operating
income reached PLN 1 716.6 million (2023: PLN 1 492.0 million) with operating expenses equal PLN 733.4 million (2023: PLN 572.3
million).
99
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Separate statement of comprehensive income
The table below presents selected items from the separate statement of comprehensive income in the given periods.
(in thousands PLN)
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Result of operations on financial instruments
1 646 119
1 450 072
13.5
Net interest income on clients cash
58 250
29 652
96.4
Income from commission and fees
10 598
10 158
4.3
Other income
1 625
2 085
(22.1)
Total operating income
1 716 592
1 491 967
15.1
Marketing
(261 478)
(204 851)
27.6
Salaries and employee benefits
(256 163)
(204 843)
25.1
Other external services
(108 017)
(89 219)
21.1
Commission expenses
(65 756)
(37 708)
74.4
Amortisation and depreciation
(17 058)
(14 497)
17.7
Taxes and fees
(11 618)
(8 996)
29.1
Costs of maintenance and lease of buildings
(6 456)
(5 807)
11.2
Other expenses
(6 856)
(6 424)
6.7
Total operating expenses
(733 402)
(572 345)
28.1
Profit on operating activities
983 190
919 622
6.9
Impairment of investments in subsidiaries
-
(125)
(100.0)
Finance income
63 386
71 002
(10.7)
Finance costs
(988)
(34 683)
97.2
Profit before tax
1 045 588
955 816
9.4
Income tax
(190 386)
(168 680)
12.9
Net profit
855 202
787 136
8.6
100
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below shows information on the Company’s operating income for the periods indicated.
12-MONTH PERIOD ENDED
31.12.2024
31.12.2023
(in thousands PLN)
(%)
(in thousands PLN)
(%)
Result of operations on financial instruments
1 646 119
95.9
1 450 072
97.2
Result of interest on client funds
58 250
3.4
29 652
2.0
Income from commission and fees
10 598
0.6
10 158
0.7
Other income
1 625
0.1
2 085
0.1
Total operating income
1 716 592
100.0
1 491 967
100.0
Result of operations on financial instruments
The largest source of operating revenues of the Company is are operations on financial
instruments, which accounted for 95.9% and 97.2% of total revenues from operating
activities in 2024 and 2023, respectively. Three product classes have the largest share in
the result of gross transactions in financial instruments: index, commodity, and currency
CFD derivatives, which generated 47.7%, 33.2% and 14.5% respectively in 2024 (39.6%,
47.6% and 10.1% respectively in 2023).
Other products, such as equity and ETP-based CFDs, bond-based CFDs, and equities and
ETPs in the analyzed periods accounted for a total of 4.1% and 2.2% of gross return on
transactions in financial instruments in 2024 and 2023, respectively.
101
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below shows the result of operations on financial instruments in 2024 and 2023 and their change:
(in thousands PLN)
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Commodity CFDs
896 672
650 847
37.8
Index CFDs
622 728
781 285
(20.3)
Currency CFDs
272 276
165 161
64.9
Stock CFDs and ETPs
44 762
24 261
84.5
Bond CFDs
735
1 079
(31.9)
Total CFDs
1 837 173
1 622 633
13.2
Shares and ETPs
30 654
11 050
177.4
Dividends from subsidiaries
10 182
7 835
30.0
Gross gain on transactions in financial instruments
1 878 009
1 641 518
14.4
Bonuses and discounts paid to clients
(2 921)
(81)
3506.2
Financial intermediation services
(228 969)
(191 365)
19.7
Net gain on transactions in financial instruments
1 646 119
1 450 072
13.5
The share of instruments in the result on operations financial instruments
39,9%
47,8%
10,1%
2,2%
2023
48,0%
33,3%
14,6%
4,1%
2024
Commodity CFDs
Index CFDs
Currency CFDs
Other
102
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The Company's revenues come for the most part from retail operations and include the revenues from:
• spreads (the difference between the sale price – offer and the purchase price – bid);
• accrued swap points (representing the cost of holding a position over time);
• commissions and fees charged to clients;
• net result (profits less losses) from the Group's market making activities.
The table below presents the percentage share of each revenue category in the gross result of operations of financial instruments (except dividends from subsidiaries).
12-MONTH PERIOD ENDED
31.12.2024
31.12.2023
Spread
53%
46%
Swaps, commission and fees
42%
41%
Market Making
5%
13%
Gross gain on transactions in financial instruments
100%
100%
Net interest income on client cash
The profit due to interest in 2024 amounted to PLN 58.3 million, which
constituted 3.4% of the Group's revenue source (in 2023: 2.0%) and was
higher by PLN 28.6 million y/y. In 2024, compared to 2023, interest income
on client cash was higher by PLN 70.2 million, i.e. by 209.2%, with a simultaneous increase
in interest costs paid to clients by PLN 41.7 million, i.e. by 1 059.6%. An important factor
influencing the increase in the level of revenues and interest costs on clients' funds was the
introduction of another novelty to the XTB offer in November 2023, i.e. interest on free funds
on clients' accounts, which allowed for achieving additional revenues for both the client and
the Group.
Result of financial activities
The result of financial activities in 2024 amounted to PLN 62.4 million, which was
an increase by PLN 26.1 million, i.e. 71.8% y/y (in 2023: PLN 36.3 million).
The following indicators had the greatest impact on the level of the above-mentioned result:
• interest income on own funds and bonds held in total in the amount of PLN 51.1
million and decreased by PLN 19.9 million y/y, which was mainly due to lower
interest rates on deposits and lower bond yields;
• positive exchange rate differences in the amount of PLN 12.3 million (increase by
PLN 46.6 million y/y), mainly due to the strengthening of PLN against EUR.
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Separate operating costs
Operating expenses in 2024 equalled PLN 733.4 million and were PLN 161.1 million higher
than in the previous year (2023: PLN 572.3 million). The most important changes occurred
in:
▪ marketing costs, an increase of PLN 56.6 million resulting mainly from higher
expenditures on offline marketing campaigns (increase by 82.3% y/y) and online
(increase by 13.4% y/y);
▪ costs of remuneration and employee benefits, increase by PLN 51.3 million, mainly
due to the increase in employment;
▪ commission costs, an increase of PLN 28.1 million resulting from larger amounts
paid to payment services providers, through which clients deposit their funds in
trading accounts;
▪ other external services, increase by PLN 18.8 million as a result of incurring mainly
higher expenditures on IT systems and licenses (increase by PLN 12.8 million y/y)
and on financial intermediation services (increase by PLN 3.5 million).
Structure of separate assets and liabilities of the balance sheet
On December 31, 2024, the total assets of XTB S.A. amounted to PLN 6 411.6 million and were PLN 1 913 million higher compared to the
end of 2023.
ASSETS
(in thousands PLN)
31.12.2024
31.12.2023
Change y/y
k PLN
%
ASSETS
Own cash
1 429 613
1 271 437
158 176
12.4
Clients' cash
3 577 139
2 142 905
1 434 234
66.9
Financial assets at fair value through P&L
1 082 560
852 787
229 773
26.9
Investments in subsidiaries
65 125
49 429
15 696
31.8
Financial assets at amortized cost
177 547
110 347
67 200
60.9
Prepayments and deferred costs
18 621
14 454
4 167
28.8
Intangible assets
982
1 086
(104)
(9.6)
Tangible assets
53 057
47 563
5 494
11.6
Income tax receivables
115
129
(14)
(10.9)
Deferred income tax assets
6 849
8 030
(1 181)
(14.7)
Total assets
6 411 608
4 498 167
1 913 441
42.5
104
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The most important asset item, both at the end of 2023 and 2024, are funds plus bonds
(presented in financial assets at fair value through financial result), which accounted for
84.7% of assets in both 2023 and 2024. Funds include the Group's own funds and the
clients' funds. Clients' funds are deposited in bank accounts separately from the Group's
funds. XTB invests part of its funds cash in bank deposits and financial instruments, i.e.
treasury bonds, bonds guaranteed by the State Treasury, and corporate bonds guaranteed
by banks. As at 31 December 2024, the total value of bonds in the Group amounted to PLN
424.7 million (as at 31 December 2023: PLN 395.8 million). At the end of 2024, own funds
plus bonds increased by 11.2% y/y, with a simultaneous increase in clients' funds by 66.9%
y/y.
The most significant increase in value, i.e. by PLN 1 434.2 million in assets, took place in
clients' funds.
LIABILITIES
(in thousands PLN)
31.12.2024
31.12.2023
Change y/y
k PLN
%
EQUITY AND LIABILITIES
Liabilities
Amounts due to clients
3 992 058
2 500 414
1 491 644
59.7
Financial liabilities measured at fair value through P&L
171 806
68 017
103 789
152.6
Liabilities due to lease
22 826
27 201
(4 375)
(16.1)
Other liabilities
156 449
86 331
70 118
81.2
Provisions for liabilities
3 281
3 732
(451)
(12.1)
Income tax liabilities
12 776
22 641
(9 865)
(43.6)
Deferred income tax provision
59 864
61 901
(2 037)
(3.3)
Total liabilities
4 419 060
2 770 237
1 648 823
59.5
Equity
Share capital
5 878
5 878
-
-
Supplementary capital
71 608
71 608
-
-
Other reserves
1 059 476
863 028
196 448
22.8
Foreign exchange differences on transaction
384
280
104
37.1
Retained earnings
855 202
787 136
68 066
8.6
Total equity
1 992 548
1 727 930
264 618
15.3
Total equity and liabilities
6 411 608
4 498 167
1 913 441
42.5
105
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
With regard to the structure of liabilities, the most significant item as at 31 December 2024
were amounts due to clients (62.3% of liabilities in 2024 and 55.6% in 2023, respectively).
Amounts due to clients result from transactions concluded by clients (including cash
deposited in clients' accounts).
The Company's equity as at the end of December 2024 amounted to PLN 1 992.5 million
and increased compared to 31 December 2023 by 15.3%, i.e. by PLN 264.6 million. The
share of total equity capital in the total liabilities and equity capital of the Group amounted
to 31.1% at the end of December 2024 (compared to 38.4% at the end of 2023).
The rate of return on assets, calculated as the ratio of the Group's net profit and the balance
sheet total, as at 31 December 2024 was 13.3%, and as at 31 December 2023 was 17.5%.
Selected financial and operational ratios of XTB S.A.
The financial ratios presented in the following table are not a measure of the financial result in accordance with the IFRS nor should they be treated as a measure of the financial result or cash
flow from operating activities or considered an alternative to a profit. These indicators are not uniformly defined and may not be comparable to ratios presented by other companies, including
companies operating in the same sector as the Group.
12-MONTH PERIOD ENDED
CHANGE
31.12.2024
31.12.2023
EBITDA (in thousands PLN)
1
1 000 248
934 119
7.1%
EBITDA margin (%)
2
58.3
62.6
(4.3)
Net profit margin (%)
3
49.8
52.8
(2.9)
Return on equity –ROE (%)
4
46.0
48.8
(2.8)
Return on assets - ROA (%)
5
15.7
18.7
(3.0)
Aggregate capital adequacy (IFR) (%)
197.8
195.5
2.3
1
) EBITDA calculated as operating profit, including amortization and depreciation.
2
) Calculated as the quotient of operating profit, including amortization and depreciation, and operating income.
3
) Calculated as the quotient of net profit and operating income.
4
) Calculated as the quotient of net financial result and average balance of equity capital (calculated as the arithmetic mean of the total equity capital as at the end of the prior period and as at the end of the current reporting period).
5
) Calculated as the quotient of net financial result and average balance of total assets (calculated as the arithmetic mean of the total assets as at the end of the prior period and as at the end of the current reporting period).
Due to the fact that operating KPIs data concerning number of clients, number of active clients, deposits, volume turnover in lots and average operating income per active client are analysed by
the Company’s Management Board on the Group level, and not in the separate view, this data was presented only in the consolidated view. In the Company's opinion, this gives a complete viewof
the Group's situation. Therefore, in the Company‘s opinion analysis of the above mentioned KPIs on the consolidated level is reliable.
106
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
The table below shows data on the Company’s revenue by geographical area for the periods indicated.
(in thousands PLN)
12-MONTH PERIOD ENDED
CHANGE %
31.12.2024
31.12.2023
Result from operations on financial instrument:
1 646 119
1 450 072
13.5
Central and Eastern Europe
1 150 745
952 414
20.8
Western Europe
314 545
338 156
(7.0)
Latin America
1
7 917
67 602
(88.3)
Middle East
2
172 912
91 900
88.2
Result of interest on client funds:
58 250
29 652
96.4
Central and Eastern Europe
45 166
27 229
65.9
Western Europe
13 084
2 423
440.0
Income from commission and fees:
10 598
10 158
4.3
Central and Eastern Europe
9 311
9 432
(1.3)
Western Europe
1 287
726
77.4
Other income:
1 625
2 085
(22.1)
Central and Eastern Europe
1 625
2 085
(22.1)
Total operating income
1 716 592
1 491 967
15.1
Central and Eastern Europe
1 206 847
991 160
21.8
- of which Poland
3
969 951
769 371
26.1
Western Europe
328 916
341 305
(3.6)
Latin America
1
7 917
67 602
(88.3)
Middle East
2
172 912
91 900
88.2
1
) The subsidiary XTB International Ltd., with its registered office in Belize, acquires clients from Latin America and the rest of the world (without Europe). The item excludes revenues from clients acquired by this company from the Middle East region.
2
) Revenue from clients from the Middle East, acquired by XTB International Ltd. with registered office in Belize and XTB MENA Limited with registered office in the United Arab Emirates.
3
) The country from which the Company derives more than 20% of its revenue each time is Poland with a share of 56.5% (2023: 51.6%). Due to the overall share in the Group's revenues, Poland was presented as the largest market in the Group in terms of revenue.
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Material off-balance sheet items
The nominal value of transactions in financial instruments (off-balance sheet items) in the
consolidated financial statements at the end of 2024 was PLN 11 604.2 million and
increased year-on-year by PLN 1 090.3 million.
The nominal value of transactions in financial instruments (off-balance sheet items) in the
separate financial statements at the end of 2024 was PLN 11 511.1 million and increased
year-on-year by PLN 1 064.2 million.
The above-mentioned nominal value of the instruments consists of transactions with clients
and brokers.
Material contracts
In 2024, the Company and the Group companies did not enter into agreements material for
XTB operations, different than described in this report, also the Company has no knowledge
about contracts concluded between shareholders material for XTB operations.
Transactions with related companies
In the 12 months period ended 31 December 2024 and 31 December 2023 there were no
related parties’ transactions concluded on other than arm’s length basis.
Transactions and the balances of settlements with related parties were presented in detail
in note 30 to the Separate Financial Statements.
Credit and loans
In the reporting period, the Company and the Group Companies did not conclude or
terminate any agreements regarding credits or loans.
In 2024, the Company and the Group companies did not grant any loans.
Sureties and guarantees
On 7 July 2017, the Parent Company granted a surety of PLN 5 664 thousand to secure the
agreement concluded by the subsidiary XTB Limited with registered office in the United
Kingdom and Worldpay (UK) Limited, Worldpay Limited and Worldpay AP LTD with
registered office in the United Kingdom. The guarantee was granted for the duration of the
main contract, which was concluded for a period of 3 years with the possibility of further
extension.
Apart from described above, in 2024 XTB did not grant and did not receive other sureties
and guarantees.
Public support
The Company has not received financial support from public funds in 2024.
108
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Activities of the brokerage house outside the territory
of the Republic of Poland
XTB, as a brokerage house, has branches and subsidiaries, which are financial institutions
within the meaning of Article 4 paragraphs 1 point 26 of Regulation 575/2013 on prudential
requirements for credit institutions and investment firms and amending Regulation (EU) No
64/2012, outside the territory of the Republic of Poland. The table below presents additional
data on the above branches and subsidiaries (included on the basis of the aforementioned
Regulation) in 2024 and 2023.
Name
Areas of
activities
Revenue
for 2024
(thousands
PLN)
Number of
employees
as at
31.12.2024
Profit before
tax for 2024
(thousands
PLN)
Income tax
for 2024
(thousands
PLN)
Branches
EU
165 644
153
7 798
2 134
Subsidiaries
EU
3 660
10
281
117
Subsidiaries
outside the
EU
226 858
109
12 202
636
Name
Areas of
activities
Revenue for
2023
(thousands
PLN)
Number of
employees
as at
31.12.2023
Profit before
tax for 2023
(thousands
PLN)
Income tax
for 2023
(thousands
PLN)
Branches
EU
124 452
136
5 692
(1 489)
Subsidiaries
EU
3 636
12
132
(45)
Subsidiaries
outside the
EU
189 864
92
10 796
62
Major events subsequent to the reporting date
On February 11, 2025, XTB Agente de Valores SpA with registered office in Chile, received
from CMF (Spa. La Comisión para el Mercado Financiero) license No. 216 to conduct
business in Chile. The company will provide brokerage services. The License of CMF
significantly strengthens XTB presence in one of the most rapidly developing regions of the
world. Thanks to it, the clients from South America will receive access to the entire XTB
offer and will be able to invest in international stocks, ETP, and all derivatives available in
XTB.
Financial result forecasts
XTB S.A. did not publish any financial forecasts for 2024 (respectively consolidated and
separate).
Dividend
The Management Board of XTB intends to recommend to the General Meeting the payment
of a dividend in the amount taking into account the level of net profit presented in the
Company's separate annual financial statements and the Company's financial capabilities.
The Management Board, when submitting proposals for the payment of dividends, will be
guided by the need to ensure an appropriate level of the Company's capital adequacy ratios,
the capital required for the Group’s growth, and the guidelines of the FSA. The intention of
the Management Board is to recommend to the General Meeting in the future to adopt
resolutions on the payment of a dividend, taking into account the factors indicated above, in
the amount ranging from 50% to 100% of the Company's standalone net profit for a given
financial year.
However, the dividend policy will be amended by the Management Board as necessary, and
decisions on this matter will be made taking into account a number of various factors
concerning to the Company, including the prospects for further operations, future profits,
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Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
cash requirements, financial condition, the level of capital adequacy ratios, expansion plans,
and legal requirements in this respect. Each resolution on the payment of dividends will also
be considered by the General Meeting.
However, the payment of the dividend and the determination of the amount of the dividend
paid ultimately depends on the decision of the shareholders at the Ordinary General Meeting
and in this respect the shareholders are not bound by any recommendation of the
Management Board.
Unit net profit in 2024 amounted to PLN 855.2 million. Taking into account the criteria set
out by the FSA in the statement published on 10 December 2024, especially in terms of the
level of the total capital ratio and the assessment of BION, in 2024 it is possible for XTB to
pay a dividend in the maximum amount of 75% of profit for 2024.
On 20 December 2024, the Company received from the Investment Company Department
of the Polish Financial Supervision Authority a supervisory rating BION) of 2 [2.7]. The rating
was assigned on June 30, 2024. The rating at level 2 means a low level of threat to the
stability of the brokerage house and thus falls within the criteria recommended by the Polish
Financial Supervision Authority, which should allow the Company to pay the dividend for
2024
in accordance with these criteria.
The chart below presents the value of the total capital ratio (IFR) in 2024.
The total capital ratio informs about the ratio of own funds to risk-weighted assets, in other
words, it shows whether the brokerage house is able to cover the minimum capital
requirement for market, credit, operational and other risks with its own funds.
At the end of 2024 the total capital ratio in the Company was 197.8%.
125%
150%
175%
200%
225%
250%
275%
01.01.2024
15.01.2024
31.01.2024
15.02.2024
29.02.2024
15.03.2024
31.03.2024
15.04.2024
30.04.2024
15.05.2024
31.05.2024
15.06.2024
30.06.2024
15.07.2024
31.07.2024
15.08.2024
31.08.2024
15.09.2024
30.09.2024
15.10.2024
31.10.2024
15.11.2024
30.11.2024
15.12.2024
31.12.2024
Aggregate capital adequacy (IFR) in 2024
Total capital ratio (IFR)
PLN 855.2 MLN
UNIT NET PROFIT FOR 2024
197.8%
TOTAL CAPITAL RATIO
AT THE END OF 2024
110
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Dividend payment on profit for 2023 made in 2024
By decision of the Company's General Meeting of Shareholders of 23 May 2024, net profit for 2023 in the amount of PLN 787.1 million was allocated in part to the payment of a dividend in the
amount of PLN 590.2 million, the remaining part of the profit in the amount of PLN 196.9 million was transferred to reserve capital. The value of the dividend per share paid for 2023 was PLN 5.02.
The dividend was paid on 20 June 2024.
The following table presents historical information on the dividend paid by the Company in each year:
DIVIDEND
FROM PROFIT
FOR THE YEAR
DIVIDEND AMOUNT
[IN THOUSANDS PLN]
DIVIDEND
DATE
DIVIDEND PAYMENT
DATE
DIVIDEND PER
SHARE [IN PLN]
DIVIDEND
RATE
1
2023
590 198
03.06.2024
20.06.2024
5.02
7.1%
2022
570 484
10.07.2023
21.07.2023
4.86
11.8%
2021
176 075
05.05.2022
16.05.2022
1.50
7.2%
2020
210 117
21.04.2021
30.04.2021
1.79
9.9%
2019
28 172
30.04.2020
15.05.2020
0.24
2.7%
2018
19 955
25.04.2019
10.05.2019
0.17
4.2%
2018
2
41 084
11.12.2018
18.12.2018
0.35
7.1%
2017
-
-
-
-
-
2016
37 564
05.05.2017
23.05.2017
0.32
3.9%
1
) Calculated as the dividend value per share divided by the market price of the shares on the last day on which shares with dividend rights could be purchased.
2
) On 18 December 2018, an advance payment was made on account of the expected dividend for the 2018 financial year in the amount of PLN 41 084 thousand, the remaining amount, i.e. PLN 19 955 thousand was paid on 10 May 2019.
111
Management Report of XTB Group and XTB S.A. in 2024
/ Financial result and dividend
Risk
management
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
112
Management Report of XTB Group and XTB S.A. in 2024
/ Risk management
The main features of internal control and risk management in relations
to the process of preparing separate and consolidated financial statements
The system of internal control and risk management in relation to the process of preparing
separate financial statements and consolidated financial is directly under the Management
Board of the parent company. Supervision over the process of preparation of financial
statements lies with the Financial Director. Financial statements are prepared by the Finance
and Accounting Department of the parent company under the supervision of the Chief
Accountant. The Parent Company also controls and analyses costs in terms of financial
targets.
In order to eliminate the risks associated with the preparation of financial statements, also of
the Group subsidiaries, are annually audited by an independent statutory auditor. The Group
constantly monitors the performance of individual areas and compares to financial targets.
The annual financial statements of the Parent Company and the annual consolidated financial
statements of the Group are audited by an statutory independent auditor. While the half-year
financial statements of the Parent Company and consolidated half-year financial statements
of the Group are reviewed by a certified auditor. The quarterly and half-yearly condensed
consolidated financial statements of the Group as well as the annual financial statements of
the Parent Company and the Group are approved prior to publication by the Management
Board of the Parent Company.
Risk management and internal audit system
Risk management
XTB Group's operations are associated with the occurrence of various types of risks that are
characteristic of the operating model adopted, which is characterized by the occurrence of
significant open positions resulting from market-maker activities, a significant degree of
complexity of the ICT infrastructure, a very large number of operations and a large number of
legal regulations in force in many different geographical areas in which the Group operates.
These risks may pose a threat to the Group itself, to clients and to the financial market as
a whole.
In order to control risks, the Group has a risk management system, which consists of policies,
procedures, mechanisms and tools to support the processes for managing specific types of
risks according to their materiality. The main objectives of the risk management system are:
▪ identification and determination of the materiality of individual risks,
▪ proper measurement or estimation of the level of risks (for risks that are difficult to
measure),
▪ controlling the level of risk by monitoring limits and taking appropriate action when
limits or alert levels are exceeded,
▪ supporting the achievement of established business objectives by control of the level
of risks and ensuring compliance with the risk appetite.
The risk management system is organized along three lines of defense:
▪ the first line of defense is formed by the organizational units whose operational
activities give rise to risks, in particular the Trading Department (risks associated
with open positions) and the IT Development Department (operational risk
113
Management Report of XTB Group and XTB S.A. in 2024
/ Risk Management
associated
with the development of systems and their operation),
▪ the second line of defense consists of units that are independent of the business unit
and are responsible for measuring, monitoring and reporting risks, including the Risk
Control Department,
▪ the third line of defense is the Audit Department, which independently monitors and
evaluates the effectiveness of the activities of the first and second lines of defense.
▪ At the strategic level, the Management Board is responsible for establishing and
monitoring the risk management policy.
The Risk Management Committee, composed of members of the Supervisory Board, was
appointed in the Parent Company. The Committee's tasks include: preparation of a draft
document regarding risk appetite of the brokerage house, issuing opinions on risk
management strategy developed by the Management Board, supporting the Supervisory
Board in supervising the strategy of the brokerage house in risk management by the
Management Board, verification of remuneration policy and principles of its implementation
in terms of adjusting the remuneration system to the risk the brokerage house is exposed to,
its capital, liquidity and probabilities and dates of obtaining income.
The Risk Control Department supports the Management Board in formulating, reviewing and
updating risk management rules in the event of the occurrence of new types of risk, significant
changes in strategy and operating plans. The Department also monitors the appropriateness
and efficiency of the implemented risk management system, identifies, monitors and controls
the market risk of the Group’s own investments, defines the overall capital requirement and
estimates internal capital. The Risk Control Department reports directly to the Management
Board.
The management system, including XTB's risk management system, is evaluated annually
by the Polish Financial Supervision Authority as part of the Supervisory Examination and
Evaluation (BION) process. The assessment obtained in 2024 shows that:
▪ in terms of the business model – the business model and strategy indicate a medium
low risk to the investment company's ability to operate effectively,
▪ in terms of governance – imperfections in governance mechanisms indicate
a medium level of threat to the stability of the brokerage house,
▪ in terms of adequacy of liquidity and funding resources - the liquidity position and
funding profile indicate a lack of noticeable threat to the stability of the brokerage
house, taking into account the management and control mechanisms of liquidity risk
and funding risk,
▪ in terms of capital adequacy - the level of own funds indicates a low level of threat
to the stability of the brokerage house, taking into account the level, management
and control mechanisms of the various risks to which the brokerage house is
exposed.
The Group is required to maintain capital resources adequate to its risks (capital adequacy)
and maintains at an appropriate level:
▪ own funds resulting from the IFR Regulation,
▪ internal capital.
Adequate capital resources are intended to safeguard the Group's ability to operate in the
event of the materialization of particular risks.
An important element of the risk management system is risk appetite, which defines the level
of risk measures that should not be exceeded and determines risk appetite. Risk appetite, like
other elements of the risk management system, is subject to periodic review and possible
adjustment to changing business conditions. Declaration of risk appetite is approved by the
Supervisory Board.
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Management Report of XTB Group and XTB S.A. in 2024
/ Risk Management
Risk factors and threats
The Group within its operations monitors and assesses risks and undertakes activities in order to minimize their impact on the financial condition.
Material risk factors
Implications for the
client/market/company
Mitigation methods
Price volatility of financial instruments
Loss due to adverse amendments in prices of
financial instruments
Negative balance protection mechanism, stop-out mechanism (variable margin), ability to set
stop-loss on a position, education of clients
and information about the high risk of leveraged instruments, limiting the level of leverage for
clients without professional client status, testing the adequacy of the product in the context of
knowledge and client experience (MiFiD questionnaire and determination of target groups).
XTB Insolvency
Impairment of cash and value of financial
instruments
Segregation of funds in segregated client bank accounts, separately from the company's
funds. Storing funds in bank accounts corresponding to positive equity of clients with an
additional surplus. Recovery Plans and Risk Management System in XTB. Daily
reconciliation of funds between bank accounts and trading systems, taking into account the
currency in which the client's account is maintained, and the cyclical process of verification
and control of cash balances on clients' money accounts, which consists in particular in
verification of deposits and withdrawals of individual clients in the trading system and the
banking system. Exclusion of client funds from the bankruptcy estate of XTB.
Loss of securities in XTB accounts
Loss of securities in XTB accounts due to
custody of securities with an inadequate
depositary
Restricting depositaries to entities that conduct business in a state whose law regulates the
activity of storing financial instruments for someone else's account, and this depositary is
subject to the supervision of the competent supervisory authority in this respect. Annual
assessment of the depositary and sub-depositories indicated by it, among others, in the field
of credit quality, internal and external regulations regarding the storage of securities.
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Material risk factors
Implications for the
client/market/company
Mitigation methods
Bankruptcy of the bank where the
client's funds are stored
Loss of funds
1. Qualitative verification of banks before opening an account in terms of:
a) the bank's position on the local banking services market in terms of financial
resources, reputation, equity, ability to meet and repay arrears and liabilities;
b) the level of provision of electronic banking services by the bank, including:
operational reliability, liquidity and speed of the Internet access system, appropriate
security standards, extensive account functionality, including the availability of
investment functions;
c) the requirement of bank diversification;
d) credit quality.
e) the legal system and market practices related to the storage of clients' money, which
could adversely affect the ownership of funds belonging to clients.
2. Monitoring of current credit quality for the already opened accounts. XTB defines the
minimum required credit ratings of banks issued by specialized rating agencies and the
warning level regarding the probability of insolvency.
3. Reducing excessive concentration of funds, including client funds, in one capital group by
establishing appropriate concentration limits.
Operational error or employee fraud
related to the deposit/withdrawal
process
Loss of funds in the event of an incorrect
payout. In the event of unrecorded/delayed
posting of the payment, investment
opportunities lost or positions closed as a
result of the stop-out mechanism
Automation of the deposit/withdrawal process for clients. Operational restrictions on access
to accounts and transfer limits on client bank accounts. Daily reconciliation of funds between
bank accounts and trading systems, taking into account the currency in which the client's
account is maintained, and the cyclical process of verification and control of cash balances
on clients' money accounts, which consists in particular in verification of deposits and
withdrawals of individual clients in the trading system and the banking system.
Leakage of client data or other violation
of the law in the area of personal data
protection
Disclosure of client sensitive data as a result of
employee error/abuse or hacking
XTB internal procedures in the field of GDPR, internal controls, XTB ICT environment
protection measures. IT security protection by external certified vendors.
Hacker attack
Disclosure of sensitive client data or loss as a
result of opening an unauthorized
transaction/ordering an unauthorized
withdrawal of funds
XTB ICT environment protection measures. IT security protection by external certified
vendors. Two-step authorization. Authorization in the event of an amendment in the declared
withdrawal account.
Improper classification of the client
according to MiFiD
Loss of the client, as a result of investing in
inadequate/too risky instruments for the client
and as a result of granting too high leverage
on leveraged instruments or the client's
misunderstanding of the product
Internal controls, Compliance controls and internal procedures
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Material risk factors
Implications for the
client/market/company
Mitigation methods
Unauthorized investment advice or
misleading the client
Loss of the client, as a result of making an
investment decision on the basis of
unauthorized advice (improper
recommendation of the analysis department or
the employee contacting the client)
Verification of selected telephone conversations of employees with clients in terms of their
compliance with the law. Internal controls, Compliance controls and internal procedures
Unclear terms of the contract with the
client, the presence of abusive clauses
in contracts with clients
Loss due to non-recognition of the client's
complaint on the basis of abusive clauses
Internal audit system, compliance supervision system, internal audit
Failure of the trading system
Loss due to the inability to close the position
during a failure. Lost opportunities to make a
profitable trade.
Business Continuity Procedures. Parallel operation of servers (tripling the amount of
computer hardware).
Failure at the broker executing the order
Lack or delay in the ability of clients to make
transactions - loss due to the inability to close
the position. Lost opportunities to make a
profitable trade.
Business Continuity Procedures.
Incorrect data in the transaction system
Loss due to entering into a transaction at an
incorrect price, closing a position as a result of
an unnecessarily activated stop-out
mechanism or making an incorrect investment
decision by the client.
Validation of price sources - comparison of prices with the backup source, verification of the
correctness of quotes in the event of a significant difference from the previous quotation.
Monitoring and limiting the size of the quotation spread. Mechanisms ensuring enforcement
and price continuity. Quotation checks carried out by the Trading Department and the Control
and Risk Department. Optimization of trading systems.
Operational error in the operation of the
trading system
Loss due to an operational error of an
employee of the Trading Department when
making corrections to transactions or entering
data into the trading system, e.g. incorrect
level of leverage on the client, incorrect
configuration of the instrument, error when
entering corporate actions
Regulated accounting rules. Automation of the process of making corrections, reporting the
corrections made in the JIRA system, access restrictions in the scope of making corrections.
Four-eyes rule and requirement for additional authorization for larger amount adjustments.
Data correctness checks carried out by the Trading Department and the Risk Control
Department.
Malfunction of the algorithmic trading
algorithm
Client loss or positions opened not in
accordance with the order
The process of self-assessment and validation of the algorithmic trading system, monitoring
the results achieved by client portfolios, stress tests for portfolios using algorithmic trading,
periodic verification of the correctness of the algorithm.
Errors in reporting to the supervisor and
to the market
Incorrect decisions of investors regarding XTB
shares due to errors in financial or non-
financial reporting
Internal audit system, compliance supervision system, internal audit
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Material risk factors
Implications for the
client/market/company
Mitigation methods
Manipulation of financial instruments in
regulated markets
Occurrence of non-market prices
Implemented MAR fraud detection system
Information leakage, unauthorized
disclosure or use of classified
information, illegal use of client data or
other legally protected information
Threat to the stability of the capital market and
the security of trading in XTB shares
XTB ICT environment protection measures. IT security protection by external certified
vendors. Procedures for the flow of confidential information, management of security
incidents, implemented market abuse detection system (MAR) and documented rules for
investment by XTB employees
Currency risk
Risk of impairment of assets, increase in the
level of liabilities or negative amendment in the
result as a result of sensitivity to amendment in
exchange rates.
1. Client position limits;
2. Position limits on the instrument.
3. The total market risk limit resulting from the declaration of the acceptable level of risk
Interest rate risk
Risk of impairment of assets, increase in the
level of liabilities or negative change in the
financial result as a result of sensitivity to
change in interest rates.
Market risk management procedure:
1. Client position limits;
2. Position limits on the instrument.
Investment policy:
1. Investment categories;
2. Allocation limits;
3. Maximum maturity;
4. Maximum involvement in issuers of financial instruments.;
5. Minimum required credit ratings of banks.
Commodity price risk
Risk of impairment of assets or negative
change of the financial result as a result of
sensitivity to change in the prices of
commodity.
1. Client position limits;
2. Position limits on the instrument;
3. The total market risk limit resulting from the declaration of the acceptable level of risk.
Equity investment price risk
Risk of impairment of assets, increase in the
level of liabilities or negative change in the
financial result as a result of sensitivity to
change in interest rates.
1. Client position limits;
2. Position limits on the instrument;
3. The total market risk limit resulting from the declaration of the acceptable level of risk
Placing an excessive amount of funds
on a term deposit/bond
Lack of availability of funds for the needs of
current operations. Loss of accrued interest
due to early termination of the deposit or
redemption of bonds at a lower price.
Monitoring financial needs. Financing current needs from external sources (e.g. a loan).
Activation of the contingency liquidity plan from the recovery plan in the event of a lack of
liquidity.
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Material risk factors
Implications for the
client/market/company
Mitigation methods
Increase in cash outflows related to
current operating activities
Lack of availability of funds for the needs of
current operations. Costs associated with the
need to activate emergency liquidity plans.
Potential financial penalties for late payment of
invoices and the reputation risk and
impediment to further cooperation with relevant
contractors.
Monitoring and limiting measures of liquidity risk, determining the liquidity risk appetite in the
Declaration of the acceptable level of risk, identifying and monitoring the sources of possible,
extreme and potential liquidity demand.
Increase in cash outflows of clients in
the event of operational unavailability of
the bank
The need to cover client withdrawals from own
funds until the availability of the banking
system is restored
Establishing a limit on the concentration of own funds to cover potential client withdrawals in
the event of unavailability of the system from own funds deposited with another bank
Materialization of market risk
Lack of availability of funds for the needs of
current operations. Costs associated with the
need to activate emergency liquidity plans.
Determining the required demand for liquid assets in an amount adequate to the level of
market risk.
Addiction (lack of diversification) or
overexposure to one entity or associate
entities
Lack of availability of funds for the needs of
current operations due to insolvency/financial
or technical problems of the bank/broker from
one capital group
Establishing a limit on the concentration of own funds within one capital group. Monitoring of
exposure and credit quality of individual entities.
Concentration of too much money in
banks/brokers from one capital group
Default by the counterparty or loss of cash
deposited in bank accounts due to insolvency
or deterioration in credit quality
Monitoring of counterparties' credit risk, determination of the required levels of credit quality
assessments and probabilities of insolvency, monitoring of the market situation and economic
environment of significant business counterparties
Subsidiary financial problems
Impairment of capital exposure and loss due to
support obligation of the subsidiary.
Monthly management report covering all subsidiaries, creation of accounting write-offs in the
event of anticipated impairment
Hardware/network failure in the server
room
Degradation of services and the cost of
purchasing new equipment or servicing
Tripling the amount of computer hardware in the server room (parallel operation), real-time
monitoring
Computer/hardware failures
Lack of access to the workplace by
employees, inability to perform daily duties
Systematic review of equipment efficiency and its possible repair/replacement. Monitoring
and analyzing the status of workstations by IT.
Failure of the trading system
Significant number of client complaints,
reputation risk; potential supervisory penalties
with the possibility of losing the license
Systematic review of the correctness of the application code, ensuring adequately efficient
servers, optimization of operation
Failure of the market risk management
system (xRisk) or snapshot module
Inability to hedge positions, resulting in the risk
of loss, difficulties in estimating the current
level of risk and maintaining capital
requirements at a level consistent with the risk
appetite, the risk of exceeding capital
XRisk backup. Continuous development of the xRisk application, optimization of operation
and correction of errors in it. Monitoring the operation of xRisk. In the event of failure of the
snapshot module itself, it is possible to estimate the level of risk using an excel tool prepared
by the Risk Control Department on the basis of current states in the xRisk system.
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Material risk factors
Implications for the
client/market/company
Mitigation methods
adequacy standards
Insufficiency/failure of data warehouse,
incompleteness/incorrectness of data in
data warehouse, no snapshots from the
required period
Inability to meet regulatory reporting
requirements, potential risk of exceeding
capital adequacy standards or the need to
incur additional costs related to more prudent
hedging of positions to guarantee compliance
with capital adequacy standards; delays in
accounting for closed positions, delays in
analyzing MAR alerts, improper fulfillment of
other reporting and reporting obligations
Monitor server load and prioritize critical processes as needed. Continuous work on the
optimization of database processes. Estimating the current capital requirements on a server
separate from the data warehouse. Data completeness and correctness checks carried out
by the Risk Control Department.
Failure of back
office/accounting/financial-accounting
systems
Delays/errors or deficiencies in bookkeeping.
Delays in work and overloading employees
(significant manual work, decrease in
employee motivation, the need to work
overtime, the risk of losing employees). Delays
in calculating the correct result for the period,
thus errors in reporting the balance sheet,
RZiS, tax, late delivery of pit to the Tax Office.
Risk of data disintegration, loss of analytics,
risk of erroneous report due to non-
standard/manual processes not foreseen by
the accounting system manufacturer (reports
generated in SQL, not directly in the
accounting system). The risk of the inability to
record newly introduced products or a
significant delay. Potential supervisory
penalties, tax penalties for untimely/erroneous
pit, penalties from the labor inspection, the
cost of hiring new employees
Monitoring the data import process. External consultations with the supplier of the accounting
system (in the scope of the service contract), optimization of imports. Clipping of the
accounting base. Setting up a new accounting base as needed. Implementation of the
middle-office system. Use of the database replica for reporting purposes.
Technical error of the trading system
Incorrect submission of a hedging order on the
market, performance of the order at the wrong
price, appearance of incorrect items on the
XTB book, incorrect net profit and loss figure
on a given item, errors in reporting and
accounting
Analysis of the cause of the error, optimization of transaction systems, price reconciliation,
validation of price sources
Operational error in the operation of the
trading system
Loss due to an operational error of an
employee of the Trading Department when
making corrections to transactions or entering
Regulated accounting rules. Automation of the process of making corrections, reporting the
corrections made in the JIRA system, access restrictions in the scope of making corrections.
Four-eyes rule and requirement for additional authorization for larger amount adjustments.
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Material risk factors
Implications for the
client/market/company
Mitigation methods
data into the trading system, e.g. incorrect
level of leverage on the client, incorrect
configuration of the instrument, error when
entering corporate actions
Data correctness checks carried out by the Trading Department and the Risk Control
Department.
Technical error of the
deposit/withdrawal automation system
Loss of funds in the event of an incorrect
payout, client complaints and reputation risk
Automation of the deposit/withdrawal process for clients. Operational restrictions on access
to accounts and transfer limits on client bank accounts. Daily reconciliation of funds between
bank accounts and trading systems, taking into account the currency in which the client's
account is maintained, and the cyclical process of verification and control of cash balances
on clients' money accounts, which consists in particular in verification of deposits and
withdrawals of individual clients in the trading system and the banking system.
Manipulating an employee - opening
unauthorized positions or making an
unauthorized correction
Possible loss due to change in the prices of
these items
Closure of unauthorized items; seeking legal compensation from the employee. Transferring
excess free funds from brokerage accounts to bank accounts. Daily verification of the status
of open positions at brokers with the risk management (xRisk) system.
Misuse of an employee/third party - theft
of equipment/data (corporate
espionage), attempt to withdraw
company or client funds to the
employee's private account
Cost of lost assets
In the field of withdrawals: Automation of the deposit/withdrawal process for clients.
Operational restrictions on access to accounts and transfer limits on client bank accounts.
Daily reconciliation of funds between bank accounts and trading systems, taking into account
the currency in which the client's account is maintained, and the cyclical process of
verification and control of cash balances on clients' money accounts, which consists in
particular in verification of deposits and withdrawals of individual clients in the trading system
and the banking system.
In the field of theft: building monitoring, access restrictions, employee training. Enforcement
of claims by legal means.
Incorrect or insufficient procedures and
measures in the field of client
identification, monitoring of client
transactions and business relations
with clients
Financial penalties, litigation, reputational
damage in connection with the use of XTB for
money laundering or financing of terrorism
purposes
AML procedures, financial security measures, internal controls, internal audits
Information leakage, unauthorized
disclosure or use of classified
information, illegal use of client data or
other legally protected information
Violation of the law in the area of personal data
protection (GDPR), losses related to client
complaints and potential supervisory penalties,
loss of reputation and outflow of clients to
competition
XTB ICT environment protection measures. IT security protection by external certified
vendors. Procedures for the flow of confidential information, management of security
incidents, implemented market abuse detection system (MAR) and documented rules for
investment by XTB employees; restrictive lists, mechanisms for access control to IT rooms
and systems, list of insiders, training - raising employee awareness
Network attack (DDOS)
Loss of access to XTB services. Loss of
credibility and potential outflow of clients to
competition. Lack of trade opportunities, the
need to cover client complaints.
Protection by external certified vendors
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Material risk factors
Implications for the
client/market/company
Mitigation methods
Operational error of IT systems
(Inaccessible, incomplete or erroneous
data from trading systems)
Supervisory penalties in the event of
exceeding the capital requirements due to
underestimation of risk; Financial losses
related to excessive hedging of positions due
to overestimation of risk; supervisory penalties,
loss of reputation and outflow of clients to
competition due to potential errors in
settlements with clients, errors in financial and
regulatory reporting
Verification of the correctness of the report data, data reconciliation between different
systems, data correctness and completeness checks
Operational error (human error) in the
operation of the IT system
(transactional, back office systems,
system for calculating capital adequacy
ratios)
Operational error (human error) when
transferring funds to the correspondent
broker
Insufficient amount to cover the trade, which
may result in the inability to hedge the position
or maintain capital adequacy or the inability to
perform orders for clients
Accurate estimate of the amount transferred to the broker. Trading limit at the broker. A
warning from the broker about the approaching margin call. Automatic checking of the status
of transfers. Daily monitoring of non-executed ordered transfers.
Loss of server room due to failure
Server recovery cost
Selection of a certified server room, diversification of the server room and quality assessment
of the service provider. Business Continuity Procedures. Assessment of the degree of
exposure to natural disasters as part of ESG risk management. Supplier audits.
Amendments in financial market laws
and regulations, lack of understanding
and compliance with certain regulatory
requirements
Supervisory penalties for untimely or incorrect
implementation of new regulations
Monitoring of regulatory changes and timely planning of implementation activities.
Application of local regulations on
branch operations
Non-compliance with the law or untimely
adaptation to amendments in regulations
Corrective actions or control of compliance with the provisions of the adopted solutions
Errors in the interpretation of
regulations
Potential errors in regulatory reporting,
calculation of capital adequacy ratios, potential
supervisory penalties for non-compliance; the
cost of a started project that cannot be
finalized for regulatory reasons
Support of the Legal and Compliance Department provided to the relevant departments, in
important matters using external, independent law firms. Internal inspections.
Using incorrect, unreliable or
incomplete data to build models
Loss as a consequence of decisions that could
be significantly based on the output of internal
models, due to errors in the development,
implementation or use of such models.
Register of models used in the company. Periodic assessment of their significance and level
of risk as well as the process of validation of relevant models.
Adopting incorrect assumptions or
simplifications when building models or
setting parameters
Using improper tools, techniques or
methods (including statistical ones) to
build models or set parameters
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Material risk factors
Implications for the
client/market/company
Mitigation methods
Inappropriate use or operation of
models due to inadequate monitoring,
validation and updating
Improper implementation of the product
or use of new suppliers
Other departments have not implemented and
tested appropriate systems for processing data
from new suppliers or appropriate settings in
systems for a new type of instrument, therefore
the potential risk of regulatory reporting
gaps/errors, a system for calculating capital
adequacy ratios, accounting and a significant
increase in manual work in these areas
Product introduction procedures requiring a pre-arrangement process. Maintaining formal,
active channels of communication between teams to ensure a smooth flow of information.
Periodic presentations of 'Demo Product & Technology', where teams share:
* changes implemented in production,
* research results,
* mock-ups of planned solutions
Unauthorized or illegal marketing or
promotional message, improper
marking of commercial information and
promotional content, incorrect
advertising messages, misleading the
client (misleading)
Supervisory penalties, loss of reputation and
outflow of clients to competition
Strict adherence to regulations, adherence to best marketing practices. XTB internal
procedures, control over the publication of commercial materials, employment of local legal
specialists in advertising and marketing
Violation of the law in the area of
consumer protection, occurrence of
abusive clauses in the regulations or in
the contract with the client
Supervisory penalties, loss of reputation and
outflow of clients to competition
Internal audit system, compliance supervision system, internal audit
Unauthorized investment advice
Supervisory penalties for unlawful activities
Verification of selected telephone conversations of employees with clients in terms of their
compliance with the law. Internal controls, Compliance controls and internal procedures
Improper fulfilment of information
obligations towards clients
Supervisory penalties, loss of reputation and
outflow of clients to competition, potential
lawsuits
Internal controls, compliance controls, internal procedures
Incorrect determination of target groups
and application of legal provisions
related to the acquisition and
classification of clients
Supervisory penalties
Product introduction procedures requiring a pre-arrangement process and approval by the
Legal and Compliance Department of the target group for the new product. Regular product
reviews identifying events that significantly affect the main characteristics of the product and
the adopted target group.
Failure to perform or improper
performance of contracts with clients,
unclear contractual terms
Lawsuits, the need to compensate clients for
financial losses, loss of client confidence and
outflow of clients to competition
Periodic contract terms analysis (GTC), compliance controls, language simplification,
additional mailing to clients, for example rolling.
Incorrect tax calculation, incorrect tax
settlements, errors in tax returns
Administrative penalties and KKS
Double checking. Audit and internal control processes. Use of local tax advisors
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Material risk factors
Implications for the
client/market/company
Mitigation methods
Improper classification of the client
according to MiFiD, offering financial
instruments contrary to the target group
Client dissatisfaction with the investment
results
Internal control, compliance control, and internal procedures. Client education.
Bad tick from quote providers
The need to cover client complaints regarding
the closure of positions at an incorrect/non-
market price. Loss of client trust.
Validation of price sources - comparison of prices with the backup source, verification of the
correctness of quotes in the event of a significant difference from the previous quotation.
Monitoring and limiting the size of the quotation spread. Mechanisms ensuring enforcement
and price continuity. Quotation checks carried out by the Trading Department and DKR.
Optimization of trading systems.
Significant increase in electricity/heat
prices due to war/natural
disasters/geopolitical decisions
Increase in operating costs
Risk materiality monitoring based on stress tests, ESG non-financial reporting
Personnel shortages - one-person
positions
Failure to meet supervisory expectations
regarding the form and scope of conducting
internal control or internal audit; Lack of
continuity of operation of these cells
Appropriate planning of internal controls, hiring a new employee
Abuse of labor law, mobbing or
discrimination, violation of health and
safety regulations
Loss of employees, potential lawsuits and
supervisory penalties. Loss of reputation.
Anonymous surveys and their analysis, whistleblowing mechanism, work regulations.
Support of local law firms. Training, webinars, implementation of the wellbeing platform
Helping Hand, through which employees can benefit from psychological support, establishing
cooperation with a mediator.
Incorrect termination of a contract of
employment
Lawsuit, loss of reputation
Cooperation with an employment law firm. Strict application of the law.
Inadequate working conditions
Loss of a key employee
Counteraction consisting in the application of HR policy in the form of substitutability at the
workplace, creation of organizational structures in which the positions of deputy directors of
given units are separated. Preferential remuneration systems for key employees, a rich
system of non-wage benefits.
Accidents at work
Delay of projects, cost of covering the
employee's absence
Training, Remote Work Regulations (OHS), work equipment, liability insurance by the
employer due to an accident at work
Prolonged sickness absence
Delay of projects, cost of covering the
employee's absence
Introduction by XTB of an extensive package of private medical care services for employees,
organization of annual vaccination against influenza in the workplace, subsidy for various
sports activities under the Multisport program, which affect health prevention by consolidating
proper healthy lifestyle patterns, implementation of the Helping Hand wellbeing platform,
through which the employee can benefit from holistic psychological support, focused on
psychoeducation and prevention, including access to:
- webinars and workshops
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Material risk factors
Implications for the
client/market/company
Mitigation methods
- educational articles
- podcasts
- coaching
- chats with experts
- online consultation and psychotherapy
- 24/7 support hotline.
Shortage of highly qualified specialists
in the labor market, failure to recruit a
person with special qualifications
Delay of projects
Professional development of people currently working (training, improvement of
qualifications), use of headhunters Supporting the development of currently employed
employees by financing participation in industry conferences, training, participation of the
employer in reimbursement of costs for participation in examinations giving specialist
qualifications, certificates, etc. (e.g. license of a securities broker, CFA, license of an
investment advisor, CIMA, etc.). Cultivating a culture of knowledge sharing and teamwork
within the organization. Constant cooperation with career offices and student organizations,
active participation of the employer in the training
new potential staff within the student community at universities, as part of
lectures for academic clubs, etc.
Low employee loyalty, employee
turnover, especially in the positions of
junior specialist, specialist
Delay of projects
Optimized recruitment process, which at the stage of finding new employees
verifies their competence, substantive knowledge and proper adjustment to the
organizational culture. Implemented process of employee adaptation, which contributes to
minimizing the risk of departures in the early period of employment. Creating a friendly
atmosphere in the workplace,
an attractive package of non-wage benefits available to employees, the possibility of
expanding the scope of responsibility, the possibility of participating in making decisions
important for the company, the possibility of interdepartmental promotion or work in foreign
branches of the company.
Change of conditions of competition
that adversely affect the entity
Lower revenues related to outflow of clients to
competition
Regular monitoring and analysis of the competitive environment and undertaking activities in
the field of competitiveness risk management and improving the competitive position of XTB
Outflow of clients to competition, low
market volatility, low inflation, too low
responsiveness of expensive marketing
campaigns
Realization of the financial result below the
requirements resulting from the need to
conduct current and future operations and
development, mainly to ensure an adequate
supply of capital.
Regular monitoring and analysis of the competitive environment and undertaking activities in
the field of competitiveness risk management and improving the competitive position of XTB,
controlling activities in the field of business cost management, ongoing monitoring of trading
results
An unfavorable for XTB change in
economic and social conditions
Decrease in revenues due to lower net client
deposits, lower client risk appetite, outflow of
client investments into the low-risk bonds/bank
Regular monitoring and analysis of the competitive environment and undertaking activities in
the field of competitiveness risk management and improving the competitive position of XTB,
controlling activities in the field of business cost management, ongoing monitoring of trading
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Material risk factors
Implications for the
client/market/company
Mitigation methods
deposits sector
results
Too low annual profits retained in
reserve capital in relation to the growing
risk exposure, the occurrence of a
significant balance sheet loss in the
current year,
methodological/implementation/operatio
nal errors in the process of estimating
capital ratios
Lack of capital adequate to the risk of
conducting business as well as the strategy in
the field of planning, structure and sources of
raising capital and the risk of its improper
implementation (including failure to obtain an
appropriate financial result).
Implemented Risk Management System; Recovery Plan
Too low annual profits retained in
reserve capital in relation to the growing
risk exposure, the occurrence of a
significant balance sheet loss due to the
materialization of the risk of the
financial result
Reduction of capital below the level necessary
to cover losses, the need to start the
liquidation or recapitalization of the company
Implemented Risk Management System, controlling activities in the field of business cost
management, ongoing monitoring of trading results
Concentration of too much money in
one banking capital group, the
possibility of manipulating the prices of
instruments on regulated markets, the
impact of XTB's financial problems on
significant counterparties, the impact of
transaction systems failure on a mass
client, loss of client confidence in the
financial sector as a result of client
dissatisfaction with the services
provided by XTB
Serious negative consequences for the
financial system and the real economy as a
result of XTB's activities
Implemented Risk Management System
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Liquidity risk
For the Company, liquidity risk is the risk of losing its payment liquidity, i.e. the risk of losing
capacity to finance its assets and to perform its obligations in a timely manner in the usual
course of business or in other predictable circumstances with no risk of loss. In its liquidity
analysis, the Group takes into consideration current possibility of generation of liquid
assets, future needs, alternative scenarios and payment liquidity contingency plans.
Currently at the Brokerage house the value of the most liquid assets (own cash) far
exceeds the value of liabilities, hence liquidity risk is relatively low. These values are
continuously monitored.
Quantitative information on liquidity risk is presented in note 36.3 Liquidity risk and note
37.3 Liquidity risk to the consolidated and stand-alone financial statement, respectively.
Operational risk
Due to the dynamic development of the Parent Company, the expansion of product
offerings
and IT infrastructure, the Company to a large extent is exposed to operational risk, defined
as the possibility of losses due to mismatch or failed internal processes, human and
systems errors or external events, while the legal risk is considered to part of the
operational risk.
The Brokerage house applies a number of procedures for the operational risk
management, including business continuity plans of the Company, contingency plans and
personnel policy. As in the case of other risks, the Company approaches to operational
risk in an active way - trying to identify risks and take action to prevent their occurrence, or
limiting their effects and an important element of this process is the analysis of the
frequency of site and the type of events in the field of operational risk.
Hedge accounting
XTB does not apply hedge accounting.
Assessment of financial funds management
The Group manages its financial funds through ongoing monitoring of possibility to finance
its assets and to perform its obligations in a timely manner in the usual course of business
or in other predictable circumstances with no risk of loss. In its liquidity analysis, the Group
takes into consideration current possibility of generation of liquid assets, future needs,
alternative scenarios and payment liquidity contingency plans.
The objective of liquidity management in XTB is to maintain the amount of cash on the
appropriate bank accounts that will cover all the operations necessary to be carried on such
accounts.
In order to manage liquidity in relation to certain bank accounts associated with the
operations of financial instruments, the Parent Company uses the liquidity model. The
essence of the model is to determine the safe area of the state of free cash flow that does
not require corrective action.
When the upper limit is achieved, the Parent Company makes a transfer to the appropriate
current account corresponding to the surplus above the optimum level. Similarly, if the cash
in the account falls to the lower limit, the Parent Company makes transfer of funds from the
current account to the appropriate account in order to bring cash to the optimum level.
Operational activities related to liquidity management are also performed by the Trading
Department and the Finance and Accounting Department.
The subsidiaries manage liquidity by analyzing the anticipated cash flows and by matching
the maturities of assets with the maturities of liabilities. The subsidiaries do not use any
models for managing liquidity. Liquidity management based on the liquidity gap analysis is
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effective and sufficient – in subsidiaries, there were no incidents related to lack of liquidity
or the lack of possibility of covering financial liabilities. In extraordinary cases, the
subsidiaries’ liquidity may be provided by the Parent Company.
The procedure also provides for the possibility of deviating from its application, and such
procedure requires the consent of at least two members of the Parent Company’s
Management Board. Information on deviations is transmitted to the Risk Control Department
of the Parent Company.
The Parent Company has also implemented liquidity contingency plans, which were not
used in the period covered by the financial statements and in the comparative period, due
to the fact that the amount of the most liquid assets (own cash and cash equivalents) greatly
exceeds the amount of liabilities.
As part of ongoing business and the tasks related to liquidity risk management, the
managers of appropriate organizational units of the Parent Company monitor the balance
of funds deposited in the account in the context of planned liquidity needs related to the
Parent Company’s operating activities. In its liquidity analysis, the existing possibility of
generation of liquid assets, future needs, alternative scenarios and payment liquidity
contingency plans are taken into consideration.
Supervision and control operations concerning the balance of cash accounts are also
performed by the Risk Control Department of Parent Company on a daily basis.
The contractual payment dates of financial assets and liabilities are presented in notes 36.3
and 37.3 to the Consolidated and Stand-Alone Financial Statements, respectively. The
marginal and cumulative contractual liquidity gap, calculated as the difference between total
assets and total liabilities for each maturity bucket, is presented for specific payment
periods.
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Corporate governance
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
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Statement on the applied corporate governance rules in 2024
Legal basis governing corporate governance of XTB S.A.
XTB S.A. follows a set of best practices for companies and continuously strives to improve
the corporate governance of its operations based on the rules of transparency, accountability
and a long-term approach that supports growth, stability and long-term investment.
XTB S.A.'s corporate governance finds its basis in the provisions of the applicable law
(Regulation of the Minister of Finance dated 29 March 2018 on current and periodic
information provided by issuers of securities and conditions for recognizing as equivalent
information required by the laws of a non-member state (Journal of Laws 2018.757, dated
20.04.2018) and recommendations presented in the documents: Best Practices for
Companies Listed on the WSE 2021 (hereinafter: "DPSN", "Best Practices") and Corporate
Governance Principles for Supervised Institutions (FSC).
Set of rules of corporate governance applied by XTB S.A.
Acting in accordance with §70 (6) (5) of the Regulation of the Minister of Finance dated 29
March 2018 on current and periodic information disclosed by issuers of securities and
conditions for recognizing as equivalent information required by the laws of a non-member
state (consolidated text, Journal of Laws of 2018, item 757), the Management Board of XTB
S.A. presents the following statement on the application of corporate governance rules in
2024.
Rules for applying derogations
Good Practices of Companies Listed on the WSE
In 2024, XTB S.A. complied with the corporate governance principles expressed in the
document "Good Practices of Companies Listed on the WSE 2021" adopted by the Exchange
Council by Resolution No. 13/1834/2021 of 29 March 2021.
The current content is available on the website dedicated to corporate governance principles
of companies listed on the WSE at: www.gpw.pl/dobre-praktyki.
The Investor Relations section of XTB S.A.'s website includes Information on the status of the
company's application of the rules included in the Set of Best Practices for Companies Listed
on the WSE 2021.
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In 2024, XTB S.A. complied with the principles expressed in the Good Practices with the exception of the three principles described in the table below.
Rule
number
Content of the rule
Company Explanation
2.1.
"A company should have a diversity policy towards the management board and
supervisory board, adopted respectively by the supervisory board or the general
meeting. The diversity policy defines the goals and criteria of diversity, among others
in such areas as gender, field of education, specialist knowledge, age and professional
experience, as well as indicates the date and method of monitoring the achievement of
these goals. In terms of gender diversity, the condition for ensuring the diversity of the
company's bodies is the participation of a minority in a given body at a level not lower
than 30%.”
The Company implements the "Diversity Policy with regard to members of the
management board of XTB S.A." approved by the Supervisory Board, however, it does
not provide for a minority share in the body at a level of no less than 30%. The company
does not have a diversity policy towards the supervisory board adopted by the general
meeting. It is worth noting that the members of the Company's governing bodies are
specialists in various areas of knowledge and have diverse industry experience
corresponding to the currently performed function. The company places emphasis on
employing employees based on the multitude of qualifications and competences in
terms of education, professional experience and skills of the selected managerial staff
in order to ensure comprehensive and reliable performance of the tasks entrusted to it.
2.2.
“The decision-makers on the appointment of members of the management board or
supervisory board of a company should ensure the versatility of these bodies by
selecting persons who ensure diversity in their composition, enabling, inter alia,
achieving the target minimum minority participation rate set at a level of no less than
30%, in line with the objectives set out in the adopted diversity policy referred to in
principle 2.1.”
The composition of the Company's Supervisory Board is the result of decisions made
by the General Meeting, and the determination of the composition of the Company's
Management Board is within the competence of the Supervisory Board. When selecting
members of the management board or supervisory board of the Company, the decisive
persons take into account the current needs of the enterprise, applying substantive
criteria and taking into account the need to ensure the versatility of these bodies by
selecting people to ensure diversity to their composition. A necessary condition for all
candidates is their substantive preparation to perform a given function, appropriate
professional experience and selection of competences, as well as education. The
individual competences of the members of the Company's governing bodies
complement each other in such a way as to ensure an appropriate level of collective
management in the organization.
2.11.6.
“2.11. In addition to the activities resulting from legal regulations, the supervisory board
prepares and presents an annual report for approval to the ordinary general meeting
once a year. The report referred to above shall contain at least:
information on the degree of implementation of the diversity policy in relation to the
management board and the supervisory board, including the achievement of the
objectives referred to in principle 2.1.”
The principle is not applied due to the nonapplication of principle 2.1.
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Corporate Governance Principles for Supervised Institution
On 22 July 2014, the Polish Financial Supervision Authority issued the Principles of Corporate
Governance for Supervised Institutions (hereinafter: the "FSC Corporate Governance
Principles"), which determine the internal and external relations of supervised institutions,
including relations with shareholders and clients, their organization, the functioning of internal
supervision as well as key internal systems and functions, the functioning of statutory bodies
and the rules of their interaction.
In accordance with the PFSA Corporate Governance Principles, a supervised institution
should strive to apply the principles set out in the Corporate Governance Rules of the Polish
Financial Supervision Authority to the widest extent, taking into account the proportionality
principle resulting from the scale, nature of the business and the specifics of the institution.
However, the withdrawal from the application of specific rules to the full extent can only occur
if their comprehensive introduction would be unduly burdensome for the supervised
institution.
The above-described rules are available on the Polish Financial Supervision Authority
website:
https://www.knf.gov.pl/dla_rynku/regulacje_i_praktyka/zasady_ladu_korporacyjnego
On 18 December 2014, the Management Board adopted a resolution regarding the
application of the Corporate Governance Rules of the Polish Financial Supervision Authority.
The application of the Corporate Governance Rules of the Polish Financial Supervision
Authority was confirmed by a resolution of the Extraordinary General Meeting of Shareholders
of 28 January 2015.
XTB S.A. applies the KNF Corporate Governance Principles to the extent that they define the
rules for the operation of brokerage houses and do not conflict with generally applicable
regulations.
The PFSA Corporate Governance Principles, as expected by the PFSA, were implemented
by the Company as of 1 January 2015. In the reporting period, the Company applied the PFSA
Corporate Governance Rules, with the following reservations:
▪ The principle set out in § 8 section 4 of the Corporate Governance Code of PFSA to
the extent that it imposes on the supervised institution the obligation to facilitate the
participation of all shareholders in the assembly of the supervisory body, inter alia
by ensuring the possibility of electronically active participation in the meetings of the
decision-making body.
Pursuant to the Articles of Association, participation in the General Meeting using
electronic means of communication will be provided by the Company, if the
announcement on convening the General Meeting will contain information about the
possibility of shareholders participating in the General Meeting using electronic
means of communication.
▪ The principle set out in § 21 section 2 of the Corporate Governance Code of PFSA
to the extent it stipulates that the election of the chairman of the supervisory body
should be made on the basis of experience and the ability to manage such body,
taking into account the independence criterion.
Pursuant to the Articles of Association, Jakub Zabłocki has the right to appoint
and dismiss one member of the Supervisory Board acting as the Chairman of the
Supervisory Board by way of a written statement on the appointment or dismissal
of the Chairman of the Supervisory Board delivered to the Company. Therefore,
compliance with the above rule will depend on Jakub Zabłocki.
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Shares and shareholding structure
As of 31 December 2024 and as of the date of submission of this Report, the share capital of
XTB S.A. consisted of 117 383 635 Series A ordinary shares and 185 616 Series B ordinary
shares. The nominal value of each share of XTB S.A. is PLN 0.05.
Due to the above-mentioned amendment registered by the General Court, the Company's
share capital currently is as follows:
SHARES
SERIES
NUMBER OF
SHARES
NOMINAL VALUE OF SHARES
(PLN)
NOMINAL VALUE OF
THE ISSUE
(PLN)
A Series
117 383 635
0.05
5 869 181.75
B series
185 616
0.05
9 280.80
Total
117 569 251
0.05
5 878 462.55
Shareholding structure – as at the beginning of the reporting period
To the best knowledge of the Management Board of the Company as at 01 January 2024, the
status of shareholders holding directly or through subsidiaries, at least 5% of the total number
of votes at the General Meeting of the Parent Entity, was as follows:
Shareholder
Number of
shares
Nominal share
value (PLN)
Share in the total
number of votes
at the GM (%)
XX ZW Investment Group S.A.
1
71 629 794
3 581 489.70
60.93
Other shareholders
45 939 457
2 296 972.85
39.07
Total
117 569 251
5 878 462.55
100.00
1
) XXZW Investment Group S.A. with its registered office in Luxembourg is directly controlled by Jakub Zabłocki, who
holds shares representing 81.97% of the share capital authorizing the exercise of 81.97% of the votes at the general
meeting of the shareholders of XXZW.
The shareholding structure as at 01 January 2024 is presented in the following chart:
39,07%
60,93%
Free float XX ZW Investment Group S.A.
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Shareholding structure – as at the end of the reporting period and as at the
date of submission of the Report
As a result of transactions related to the accelerated construction of the book of demand
addressed exclusively to selected investors meeting certain criteria "ABB", concluded by the
main shareholder, XX ZW Investment Group S.A., to the best knowledge of the Management
Board of the Company as at 31 December 2024, the status of shareholders holding directly
or through subsidiaries, at least 5% of the total number of votes at the General Meeting of the
Parent Entity, was as follows:
Shareholder
Number of
shares
Nominal share
value (PLN)
Share in the total
number of votes
at the GM (%)
XX ZW Investment Group S.A.
1
51 472 869
2 573 643.45
43.78
Other shareholders
66 096 382
3 304 819.10
56.22
Total
117 569 251
5 878 462.55
100.00
1
) XX ZW Investment Group S.A. with registered office in Luxembourg is directly controlled by Jakub Zabłocki, who holds
shares representing 81.97% of the share capital authorizing the exercise of 81.97% of the votes at the general meeting
of the shareholders of XX ZW.
The shareholding structure as at 31 December 2024 and as at the date of submission of this
Report is presented in the following chart:
After the balance sheet date, and as of the date of submission of this Report,
there were no changes other than those described above.
43,78%
56,22%
XX ZW Investment Group S.A. Free float
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Dividend
The Ordinary General Meeting is the body authorized to make decisions on the distribution of
the Company's profit and dividend payment. The Ordinary General Meeting of Shareholders
adopts a resolution on whether and what part of the Company's profit shown in the financial
statements, audited by a statutory auditor, should be used to pay the dividend. It also
determines the dividend day and the dividend disbursement date.
The right to dividend is payable to persons on accounts of which dematerialized shares
(bearer shares) are kept on the dividend day and to entities authorized to sell dematerialized
Shares on a collective account.
The conditions for the receipt of dividend by the shareholders of the Company correspond to
the rules adopted for public companies. The resolution on dividend payment should indicate
the date of determining the right to dividend (dividend day) and the dividend disbursement
date.
Detailed information on the Dividend Policy will be found in the section Financial result
and dividend, point Dividend.
Acquisition of treasury shares
As part of the purchase of treasury shares in order to fulfill the obligations arising
from the incentive program in force in the Company, on the basis of the authorization
contained in Resolution No. 4 of the Extraordinary General Meeting of XTB S.A. of April 12,
2024, 2024, Trigon Dom Maklerski S.A. purchased a total of 129,732 treasury shares of the
Company for the account of XTB, at an average price of PLN 59.65 per share, on April 12-
19. These shares constitute 0.11% of the share capital of the Company and entitle to 129 732
votes at the General Meeting of the Company, which constitutes 0.11% of the total number of
votes. (Current reports No. 12/2024 of 12.04.2024, 13/2024 of 22.04.2024)
Holders of securities with special control rights
In the 2024 financial year and as at the date of publication of this report, there were no
securities that would give special control rights to the Company.
Restrictions on exercising the voting right
In the 2024 financial year and as at the date of publication of this report, there were no
limitations to the exercise of voting rights attached to the Company's securities.
Restrictions on the transfer of ownership of securities
As at the balance sheet date and the publication date of this report, there were no restrictions
on the transfer of ownership of securities.
Agreements as a result of which changes may occur in the future
in the proportions of shares held by the current shareholder
As at the date of publication of this annual report, the Company is not aware of any events
that may result in future changes in the proportions of shares held by existing shareholders.
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XTB Statutory Bodies
General Meeting
The manner of functioning of the Company's General Meeting and its powers are
contained in the Company's Articles of Association and in the Regulations of the General
Meeting of XTB S.A. with registered office in Warsaw, which are available on the Company's
website ir.xtb.com in the Corporate Governance section.
Operation of the General Meeting
General Meetings is convened by the Management Board as ordinary or extraordinary.
Ordinary General Meetings are held annually, not later than within six months after the end of
the financial year.
Extraordinary General Meetings are convened in the circumstances specified in the
Commercial Companies Code or in the Articles of Association and also if the authorities or
persons authorized to convene General Meetings believe such to be necessary.
Ordinary General Meeting may be convened by the Supervisory Board, if the Management
Board fails to convene it on time. The Supervisory Board may also convene the extraordinary
General Meeting if it deems it necessary. The right to convene an extraordinary General
Meeting is also vested with the Company’s shareholders representing at least one-half of the
Company’s share capital or at least one-half of the total number of votes in the Company. In
such case, the Company’s shareholders will appoint the chairman of such General Meeting.
Furthermore, a shareholder or shareholders of the Company representing at least one-
twentieth of the Company’s share capital may request that an extraordinary General Meeting
be convened and that certain matters be placed on the agenda of such General Meeting. The
request to convene the extraordinary General Meeting must be submitted to the Management
Board in writing or in electronic form. If within two weeks from the submission of such request
to the Management Board the extraordinary General Meeting is not convened, the Registry
Court may authorize the Company’s shareholders submitting such request to convene an
extraordinary General Meeting. In such case, the chairman of the General Meeting is
appointed by the Court.
Competences of the General Meeting
According to the Commercial Code of Companies, tasks of the General Meeting include
in particular:
▪ the consideration and approval of the Management Board’s report on the Company’s
Operations and the financial statements for the previous financial year,
▪ the granting of a vote of approval to the members of the Management Board and the
Supervisory Board with respect to the performance of their duties,
▪ decisions regarding claims for the redress of damage caused while establishing the
Company or exercising management or supervision over the Company,
▪ the sale or lease of the Company’s enterprise or an organized part thereof and the
establishment of a limited property right thereon,
▪ making a distribution of profit or covering of losses,
▪ issuance of convertible bonds or bonds with priority rights and subscription warrants,
referred to in art. 453 § 2 of the CCC,
▪ liquidation of the Company,
▪ the acquisition of treasury shares for redemption, redemption and reduction of share
capital of the Company,
▪ merger, transformation or division of the Company,
▪ making amendments to the Articles of Association of the Company.
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According to the Articles of Association, the competences of the General Meetings include
also:
▪ the approval of the Regulations of the Management Board,
▪ the adoption of the Supervisory Board Rules,
▪ the determination of the rules and amount of the remuneration of the members of
the Supervisory Board,
▪ the creation, drawing upon and liquidation of reserve capitals and other special-
purpose funds and the drawing upon the supplementary capital.
The resolutions of the General Meeting passed by an absolute majority of votes, unless the
law or the Articles of Association provide for stricter requirements for the adoption of the
resolution.
The General Meeting will be deemed to have been validly convened regardless of the number
of shares represented thereat, provided that the General Meeting will be able to adopt a
resolution regarding the amendment to § 15, sections 3 and 4 of the Articles of Association
only in the presence of shareholders representing at least 2/3 (two-thirds) of the overall
number of votes a the General Meeting.
General Meetings in 2024:
12 April 2024 – Extraordinary General Meeting, apart from resolutions of an orderly nature,
adopted resolutions on the following issues:
▪ amendment of the Regulations of the Incentive Scheme and the Variable
Remuneration Policy in the Company;
▪ resolution on the authorization of the Management Board to acquire treasury shares
and the creation of reserve capital for the acquisition of treasury shares of the
company;
▪ the determination of the remuneration of the members of the Supervisory Board.
23 May 2024 – Ordinary General Meeting, apart from resolutions of an orderly nature,
adopted resolutions on the following issues:
▪ consideration and approval of the Report of the Management Board on the activities
of the Group and the Company for 2023 and the Report on Sustainable Development
of the XTB Group for 2023;
▪ approval of the Company's stand-alone financial statement for 2023;
▪ approval of the consolidated financial statement of the XTB S.A. Group for 2023;
▪ adoption of a resolution on the distribution of profit;
▪ the discharge of the Members of the Management Board of the Company in carrying
out their duties in 2023;
▪ consideration and approval of the Report on the activities of the Company's
Supervisory Board for 2023;
▪ the discharge of the Members of the Supervisory Board of the Company in carrying
out their duties in 2023,
▪ expressing an opinion on the Remuneration Report for 2023.
19 November 2024 – Extraordinary General Meeting, apart from resolutions of an orderly
nature, adopted resolutions on the following issues:
▪ the establishment of a new term of the Supervisory Board;
▪ appointment of Members of the Supervisory Board for a new term of office;
▪ the assessment of the collective suitability of the Supervisory Board;
▪ resolution on the authorization of the Management Board to acquire treasury shares
and the creation of reserve capital for the acquisition of treasury shares of the
company;
▪ the adoption of an updated Policy on the verification and selection of members of
the Management Board, Supervisory Board and Key Employees of XTB S.A.
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Rights and obligations related to the Shares
Certain rights and obligations related to the Shares are presented below. The issues
regarding the rights and obligations related to the shares are specifically regulated under the
Polish Commercial Companies Code, the Act on Public Offering, the Act on Trading in
Financial Instruments and the Articles of Association.
The Articles of Association do not contain provisions regarding the threshold amount of shares
owned, beyond which it is necessary to state the shareholding of the Company shareholder
or contain provisions imposing stricter conditions governing changes in capital than specified
by the applicable law.
Right to dispose of the Shares
The shareholders of the Company have the right to dispose of shares. Disposal of shares
consists of their disposal (transfer of ownership) and other forms of the ordinance,
including pledging, establishing rights of use and their lease.
Dividend
The shareholders of the Company have the right to participate in the profit, which will be
shown in the annual stand-alone financial statement audited by the statutory auditor,
designated by the resolution of the General Meeting for payment to the shareholders of the
Company (right to dividend).
The Ordinary General Meeting is the body authorized to make decisions on the distribution of
the Company's profit and dividend payment. The Ordinary General Meeting of Shareholders
adopts a resolution on whether and what part of the Company's profit shown in the financial
statements, audited by the statutory auditor, should be used to pay dividends. The Ordinary
General Meeting should take place within six months after the end of each financial year (the
financial year corresponds to the calendar year), i.e. by the end of June.
The Ordinary General Meeting also sets the date of the dividend and the date of dividend
disbursement. The dividend day may be designated as at the date of adoption of the
resolution on the distribution of profit or within the next three months, counting from that day.
The amount to be distributed among the shareholders of the Company may not exceed the
profit for the last financial year, increased by undistributed profits from previous years, and
amounts transferred from the supplementary and reserve capital created from profit, which
may be allocated for the payment of dividends. However, this amount should be reduced by
uncovered losses, treasury shares and amounts that, according to the Commercial
Companies Code or the Articles of Association, should be allocated from the profit for the last
financial year to supplementary or reserve capital.
The Management Board may pay shareholders an advance on the anticipated dividend at the
end of the financial year if the Company has sufficient funds to pay. The advance payment
requires the consent of the Supervisory Board. The company may pay an advance if its
approved financial statements for the previous financial year show profit. The advance may
amount to at most half of the profit earned from the end of the previous financial year, shown
in the financial statements audited by the statutory auditor, increased by reserve capital
created from profit, which the Management Board may use to distribute advances and
reduced by uncovered losses and treasury shares.
The right to dividend is payable to persons on accounts of which dematerialized shares
(bearer shares) are kept on the dividend day and to entities authorized to sell dematerialized
Shares on a collective account.
A shareholder's claim against the Company for payment of a dividend may be made
within 10 years, starting from the date of adoption by the ordinary General Meeting of a
resolution to allocate all or part of the Company's profit to be paid to shareholders. After this
date, the Company may evade payment of the dividend, raising the plea of limitation.
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Terms of payment of dividend
The conditions for the receipt of dividend by the shareholders of the Company correspond to
the rules adopted for public companies. The resolution on dividend payment should indicate
the date of determining the right to dividend (dividend day) and the dividend disbursement
date. Subject to the provisions of the Rules and Regulations of the NDS, the dividend day
may be designated as at the date of adoption of the resolution or within the next three months,
counting from that day. The dividend is paid on the day specified in the resolution of the
General Meeting, and if the resolution of the General Meeting does not specify such a day,
the dividend is paid on the day determined by the Supervisory Board.
Subscription right
The shareholders of the Company have the right to subscribe for the new shares of the
Company in relation to the number of Shares held (pre-emptive right). The Company's
shareholders have the right of priority to acquire new shares of the Company in relation to the
number of Shares held, with the pre-emptive right also for issuing securities convertible into
shares of the Company or incorporating the right to subscribe for shares of the Company.
The resolution on increasing the share capital of the Company should indicate the day
according to which the shareholders of the Company are designated who have the right to
collect new shares (day of subscription right). The subscription right can’t be determined later
than within six months from the day the resolution was passed.
The agenda of the General Meeting at which a resolution to increase the share capital of the
Company is to be adopted should specify the proposed day of subscription right. Depriving
the Company's shareholders of the right to acquire the shares of the new issue of the
Company may take place only in the interest of the Company and in the event that it was
announced in the agenda of the General Meeting. The Management Board presents the
General Meeting with a written opinion justifying the reasons for the deprivation of the pre-
emptive right and the proposed issue price of new shares of the Company or the method of
its determination. A majority of at least four fifths of votes is required to pass a resolution
regarding the deprivation of the Company's shareholders rights.
The above-mentioned requirements regarding the adoption of a resolution regarding the
deprivation of the current shareholders of the Company's pre-emptive rights are not applicable
if:
▪ the resolution on capital increase states that the new shares of the Company are to
be fully covered by the financial institution (underwriter), with the obligation to offer
them to the shareholders of the Company in order to enable them to exercise the
pre-emptive right on the terms specified in the resolution;
▪ the resolution states that the new shares of the Company are to be taken up by the
underwriter
in the event that the shareholders of the Company, with whom the pre-emptive
right is used, will not take part or all of the shares offered to them.
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Right to a share in the assets in the case of the winding-up of the Company
If the Company is liquidated, the assets remaining after the satisfaction or securing of the
creditors of the Company are divided between the shareholders of the Company on a pro rata
basis to their contributions to the share capital.
The right to participate in the General Meeting and voting rights
The shareholder exercises the right to vote at General Meetings. Pursuant to the Code of
Commercial Companies, General Meetings may be ordinary (ordinary General Meetings) or
extraordinary (Extraordinary General Meetings).
Each Action gives the right to one vote at the General Meeting.
A shareholder of the Company may participate in the General Meeting and exercise the right
to vote in person or through a holder of the power of attorney. A shareholder of the Company
intending to participate in the General Meeting through a proxy must give the holder of the
power of attorney the power of attorney in writing or in electronic form. The Company takes
appropriate actions to identify the Company's shareholder and holder of the power of attorney
in order to verify the validity of the power of attorney granted in electronic form.
A detailed description of the manner of verifying the validity of the power of attorney granted
in electronic form includes an announcement on convening the General Meeting.
Pursuant to the Articles of Association, participation in the General Meeting by means of
electronic communication is allowed, subject to the following. In the event that the
announcement on convening the General Meeting contains information about the possibility
of shareholders participating in the General Meeting using electronic means of
communication, the Company is obliged to provide shareholders with the opportunity to
participate in the General Meeting using electronic means of communication.
The detailed rules for conducting the General Meeting using electronic means of
communication are determined by the Management Board, taking into account the provisions
of the Regulations of the General Meeting. The Management Board announces the rules on
the Company's website along with the announcement on convening the General Meeting.
A shareholder of the Company holding shares registered on more than one securities account
may appoint separate holders of the power of attorney to exercise the rights attached to
shares registered on each account.
If a representative of a shareholder of the Company at the General Meeting is a Member of
the Management Board, a member of the Supervisory Board, liquidator, employee of the
Company or a member of the bodies or employee of a subsidiary or a subsidiary of the
Company, the power of attorney may authorize to represent only one General Meeting.
The holder of the power of attorney is obliged to disclose to the shareholder of the Company
circumstances indicating the existence or the possibility of a conflict of interests. In this case,
granting a further power of attorney is unacceptable. The holder of the power of attorney
referred to above votes in accordance with the instructions provided by the shareholder of the
Company.
Each share gives the right to one vote at the General Meeting. The Articles of Association do
not provide for voting preference. A shareholder may vote differently from each of the shares
held. A holder of the power of attorney may represent more than one shareholder of the
Company and vote differently from the shares of each shareholder of the Company.
A shareholder of the Company may not, either personally or by holder of the power of attorney,
vote on adopting resolutions regarding his responsibility towards the Company for any reason,
including granting a vote of acceptance, exemption from obligations towards the Company
and a dispute between him and the Company. The above limitation does not apply to voting
by a shareholder of the Company as a holder of the power of attorney of another shareholder
when adopting resolutions regarding the person referred to above.
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Only persons who are shareholders of the Company sixteen days before the date of the
General Meeting (day of registration of participation in the General Meeting) have the right to
participate in the General Meeting. In order to participate in the General Meeting, those
entitled from the dematerialized Bearer Stocks of the Company should request the entity
maintaining their securities account to issue a personal certificate on the right to participate
in the General Meeting. The demand should be presented not earlier than after the
announcement of convening the General Meeting and no later than the first weekday after
the date of registration of participation in the General Meeting.
Holders of registered shares and temporary certificates, as well as pledgees and users who
have the right to vote, have the right to participate in the General Meeting, if they are entered
into the book of shares on the day of registration of participation in the General Meeting.
The list of persons entitled to participate in the General Meeting is determined on the basis of
the list prepared by the entity keeping the securities deposit in accordance with the Act on
Trading in Financial Instruments and on the basis disclosed in the Company's share register
on the day of registration of participation in the General Meeting. The above list is displayed
at the Company's registered office for three days preceding the day of the General Meeting.
The Company's shareholder may request that the list of shareholders entitled to participate in
the General Meeting be sent to him free of charge via e-mail, providing his own e-mail address
to which the list should be sent.
In relation to shares registered on a collective account, a certificate confirming the right to
participate in the General Meeting shall be a document with appropriate content issued by the
holder of the said account. If the summary account is maintained by NDS (or an entity
employed by NDS to perform duties related to the maintenance of securities deposit),
information on the holder of such an account should be disclosed to NDS (or an entity
employed by NDS to perform duties related to the operation of the securities depository) by
the entity conducting a summary account for it before the first issue of such a document.
On the basis of the above-mentioned documents, the omnibus account holder will prepare
a list of persons authorized to participate in the General Meeting. If the omnibus account
holder is not a NDS participant (or a bank employed by NDS in order to perform duties related
to the securities deposit), the list of persons authorized to participate in the General Meeting
is delivered through a NDS participant (or a bank that NDS has employed to perform its duties
associated with keeping a securities deposit).
The Company's shareholder may transfer the Shares in the period between the date of
registration of participation in the General Meeting and the date of closing the General
Meeting.
Right to place particular matters on the agenda
A shareholder or shareholders of the Company representing at least one twentieth of the
Company's share capital may request that specific matters be placed on the agenda of the
next General Meeting. The request should be submitted to the Management Board no later
than twenty one days before the set date of the General Meeting. The request may be
submitted in electronic form. The Management Board is obliged to announce immediately,
but no later than eighteen days before the set date of the General Meeting, changes to the
agenda introduced at the request of the Company's shareholders. The announcement is
made in a manner appropriate for convening the General Meeting.
Manner in which the General Meeting is convened
The General Meeting is convened through an announcement made on the Company's
website and in a manner specified for the provision of current information in accordance with
the Act on Public Offering. The announcement should be made at least twenty-six days before
the date of the General Meeting. The announcement about the General Meeting should
include in particular:
▪ the date, time and place of the General Meeting and the detailed agenda,
▪ a precise description of the procedures for participation in the General Meeting and
the exercise of voting rights,
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▪ day of registering participation in the General Meeting,
▪ information that only persons who are shareholders of the Company on the
registration date of participation in the General Meeting have the right to participate
in the General Meeting,
▪ an indication of where and how a person entitled to participate in the General
Meeting may obtain the full text of documentation to be presented to the General
Meeting and draft resolutions or, if no resolutions are envisaged, comments of the
Management Board or Supervisory Board regarding matters introduced into the
agenda the General Meeting or issues that are to be included in the agenda before
the date of the General Meeting, and
▪ indication of the address of the website on which information on the General Meeting
will be made available.
Pursuant to the Regulation on Reports, the Company will be required to submit in the form of
a current report, among others the date, time and place of the General Meeting together with
its detailed agenda.
In addition, in the event of a planned amendment to the Articles of Association, the current
provisions, the content of the proposed amendments and if, due to a large scope of intended
amendments, the Company makes a decision to prepare a new uniform text, the new uniform
text of the Articles of Association together with the calculation of its new provisions. The
content of draft resolutions and annexes to the projects to be discussed at the General
Meeting that are relevant to the resolutions adopted shall also be announced in the form of a
current report.
Venue of the General Meeting
General Meetings are held in the Company’s registered office. The General Meetings in 2024
were broadcast online via a dedicated website, the address of which was indicated via the
Company's website no later than 7 days before the date of the General Meeting. In 2024,
there was no situation where the announcement on convening the General Meeting contained
information about the possibility of shareholders participating in the General Meeting using
electronic means of communication.
Right to propose draft resolutions to the Company
A shareholder or shareholders of the Company representing at least one-twentieth of the
share capital may submit to the Company in writing or using electronic communication means
draft resolutions regarding matters included in the agenda of the General Meeting or issues
to be included in the agenda prior to the date of the General Meeting. The company
immediately publishes draft resolutions on its website.
Right to demand the issuance of duplicates of motions
Each shareholder of the Company has the right to demand copies of motions regarding issues
included in the agenda of the next General Meeting. Such a request should be submitted to
the Management Board, no later than one week before the General Meeting.
Right to demand that the list of participants of the General Meeting be verified
Immediately after the election of the chairman of the General Meeting, an attendance list
containing a list of participants of the General Meeting should be drawn up, specifying the
number of shares of the Company that each of them presents and their votes. The attendance
list should be signed by the chairman of the General Meeting and presented during the
meeting. At the request of shareholders holding one-tenth of the share capital represented at
the General Meeting, the attendance list should be checked by a committee elected for this
purpose, composed of at least three persons. Applicants have the right to choose one
member of the commission.
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Right to information
The Management Board is obliged to provide the Company's shareholder, during the General
Meeting, upon request with information regarding the Company, if it is justified for the
assessment of a matter covered by the agenda of the General Meeting. If there are important
reasons to do so, the Management Board may provide information in writing outside the
General Meeting. In such a case, the Management Board is obliged to provide information
not later than within two weeks from the day the shareholder filed a request at the General
Meeting.
The Management Board refuses to provide information if it could cause damage to the
Company, a company associated with the Company or a company or a cooperative subsidiary
of the Company, in particular by disclosing technical, commercial or organizational secrets of
the company. A Member of the Management Board may refuse to provide information if the
provision of information could be the basis of his criminal, civil or administrative liability.
The information provided to the Company shareholder should be made available to the public
in the form of a current report.
A shareholder who was refused to disclose the information requested during the General
Meeting and who filed an objection to the Minutes may submit an application to the registry
court to oblige the Management Board to provide information. Such a request should be
submitted within one week from the end of the General Meeting at which information was
refused. A shareholder may also submit an application to the registry court for obliging the
Company to publish information provided to another shareholder outside the General
Meeting. Pursuant to the Regulation on Reports, the Company will be obliged to provide in
the form of a current report information provided to a shareholder following the Management
Board's obligation by the registry court in the cases referred to above.
Right to demand the issuance of duplicates of the annual financial statements
Each shareholder of the Company has the right to request copies of the Management Board's
report on the Company's operations and financial statements along with a copy of the
Supervisory Board's report and the statutory auditor's opinion no later than fifteen days before
the General Meeting.
Right to request the election of the Supervisory Board by separate groups
At the request of the Company's shareholders representing at least one fifth of the Company's
share capital, the Supervisory Board should be elected by the next General Meeting by voting
in separate groups. In this case, the mode provided for in the Articles of Association will not
be applicable and the shareholders will apply the procedure provided for in the Code of
Commercial Companies. The mechanism of such selection is as follows: the total number of
Company shares is divided by the total number of members of the Company's Supervisory
Board. Shareholders who represent such a number of shares may form a separate group to
elect one member of the Supervisory Board and may not vote in the selection of other
members. If, after a vote in the voting mode, separate groups in the Supervisory Board remain
vacancies, shareholders who have not participated in the creation of any group will be entitled
to elect other members of the Supervisory Board. If the election of the Supervisory Board is
made by way of voting in separate groups, the limitation of the preference for voting rights
does not apply, and each Action gives the right to one vote, excluding restrictions on shares
that do not entitle to exercise voting rights.
Right to appeal against the resolutions of the General Meeting
The Company's shareholders are entitled to appeal against resolutions adopted by the
General Meeting by way of an action to repeal a resolution or an action for annulment of a
resolution.
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Action for the revocation of a resolution
A resolution of the General Meeting that is contrary to the Articles of the Association or
decency and which harms the interest of the Company or intended to harm a shareholder of
the Company may be appealed against by way of action against the Company for repealing
the resolution.
An action to cancel a resolution of the General Meeting should be brought within one month
from the date of receipt of information about the resolution, however not later than within three
months from the date of adopting the resolution.
Action to have a resolution declared invalid
A resolution of the General Meeting contrary to the Act may be challenged by an action
brought against the Company for the annulment of a resolution.
An action for annulment of a resolution of the General Meeting should be brought within thirty
days from the date of its announcement, but no later than one year from the date of adoption
of the resolution.
Entities authorized to challenge resolutions of the General Meeting
The following persons have the right to file an action seeking to have a resolution of the
General Meeting declared invalid or an action for the revocation of a resolution of the General
Meeting:
▪ the Management Board, the Supervisory Board and the individual members thereof;
▪ a shareholder of the Company who voted against the resolution and who upon the
adoption thereof requested that his objection be recorded in the minutes of the
General Meeting;
▪ a shareholder of the Company who was refused participation in the General Meeting
without providing a good reason;
▪ the shareholders of the Company who were not present at the General Meeting,
only if the General Meeting was improperly convened or in the case of a resolution
on a matter which was not included on the agenda.
Change to the Rights Entrusted with the Company’s Shareholders
A change in the rights of shareholders in the form of amending the provisions of the Articles
of Association requires a resolution of the General Meeting adopted by a three-fourths
majority of votes and an entry in the Register of Entrepreneurs of the National Court Register.
In addition, a resolution to amend the Articles of Association, increasing the benefits of the
Company's shareholders or reducing the rights granted personally to the Company's
shareholders, requires the consent of all shareholders of the Company to whom it applies.
Redemption of Shares
Shares may be redeemed by way of a decrease in the share capital of the Company, however,
the redemption requires the consent of the shareholder of the Company. The Articles of
Association do not contain a provision regarding the compulsory retirement of the Shares.
The conditions, legal basis and procedure for redemption of shares and the amount of
remuneration for redeemed shares or justification for redemption without remuneration shall
be determined each time by the General Meeting in the form of a resolution.
Right to Request the Appointment of a Special-Purpose Statutory Auditor
According to art. 84 of the Act on Public Offer, at the request of a shareholder or shareholders
of the Company, holding at least 5% of the total number of votes, the General Meeting may
adopt a resolution regarding the examination by a court expert of a specific issue related to
the creation of the Company or conducting its affairs. These shareholders may, for this
purpose, request that an extraordinary General Meeting be convened or that the matter of
adopting this resolution be placed on the agenda of the next General Meeting. If the
shareholders decide to take advantage of the first option and within two weeks from the date
of requesting convening such a General Meeting, the Extraordinary General Meeting will not
be convened, the registry court may authorize the shareholders of the Company to submit the
request to convene an extraordinary General Meeting. The court appoints the chairman of
this General Meeting. If shareholders decide to use the second option and request that the
resolution be placed on the agenda of the next General Meeting, such request must be
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delivered to the Management Board in writing no later than twenty one days before the
planned date of the General Meeting.
The resolution of the General Meeting on the selection of the auditor for special matters
should specify in particular:
▪ the data of the special-purpose auditor, which auditor should be approved in writing
by the requesting shareholder;
▪ the subject and the scope of the audit, which should comply with the contents of the
request, unless the requesting party consented in writing to change the subject and
scope of the audit;
▪ the types of documents that should be made available to the auditor by the
Company; and
▪ the start date of the audit, which should not be later than three months from the date
of the adoption of the resolution.
If the General Meeting fails to adopt the resolution in accordance with the request or adopts
such resolution in breach of Article 84 clause 4 of the Act on Public Offering, the requesting
parties may, within 14 days of the date of the adoption of the resolution, request that the
registry court appoint the identified entity as a special purpose auditor.
The auditor for special matters may only be an entity having the expertise and qualifications
necessary to examine the matter specified in the resolution of the General Meeting, which will
ensure the preparation of a reliable and objective audit report. The auditor for special matters
may not be an entity providing services to the Company, its parent or subsidiary in the audited
period, as well as its parent entity or a significant investor within the meaning of the Accounting
Act. The auditor for special matters may also not be an entity that belongs to the same capital
group as the entity that provided the services referred to above.
The Management Board and the Supervisory Board are required to make available to the
special-purpose auditor such documents as have been specified in the resolution of the
General Meeting upon the appointment of the special purpose auditor, or upon the decision
of the court on the appointment of the special purpose auditor, and to provide the auditor with
the explanations necessary for carrying out the audit.
The special purpose auditor is required to present to the Management Board and the
Supervisory Board of the company a written report on the audit results. The Management
Board is required to announce the report in the form of a current report. The report of the
special purpose auditor may not disclose information that constitutes a technical, trade or
organizational secret of the Company, unless it is necessary for justifying the position
presented in the report.
The Management Board is required to submit a report on the consideration of the audit
findings at the next General Meeting.
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Supervisory Board
Supervisory Board shall supervise the operations of the Company in all areas of its
operations.
Pursuant to § 15 of the Articles of Association of the Company, the Supervisory Board
consists of five to nine members. The Supervisory Board members are appointed for a joint
three year term of office. The detailed procedures of the Supervisory Board and its
organization are set forth in the Supervisory Board Rules.
Rules of appointment and dismissal of the Supervisory Board
Members of the Supervisory Board were appointed and dismissed as follows:
▪ Jakub Zabłocki has the right to appoint and dismiss one member of the Supervisory
Board acting as Chairman of the Supervisory Board by means of a written statement
on the appointment or dismissal of the Chairman of the Supervisory Board delivered
to the Company; the aforementioned right constituting another way of appointing a
member of the Supervisory Board within the meaning of Art. 385 § 2 of the
Commercial Companies Code shall be vested in Mr. Jakub Zablocki until such time
as, through entities controlled by him within the meaning of the Accounting Act or
jointly with such entities or personally, he holds shares in the Company representing
at least 33% of the total number of votes at the General Meeting;
▪ the other members of the Supervisory Board will be appointed and dismissed by the
General Meeting.
The number of members of the Supervisory Board in a given term is determined by the
General Meeting, and if the General Meeting does not reach other decision, the number of
members of the Supervisory Board will be five. In the case of the election of the Supervisory
Board by way of separate group voting in compliance with Article 385 of the Commercial
Companies Code, the number of Supervisory Board members will be five.
The members of the Supervisory Board may elect from among themselves a Deputy
Chairman of the Supervisory Board and a secretary of the Supervisory Board. Once Jakub
Zabłocki loses his personal right referred to above, the members of the Supervisory Board
will elect a Chairman of the Supervisory Board from amongst themselves.
The mandates of the Supervisory Board members shall expire on the date of the General
Meeting approving financial statements for the last full financial year as a member of the
Supervisory Board and in other cases specified in the Code of Commercial Companies.
Composition of the Supervisory Board during the reporting periods
As during the period from 1 January 2024 to the date of submission of this report, the
composition of the Supervisory Board was as follows:
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NAME AND SURNAME
FUNCTION
STARTING DATE OF THE
CURRENT TERM OF OFFICE
EXPIRATION DATE
OF THE
CURRENT TERM OF
OFFICE
MET THE CRITERION OF
INDEPENDENCE
1
Aleksander Chłopecki
Chairman of the Supervisory Board
16.01.2025
2
20.11.2027
YES
Bartosz Zabłocki
Member of the Supervisory Board
20.11.2024
20.11.2027
NO
Grzegorz Grabowicz
Member of the Supervisory Board
20.11.2024
20.11.2027
YES
Katarzyna Dąbrowska
Member of the Supervisory Board
20.11.2024
20.11.2027
YES
Ewa Stefaniak
Member of the Supervisory Board
20.11.2024
20.11.2027
YES
Jan Byrski
Chairman of the Supervisory Board
20.11.2024
15.01.2025
3
YES
Jakub Leonkiewicz
Vice-Chairman of the Supervisory Board
19.11.2021
19.11.2024
YES
Łukasz Baszczyński
Member of the Supervisory Board
19.11.2021
19.11.2024
NO
1
) §20 (1) of the Articles of Association of XTB S.A. dated 31.07.2023 stipulates that at least two members of the Supervisory Board should meet the independence criteria.
2
) In accordance with the current report No. 3/2025, on January 15, 2025, the Company received a statement from Mr. Jakub Zabłocki, according to which, exercising the right specified in § 15 section 3 point (a) of the Company's Articles of Association,
Mr. Jakub Zabłocki appointed Mr. Aleksander Chłopecki as the Chairman of the Supervisory Board for a joint term of office starting from January 16, 2025.
3
) According to Current Report No. 1/2025, on January 2, 2025, the Company received a resignation from Mr. Jan Byrski from the position of Chairman of the Supervisory Board of XTB on January 15, 2025 for personal reasons.
During the reporting period and until the date of this report, there were the following changes
in the composition of the Supervisory Board:
▪ on 19 November 2024, the term of office of Jakub Leonkiewicz – Deputy Chairman
of the Supervisory Board and Łukasz Baszczyński – Member of the Supervisory
Board ended;
▪ on 19 November 2024, the Extraordinary General Meeting of the Company
appointed the following persons as Members of the Supervisory Board for a joint
term of office from November 20, 2024 to November 20, 2027: Ms. Ewa Stefaniak,
Ms. Katarzyna Dąbrowska, Mr. Bartosz Zabłocki and Mr. Grzegorz Grabowicz;
▪ on January 2, 2025, the Company received a resignation from Mr. Jan Byrski from
the position of Chairman of the Supervisory Board of XTB on January 15, 2025 for
personal reasons;
▪ on January 15, 2025, Mr. Aleksander Chłopecki was appointed by Mr. Jakub
Zabłocki exercising a personal right to the position of the Chairman of the
Supervisory Board of the joint term of office starting from January 16, 2025 to the
end of November 20, 2027.
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Authority of the Supervisory Board
The Supervisory Board exercises constant supervision over the Company's activities in all
areas of its operations.
In addition to the matters reserved by the provisions of the Commercial Companies Code, the
powers of the Supervisory Board include in particular:
▪ evaluation of the financial statements for the previous financial year and evaluation
of the Management Board's report on the Company's operations for the previous
financial year as to their conformity with the books and documents as well as with
the facts, and the Management Board's motions regarding profit distribution or loss
coverage;
▪ submission to the General Meeting of Shareholders of an annual written report on
the results of the evaluation referred to in the paragraph above;
▪ suspending members of the Management Board for important reasons;
▪ determining the terms and conditions of remuneration and employment of Members
of the Management Board;
▪ appointing the committees referred to in § 18 of the Supervisory Board Rules;
▪ approving the payment of advances on anticipated dividends;
▪ approval of annual budgets, which will include the budgets of the Company,
Subsidiaries and the consolidated budget of the Company's capital group;
▪ appointing an independent external statutory auditor for the Company and
Subsidiaries;
▪ approval of the granting of sureties, guarantees and other forms of assumption of
obligations of third parties excluding events directly and strictly related to the
Company's operating activities, understood as all activities directly related to the
Company's and the Subsidiaries' brokerage activities carried out at a given time, in
particular those related to trading in foreign exchange contracts, contracts for
differences and other OTC market instruments, including marketing activities
("Company's Operating Activities");
▪ consenting to the establishment of pledges, mortgages, transfers by way of security
and other encumbrances on the assets of the Company or Subsidiaries not provided
for in the budget;
▪ consenting to the acquisition, acquisition or disposal by the Company or Subsidiaries
of shares in other companies or of assets or an organized part of the enterprise of
another company or companies, as well as to the accession to (or withdrawal from)
other entrepreneurs or companies by the Company or Subsidiaries, with the
exception of agreements entered into within the framework of the Company's
Operations, if the acquisition, purchase or disposal does not exceed 5% of the share
capital of another company;
▪ approval of the sale, encumbrance, leasing or other disposition of real estate of the
Company and Subsidiaries not provided for in the budget approved by the
Supervisory Board;
▪ giving consent to the execution of agreements between the Company or
Subsidiaries and Members of the Management Board, members of the Supervisory
Board and shareholders of the Company or entities affiliated with any of the of the
members of the Management Board, the Supervisory Board or the Company's
shareholders, with the exception of agreements concluded within the framework of
the Company's Operating Activities;
▪ granting consent to implementation and granting key managers of the Company or
of the Subsidiaries the incentive program;
▪ granting consent to members of the Management Board to engage in competitive
interests within the meaning of Article 380 of the Commercial Companies Code;
▪ granting consent for the Company to dispose of a right or incur an obligation by the
Company with a value exceeding EUR 3 000 000 (three million) in a financial year
that are not provided for in the Company's budget approved by the Supervisory
Board, including ordinances and obligations for recurring or continuous services, if
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the value of the benefits resulting therefrom exceeds EUR 3 000 000 (three million)
per financial year.
Functioning of the Supervisory Board
The Chairman of the Supervisory Board directs the work of the Supervisory Board and
represents the Supervisory Board before other bodies of the Company. In the absence of the
Chairman of the Supervisory Board or a vacancy in this position, the powers of the Chairman
of the Supervisory Board referred to above shall be exercised by a member of the Supervisory
Board authorized by him, and in the absence of such authorization, the oldest member of the
Supervisory Board.
The Chairman of the Supervisory Board or a member of the Supervisory Board authorized by
him convenes and chairs meetings of the Supervisory Board, and in the absence of such
authorization granted by the Chairman of the Supervisory Board, the right to convene and
chair meetings is vested in the oldest member of the Supervisory Board in terms of age. The
Supervisory Board may also be convened by two members of the Supervisory Board acting
jointly.
The convening of a meeting of the Supervisory Board may be requested by the Management
Board or a member of the Supervisory Board, stating the proposed agenda. A meeting of the
Supervisory Board should be convened for a date no later than 14 days from the date of the
request, with the proviso that if there are justified circumstances which make it impossible for
at least half of the members of the Supervisory Board to be present at the meeting on the
aforementioned date, a meeting of the Supervisory Board may be convened no later than
30 days from the date of the request.
Resolutions of the Supervisory Board may also be adopted by written circulation or by means
of direct remote communication.
Members of the Supervisory Board may participate in the adoption of resolutions of the
Supervisory Board by casting their vote in writing through another member of the Supervisory
Board. The casting of a vote in writing may not relate to matters placed on the agenda at
a meeting of the Supervisory Board.
The detailed procedures of the Supervisory Board and its organization are set forth in the
Supervisory Board Rules.
The validity of the Supervisory Board's resolutions requires the invitation of all and the
presence of at least half of its members, including the Chairman or Vice Chairman of the
Supervisory Board.
Resolutions of the Supervisory Board are adopted by a simple majority of votes. In the event
of an equal number of votes, the vote of the Chairman of the Supervisory Board is decisive.
Activities of the Supervisory Board in 2024
In 2024, the Supervisory Board of XTB S.A. held eleven meetings. In the year under review,
69 resolutions were adopted at Supervisory Board meetings and by circulation. The average
attendance of Members of the Company's supervisory body was 98%.
Individual attendance of Members of the Company's supervisory body was respectively:
▪ Jan Byrski – 100%;
▪ Jakub Leonkiewicz – 89%;
▪ Łukasz Baszczyński – 100%;
▪ Bartosz Zabłocki – 100%;
▪ Grzegorz Grabowicz – 100%;
▪ Katarzyna Dąbrowska – 100% and
▪ Ewa Stefaniak – 100%.
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Description of competencies and professional experience of Members of the Supervisory Board of XTB S.A.
The following is the main information on the education, qualifications and previously held positions of the persons comprising the Company's supervisory body:
Aleksander
Chłopecki
Chairman of the
Supervisory Board
A graduate from the Faculty of Law and Administration at the University of Warsaw and Rhenish Friedrich Wilhelm University of Bonn, a professor of law employed
at the University of Warsaw in the Department of Commercial Law at the Faculty of Law and Administration of the University of Warsaw. Aleksander Chłopecki has
extensive knowledge acquired over the course of his professional experience on the financial market since 1991.
Since 2008, he has been the President of the Court of Arbitration at the Polish Financial Supervision Authority. Entered on the list of legal advisors, associate of law
firms. In 1991-1996, he was an Adviser to the Chairman of the Securities Commission. In 1997-2000, he held the position of Director of the Legal Department in the
Securities and Exchange Commission, and in 2001-2004 he was the Legal Affairs Deputy of the Chairman of the Securities and Exchange Commission. In 2004-
2006, he was a member of the Management Board of the National Depository for Securities S.A., as well as the Chairman of the Supervisory Board of PZU S.A. In
2016-2024, he was a Member of the Supervisory Board of OANDA TMS Brokers S.A. Currently, Aleksander Chłopecki is associated with the Marvipol Development
capital group - since 2016, he has been the Chairman of the Supervisory Board of Marvipol Development S.A. He also acts as a permanent arbitrator at the Arbitration
Court at the General Prosecutor's Office of the Republic of Poland.
Author and co-author of most legal regulations in force in the past and currently on the Polish capital market. In 2011-2013, a member of the Securities Markets
Stakeholder Group (SMSG) of the advisory body of the European Securities Market Authority (ESMA).
According to the submitted statement, Aleksander Chłopecki does not conduct any form of activity competitive to the Company, as well as does not participate in
a competitive company, as a partner in a civil law partnership, partnership or as a member of the body of a capital company, and does not participate in another
competitive legal entity, as a member of its body, and, moreover, does not appear in the Register of Insolvent Debtors kept on the basis of the Act on the National
Court Register.
At the same time, according to the submitted statement, Aleksander Chłopecki, due to over 30 years of professional experience in the field of financial market,
commercial law and membership in the supervisory boards of public companies, meets the requirements for members of the audit committee set out in the Act of 11
May 2017 on statutory auditors, audit companies and public supervision, as well as in the scope of the existence of actual and significant links between the candidate
and a shareholder holding at least 5% of the total number of votes in the Company.
Member of the Supervisory Board meets the independence criteria set out in § 20 sec. 2 of the Articles of Association.
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Katarzyna
Dąbrowska
Member of the
Supervisory Board
She started her professional career in 2003 in the audit department at Deloitte. In 2005-2015, she was associated with BZWBK Asset Management and BZWBK TFI
S.A. (currently Santander TFI S.A.) – first as an analyst, then as a manager and Stock Market Manager. She managed funds investing in the CEE region and Turkey.
For the results of her work, she was distinguished by industry journals: she received the Parquet – Golden Wallet award twice – in 2014 and 2012, as well as the title
of Fund of the Year in 2012 and 2009 from Puls Biznesu. Currently, she manages the venture capital fund – Inventures. She is a member of the Supervisory Boards
in portfolio companies Inventures – Sidly Healthcare sp. z o.o. 2019 – 2021, Napoleon sp. z o.o. 2018-2021, Ecommerce factory S.A. 2019 – 2024, Trustmate S.A.
since 2022, Edrone sp. z o.o. since 2024.
In 2004, she graduated from the Poznań University of Economics with a master's degree in management and marketing, specializing in capital investments and
financial strategies of enterprises.
Member of the Supervisory Board meets the independence criteria set out in § 20 sec. 2 of the Articles of Association.
Ewa Stefaniak
Member of the
Supervisory Board
A graduate of the Higher School of Management in Warsaw in the field of accounting and controlling. She has a qualification certificate for keeping accounting books
issued by the Minister of Finance of the Republic of Poland.
In 1991-1995, she was the Chief Accountant in the following companies: Kontrakt sp. z o.o., Hotel and Lodging sp. z o.o. and Contingsult sp. z o.o. From September
1996 to May 2006, she worked at ING Investment Management (Poland) S.A. as the Chief Accountant/Portfolio Controller. From September 2006 to October 2019,
she was employed at X-Trade Brokers Dom Maklerski S.A. (currently XTB S.A.) as the chief accountant. In 2008-2015, she was a Member of the Management Board
at XTB S.A.
A member of the Supervisory Board meets the independence criteria set out in § 20 sec. 2 of the Articles of Association.
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Bartosz Zabłocki
Member of the
Supervisory Board
Bartosz Zabłocki started his professional career in 2002 at Contract Administration sp. z o.o. where until 2007 he was the specialist for brand protection. Since 2005
to June 2022 he was a partner in the law office of Kancelaria Prawna P. Grzelka & Wspólnicy sp. k. Since 2006, Bartosz Zabłocki has been running his own business:
“Globetroter Bartosz Zabłocki”. Since March 2021, he is a Member of the Management Board of Kamienica sp. z o.o.
Bartosz Zabłocki graduated from the Department of Law and Administration at the University of Lodz.
Member of the Supervisory Board does not meet the independence criteria specified in § 20, section 2 of the Articles of Association.
Grzegorz
Grabowicz
Member of the
Supervisory Board
Grzegorz Grabowicz has been a Member of the Management Board and Financial Director at Mabion S.A. since January 2019. Grzegorz Grabowicz gained
knowledge and experience in management while working: over the period 1998 – 2003 in the Audit Department at Deloitte, in 2003 as Financial Controller at BFF
Polska S.A. (formerly: Magellan S.A.), over the period 2004 – 2017 as Financial Director at BFF Polska S.A. and Vice Chairman of the Management Board at BFF
Polska S.A. Between 2010 and 2013 he worked as Chairman of the Management Board of MEDFinance S.A. In the years 2007 – 2017 was a Member of the
Supervisory Board of Magellan Czech Republic and Magellan Slovakia. Over the period 2013 – 2017 he was a Chairman of the Supervisory Board of MEDFinance
S.A. From 2014 to October 2018 Mr Grzegorz Grabowicz was a Member of the Supervisory Board of Skarbiec Holding S.A. From October 2017 to August 2020 he
was a Member of the Supervisory Board of Develia S.A. (formerly: LC Corp S.A.) and from June 2018 to May 2019 he was a Member of the Supervisory Board of
Medicalgorithmics S.A. From May 2020, he is a member of the Supervisory Board of PRAGMAGO S.A.
In 1998 he graduated from the University of Lodz, Faculty of Management and Marketing, specialization in Accounting, and received a Master’s degree in Management
and Marketing. In 2010 he completed a program organized by the Nottingham Trent University and the WSB at the University in Poznań and receive the EMBA
(Executive Master of Business Administration) degree. Grzegorz Grabowicz is also a Statutory Auditor.
Member of the Supervisory Board meets the independence criteria set out in § 20 sec. 2 of the Articles of Association.
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Below are the CVs of Members of the Supervisory Board who, as at the date of submission of the Report, no longer perform functions in the supervisory body of the Company, but
performed them in 2024.
Jan Byrski,
Chairman of the
Supervisory Board
Appointed on: 20.11.2024,
resignation submitted on:
15.01.2025
He specializes in the law of financial innovation (FinTech), including in the payment, banking and insurance markets, in legal aspects of information protection
(personal data, professional secrets, business secrets), IT and TMT, as well as conducting proceedings before the President of the National Bank of Poland,
the Chairman of the Polish Financial Supervision Authority (KNF) and the President of UODO and cases before administrative courts. He advises companies
and financial institutions from the Polish market, as well as international markets.
He is a legal expert of the Polish Insurance Association (PIU) and the Foundation for the Development of Non-Cash Transactions (FROB). He is a member of
IAPP and the SABI-IOD association. Vice-chairman of the FinTech Committee of PIIT. Member of working teams at the UKNF for the development of financial
innovation (FinTech) and MC working groups, including distributed registries and blockchain. Participant in parliamentary work on adjusting Polish law to the
PSD 2 Directive, the Interchange Fee Regulation (IF Reg), RODO and numerous amendments to the Personal Data Protection Act and the Payment Services
Act. Speaker at conferences, seminars and trainings in Poland and abroad. Member of the Advisory Board of the monthly magazine IT in Administration.
Author and co-author of numerous scientific and popular science items, including: the monograph "Legally protected secrecy in banking activities" (C.H. Beck
2010), which won the I prize of the National Bank of Poland in the Scientiae Legis Excellentia competition for the best doctoral dissertations in business law,
as well as the dissertation "Outsourcing in the activities of payment service providers" (C.H. Beck 2018). Individual recommendations in Chambers & Partners
Europe 2020 2021 Banking & Finance: Regulatory Poland, FinTech Legal Poland 2020 and 2021 and Legal 500 EMEA Poland 2020 and 2021 in the category:
Data privacy and data protection.
University professor at the Institute of Law of the Cracow University of Economics. Graduate I degrees at the Faculty of Law of the Jagiellonian University.
Participant of the Jagiellonian University School of German Law and the Universities of Heidelberg and Mainz, as well as the Jagiellonian University School of
Austrian Law and the University of Vienna. Scholarship holder of the Foundation for Polish-German Cooperation at Ruhr-Universität Bochum. Scholarships at
Ernst-Moritz-Arndt Universität Greifswald, Johann Gutenberg Universität Mainz and at Max-Planck-Institut für Immaterialgüter-und Wettbewerbsrecht.
Member of the Supervisory Board met the independence criteria set out in § 20 sec. 2 of the Articles of Association.
Jakub Leonkiewicz,
Vice-Chairman of the
Supervisory Board
Term of office: 19.11.2021 –
19.11.2024
Jakub Leonkiewicz started his professional career in 2001 in the business development department at Interhyp.de in Germany. In 2001-2002 he worked at
Roland Berger Strategy Consultants in Germany. In the years 2002-2015 Jakub Leonkiewicz was associated with J.P. Morgan – first as an analyst in the
merger and acquisition team in London and since 2012 as a director of J.P. Morgan in Warsaw, where he was responsible for J.P. Morgan’s practice in Poland
and the Baltic countries. From November 2015 to January 2017 and once again from May 2017 he is the Chairman of the XTB Supervisory Board. Currently,
Mr. Jakub Leonkiewicz acts as a partner in Avia Capital private equity fund.
Jakub Leonkiewicz graduated in 2002 with a master’s degree from the Warsaw School of Economics with a degree in finance and banking. Jakub Leonkiewicz
participated in the CEMS Master Program (Community of European Management Schools) at the London School of Economics and was a scholarship holder
at the Christian-Albrecht Universität zu Kiel.
Member of the Supervisory Board met the independence criteria set out in § 20 sec. 2 of the Articles of Association.
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Łukasz Baszczyński,
Member of the Supervisory
Board
Term of office: 19.11.2021 –
19.11.2024
Łukasz Baszczyński commenced his professional career in 1999 as a clerk in the District Court in Zgierz. From 2002 to 2006 he cooperated as an attorney
with the law office of Kancelaria Radców Prawnych P. Stopczyk & R. Mikulski and as an assistant to the management board of Sarton Management
sp. z o.o.
He is a partner at the law office of Kancelaria Prawna P. Grzelka & Wspólnicy sp. k.
Until 27 September 2019, he was a partner in Baszczyński & Dąbrowska Intellectual Property Law. Until 6 June 2016, he was a member of the supervisory
board of Novama Cloud S.A.
Bartosz Zabłocki graduated from the Department of Law and Administration at the University of Lodz. In 2008, he was registered in the register of legal advisors
and in 2010 in the register of advocates at the District Chamber of Advocates in Warsaw. Łukasz Baszczyński is entered in the list of candidates for members
of supervisory boards of companies with the shareholding of the State Treasury.
Member of the Supervisory Board did not meet the independence criteria specified in § 20, section 2 of the Articles of Association.
In 2024, the members of the Company's Supervisory Board invested an appropriate amount of time in performing their responsibilities.
Shares of the Company and related entities held by the
Supervisory Board Members
Supervising persons did not hold shares of the Company.
The supervising persons did not treasury shares in related entities.
Functions held by members of the Issuer's Supervisory Board
in Group companies
Members of the Supervisory Board of the parent company did not hold any positions in the
governing bodies of subordinated entities during the reporting period.
Members of the Supervisory Board serving on committees of the
Supervisory Board
Committees of the Supervisory Board
The following committees operate within the Supervisory Board:
▪ Audit Committee;
▪ Remuneration Committee;
▪ Risk Management Committee.
The Supervisory Board performs the tasks of the Remuneration Committee and the Risk
Management Committee collegially by virtue of a resolution adopted by it. Since October 13,
2017, the Audit Committee has functioned as a separate committee, whereas prior to that
date, the tasks of the Audit Committee were performed collegially by the Supervisory Board.
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In 2024 and as of the date of submission of this report, Members of the Supervisory Board
performed the following functions in committees of the Supervisory Board:
NAME AND
SURNAME
FUNCTION
FUNCTION OF
THE AUDIT
COMMITTEE
FUNCTION OF THE
REMUNERATION
COMMITTEE
FUNCTION OF THE
RISK
MANAGEMENT
COMMITTEE
Aleksander
Chłopecki
1
Chairman
of the
Supervisory
Board
NO
YES
YES
Bartosz
Zabłocki
Member of
the
Supervisory
Board
YES
YES
YES
Grzegorz
Grabowicz
Member of
the
Supervisory
Board
YES
YES
YES
Katarzyna
Dąbrowska
Member of
the
Supervisory
Board
NO
YES
YES
Ewa
Stefaniak
Member of
the
Supervisory
Board
YES
YES
YES
Jan Byrski
2
Chairman
of the
Supervisory
Board
NO
YES
YES
Jakub
Leonkiewicz
3
Vice-
Chairman
of the
Supervisory
Board
YES
YES
YES
Łukasz
Baszczyński
4
Member of
the
Supervisory
Board
NO
YES
YES
1
) functions performed from 16.01.2025
2
) functions performed until 15.01.2025
3
) functions performed until 19.11.2024
4
) functions performed until 19.11.2024
The Supervisory Board may also appoint other committees. Detailed tasks and rules for the
appointment and operation of committees are defined in the Supervisory Board Rules.
Audit Committee
In the period from January 1, 2024 to November 19, 2024, the Audit Committee met in the
following composition:
NAME AND
SURNAME
FUNCTION
INDEPENDENCE
CRITERIA
CRITERIA OF
FINANCIAL
KNOWLEDGE
THE CRITERION
OF
PROFESSIONAL
KNOWLEDGE
Grzegorz
Grabowicz
Chairman of the
Audit Committee
YES
YES
YES
Jakub
Leonkiewicz
Member of the
Audit Committee
YES
YES
YES
Bartosz
Zabłocki
Member of the
Audit Committee
NO
YES
YES
In the period from November 27, 2024 to December 31, 2024, and until the date of this report,
the Audit Committee met in the following composition:
NAME AND
SURNAME
FUNCTION
INDEPENDENCE
CRITERIA
CRITERIA OF
FINANCIAL
KNOWLEDGE
THE CRITERION
OF
PROFESSIONAL
KNOWLEDGE
Grzegorz
Grabowicz
Chairman of the
Audit Committee
YES
YES
NO
Ewa
Stefaniak
Member of the
Audit Committee
YES
YES
YES
Bartosz
Zabłocki
Member of the
Audit Committee
NO
YES
YES
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Number of meetings held by the Audit Committee or meetings of the Supervisory Board
or other supervisory or controlling body dedicated to the performance of the Audit
Committee's duties
In 2024, 12 meetings of the Company's Audit Committee were held. In 2024, 21 resolutions
were adopted at meetings of the Audit Committee and by circulation. The average attendance
rate of the Company's Audit Committee Members was 94%. Individual attendance of the
Company's Supervisory Body Members was respectively: Grzegorz Grabowicz – 100%,
Jakub Leonkiewicz – 82%, Bartosz Zabłocki – 100% and Ewa Stefaniak – 100%.
Responsibilities of the Audit Committee
The Audit Committee's responsibilities include, in particular:
▪ monitoring the financial reporting process;
▪ monitoring the effectiveness of the systems of legal compliance supervision (SLC),
internal control (SIC), internal audit (SIA) including financial reporting, sustainable
development reporting, and risk management (SRM), including taking note of reports
on the effectiveness of the systems' operation and evaluating them;
▪ monitoring the performance of audit activities, in particular the audit company's
performance of the audit, taking into account any conclusions and findings arising
from the audit of the audit company;
▪ controlling and monitoring the independence of the statutory auditor and the audit
company, in particular where services other than the audit and the attestation of
sustainable development reporting are provided to the Company by the audit
company;
▪ presenting offers of audit companies to the Supervisory Board and recommending
the selection of a company to carry out the audit of the financial statements; and the
attestation of sustainable development reporting;
▪ informing the Supervisory Board of the results of the audit or the attestation of
sustainable development reporting and explaining how they have contributed to the
integrity of the Company's financial reporting and the role of the Audit Committee in
the audit process;
▪ assessing the statutory auditor's independence and approving the auditor's provision
of permitted non-audit services to the Company;
▪ developing a policy for the selection of the audit company to conduct the audit and
the attestation of sustainable development and reviewing the said document on a
regular basis;
▪ developing a policy on the provision of permitted non-audit and non-attestation
services by the company conducting the audit or the attestation of sustainable
development, by affiliates of the company, and by a member of the company's
network and reviewing it regularly;
▪ defining the procedure for the selection of the audit company by the Company and
reviewing it regularly;
▪ making a recommendation to the Supervisory Board on the appointment of statutory
auditors or audit companies;
▪ making recommendations to ensure the integrity of the financial reporting process in
the Company;
▪ adopting the report on the activities of the Audit Committee for the previous financial
year.
Topics of the Audit Committee meetings held in 2024 include:
▪ discussing the Company's quarterly reports;
▪ giving an opinion on the annual financial statements along with issuing
recommendations to the Company's Supervisory Board;
▪ discussing, analyzing and evaluating the offers of audit companies for conducting
audits for the years 2024-2025 and agreeing to the provision of additional services;
▪ reviewing reports on the functioning of internal control, risk management and internal
audit systems and listening to persons responsible for the functioning of these
systems;
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▪ meetings with representatives of the audit company conducting the audit of the
Company's financial statements;
▪ adoption of the report on the activities of the Audit Committee for 2023;
▪ verification of the policies and procedures and regulations of the Audit Committee;
▪ verification of the independence and remuneration of the audit company;
▪ adoption of the Committee's work plan for the next year.
Independence criteria and process for XTB Audit Committee Members:
Independent members of the Audit Committee
In the year 2024 in the Audit Committee of XTB, the independent members meeting the
prerequisites of independence listed in Article 129 (3) of the Act on Statutory Auditors, Audit
Firms and Public Supervision of 11 May 2017 (Journal of Laws of 2017, item 1089) (the "Act
on Auditors") were:
▪ Grzegorz Grabowicz – Chairman of the Audit Committee;
▪ Jakub Leonkiewicz – Member of the Audit Committee (Member of the Audit
Committee
in the term of office expiring on 19 November 2024);
▪ Ewa Stefaniak – Member of the Audit Committee (Member of the Audit Committee
from
27 November 2024).
Members with knowledge and skills in accounting or auditing financial statements,
with an indication of how they were acquired
The persons listed below, members of the Audit Committee, acquired knowledge and skills in
the field of accounting or auditing financial statements as a result of the education and
professional experience described:
▪ Grzegorz Grabowicz – Member of the Supervisory Board and Chairman of the
Committee, has a university degree in accounting, an MBA degree, as well as
statutory auditor's qualifications and knowledge acquired over the course of
professional experience in companies. In 1998-2003, he worked in the Audit
Department at Deloitte. In 2003, he was the financial controller at BFF Polska S.A.
(formerly Magellan S.A.), and in 2004-2017 he was the financial director at BFF
Polska S.A. and vice-president of the Management Board at BFF Polska S.A. In
2010-2013, he was the President of the Management Board of MEDFinance S.A. In
2007-2017, he was a member of the Supervisory Board of Magellan Czech Republic
and Magellan Slovakia. Over the period 2013 - 2017 he was a Chairman of the
Supervisory Board of MEDFinance S.A. From 2014 to October 2018 he was a
Member of the Supervisory Board of Skarbiec Holding S.A. From October 2017 to
August 2020 he was a Member of the Supervisory Board of Develia S.A. (formerly
LC Corp S.A.) and from June 2018 to May 2019 he was a Member of the Supervisory
Board of Medicalgorithmics S.A. From May 2020 he is a Member of the Supervisory
Board of PRAGMAGO S.A. and from January 2019 he is a Member of the
Management Board and Financial Director of the public company Mabion S.A.
Z XTB. Over the years his functions have allowed Grzegorz Grabowicz to gather
experience in the field of finance and management enabling him to meet the
independence criteria referred to in the Act.
▪ Ewa Stefaniak – Member of the Supervisory Board and the Committee, has a higher
education and a qualification certificate for keeping accounting books issued by the
Minister of Finance of the Republic of Poland. In 1991-1995, she was the Chief
Accountant in the following companies: Kontrakt sp. z o.o., Hotel and Lodging sp. z
o.o. and Contingsult sp. z o.o. From September 1996 to May 2006, she worked at
ING Investment Management (Poland) S.A. as the Chief Accountant/Portfolio
Controller. From September 2006 to October 2019, she was employed at X-Trade
Brokers Dom Maklerski S.A. (currently XTB S.A.) as the chief accountant. In 2008-
2015, she was a Member of the Management Board at XTB S.A.
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▪ Jakub Leonkiewicz – Member of the Supervisory Board and the Committee in the
term of office expiring on 19 November 2024, has a university degree in economics.
For over 9 years, he was a Member of the Supervisory Board of the Company, which
allowed him to get to know the specifics of the activities carried out by XTB in detail.
In the years 2002-2015 Jakub Leonkiewicz was associated with J.P. Morgan – first
as an analyst in the merger and acquisition team in London and since 2012 as a
director of J.P. Morgan in Warsaw, where he was responsible for J.P. Morgan’s
practice in Poland and the Baltic countries. Currently, Jakub Leonkiewicz acts as a
partner in Avia Capital private equity fund.
▪ Bartosz Zabłocki – Member of the Supervisory Board and the Committee, has a
higher legal education. For over 9 years, he has been a Member of the Supervisory
Board of the Company. From 2005 to 2022, he was a partner in the law office of the
law office of P. Grzelka & Wspólnicy sp. k., and in the years 2012-2022 a Member
of the Management Board of XX ZW Investment Group S.A. Since March 2021, he
has been a Member of the Management Board of Kamienica sp. z o.o.
Since November 2023, a partner in Contigate sp. z o.o.
Members with knowledge and skills in the industry in which the Issuer operates,
indicating how they were acquired
▪ Bartosz Zabłocki – has been a member of the Supervisory Board of XTB for over 9
years, which allowed him to acquire relevant knowledge of the industry. From 2005
until June 2022, he was a partner in the law firm P. Grzelka & Wspólnicy sp. k.
▪ Grzegorz Grabowicz – Member of the Supervisory Board has education, knowledge
and experience in the field of accounting, has an MBA degree and statutory auditor's
qualifications. He served as a financial controller and financial director, he sat on the
management boards and supervisory boards of companies with different business
profiles, also listed on the Warsaw Stock Exchange. Over the years, the functions
performed at XTB have allowed Grzegorz Grabowicz to gather knowledge about the
specifics of the industry in which the Company operates.
▪ Ewa Stefaniak – Member of the Supervisory Board and the Audit Committee, has a
higher education and experience in the field of accounting and bookkeeping.
Professionally associated with the Company for 13 years, including as a Member of
the Management Board, which allowed her to get to know the specifics of the
financial industry, brokerage activities carried out by XTB in detail.
▪ Jakub Leonkiewicz – Member of the Supervisory Board in the term of office expiring
on 19 November 2024. He has been a member of XTB's Supervisory Board for more
than 8 years, which has allowed him to gain a detailed understanding of the financial
industry and the specifications of the stock and OTC brokerage business (derivatives
on currencies, commodities, indices, stocks and bonds) conducted by XTB. In
addition, he worked at Roland Berger Strategy Consultants in Germany from 2001
to 2002. From 2002 to 2015, he was associated with J.P. Morgan - first as an analyst
in the mergers and acquisitions team in London and, from 2012, as a director of J.P.
Morgan in Warsaw, where he was responsible for J.P. Morgan's practice for Poland
and the Baltic States. He currently serves as a partner in the private equity fund Avia
Capital.
Information on the provision of permitted non-audit services by the audit company
auditing the financial statements and on the assessment of the audit company's
independence and consent to the provision of these services
For 2024, the audit company PricewaterhouseCoopers Polska spółka z ograniczoną
odpowiedzialnością Audyt sp.k. performed the following permitted non-audit services:
▪ the audit of the separate financial statements and the consolidated financial
statements for 2024;
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▪ review of the condensed interim financial statements and condensed interim
consolidated financial statements for the period from 1 January 2024 to 30 June
2024;
▪ a review of the Company's client asset custody process as at 31 December 2024;
▪ an assurance service on compliance with the applicable requirements of the
remuneration report prepared by the Company's Supervisory Board for the year
ended 31 December 2024;
▪ performing an attestation of sustainable development reporting based on the
European Sustainability Reporting Standards (ESRS) for the year ended
31 December 2024;
▪ performing a verification of the tagging of the annual consolidated financial
statements for 2024 with XBRL tags, in accordance with the ESEF regulation.
The above-mentioned services were performed on the basis of the Supervisory Board's
approval of February 21, 2024, after reviewing the Audit Committee's recommendation of 26
January 2024.
The Audit Committee approved the engagement of the audit company (i.e.
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k.) to
perform the above permitted non-audit services. The independence of the auditor's services
in the audit process was positively verified before the relevant recommendations were
submitted to the Audit Committee.
Audit Committee: Cooperation with the auditor
On 13 October 2017, the Supervisory Board approved three documents governing
cooperation with the auditor. The documents are subject to periodical verification and
updating.
The main features of the Audit Company Selection Procedure, the Audit Company Selection
Policy and the Policy for the provision of permitted non-audit services by the audit company
performing the audit (including by affiliates of the audit company and by a member of the audit
company's network of permitted non-audit services) are set out in the table below:
Procedure for
selecting the audit
company
The purpose of the Procedure is to describe the process of
selecting an audit company. The Procedure contains elements,
i.e.: request for proposals, evaluation of the proposals, selection of
the proposal, conclusion of the contract or re-selection.
Audit company
selection policy
The purpose of the Policy is to set out the principles and criteria for
the selection of the audit company that will carry out the Company's
audit. It describes the criteria for the selection of entities authorized
to carry out the audit; the criteria for the evaluation of the offers
received; the criteria for the independence assessment carried out
by the Audit Committee; and the rules for the submission and
selection of offers.
Audit company selection criteria included in the Policy:
1. The company will each time send requests for proposals to the
following audit companies: EY, PwC, KPMG and Deloitte.
2. The Company's Management Board is entitled to make enquiries of
reputable audit companies of international scope of business.
3. In order to ensure the independence of the statutory auditor and the
audit company, the selection of the audit company is made taking
into account the rotation rules for the audit company and the key
statutory auditor under the Act on Statutory Auditors and Regulation
(EU) No. 537/2014 of the European Parliament and of the Council
of 16 April 2014 on specific requirements for the statutory audit of
public-interest entities, repealing Commission Decision
2005/909/EC, in particular:
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a) the maximum period of uninterrupted duration of the statutory
audit engagements referred to, inter alia, in the second
subparagraph of Article 17(1) of the Regulation, carried out by
the same audit company or by an audit company affiliated to
that audit company or any member of the network operating in
the countries of the European Union to which those audit
companies belong, shall not exceed 10 years;
b) the key statutory auditor may not carry out a statutory audit in
the Company for more than 5 years;
c) the key auditor may re-perform the statutory audit of the
Company after a period of at least 3 years has elapsed since
the completion of the last statutory audit.
4. No enquiries are sent to the audit firm that carried out the Audits for
the previous 10 financial years.
5. The re-submission of a request for proposal to the audit company
referred to in point 3 may take place 4 years after the completion of
the last Audit carried out by that company.
Policy for the
provision by the
audit company of
permitted non-
audit services.
The purpose of the Policy is to set out the general principles under
which the audit company performing the audit may provide services
to the Company or to related parties of the Company. The Policy
contains a catalogue of permitted services.
Recommendation on the selection of the audit company to carry out the audit
In 2024, the Company's Supervisory Board selected the audit company
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k to
audit the Company's financial statements for 2024-2025, i.e. to review the Company's
separate and consolidated interim financial statements for the six months ended 30 June
2024 and 30 June 2025, and to audit the Company's annual separate and consolidated
financial statements prepared for the year ended 31 December 2024 and 31 December 2025.
The selection of the new auditor was carried out on the basis of the Company's Audit
Company Selection Policy and the Procedure for the Selection of an Audit Company to Audit
XTB's Financial Statements. The essence of the procedure in question was that the Audit
Committee analyzed the offers collected in terms of the requirements under the Act on
Auditors, Audit Companies and Public Sector, and the criteria and guidelines specified in the
aforementioned Policy. As a result of analyzing and comparing the offers, the Audit
Committee recommended two audit companies to the Supervisory Board, at the same time
indicating the offer of PricewaterhouseCoopers Polska Sp. z o.o Audyt sp.k. as the preferred
one.
The Supervisory Board, after reviewing the recommendation, selected the entity preferred by
the Audit Committee.
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Remuneration Committee
Within the scope of its powers, the Supervisory Board may, by way of a adopted resolution,
appoint other committees and determine their composition.
In 2024, the Remuneration Committee of XTB S.A. held three meetings. During the year under
review, 5 resolutions were adopted at the Remuneration Committee meetings. The average
attendance of the members of the body was 93%. The individual attendance of the Company's
Remuneration Committee Members was respectively: Jan Byrski – 100%, Jakub Leonkiewicz
– 50%, Łukasz Baszczyński – 100%, Bartosz Zabłocki – 100%, Grzegorz Grabowicz – 100%,
Katarzyna Dąbrowska – 100% and Ewa Stefaniak – 100%.
In the Company, the function of the Remuneration Committee is performed by the entire
Supervisory Board. The tasks of the Remuneration Committee are:
▪ to assist the Board in the preparation of remuneration arrangements in accordance
with the variable remuneration policy ("Remuneration Policy");
▪ providing an opinion on the Remuneration Policy, including the amount and
components of remuneration;
▪ reviewing the Remuneration Policy;
▪ overseeing the payment of variable components of remuneration to individuals in
positions with a material impact on the risk profile of the investment company;
▪ determining the variable components of the remuneration of the Members of the
Management Board, taking into account the principles described in the
Remuneration Policy.
Risk Management Committee
Within the scope of its powers, the Supervisory Board may, by way of a adopted resolution,
appoint other committees and determine their composition.
In 2024, the Risk Management Committee of XTB S.A. held five meetings. During the year
under review, 3 resolutions were adopted at Risk Management Committee meetings. The
average attendance rate of the Company's Risk Management Committee members was
100%. The individual attendance rate of the Company's Risk Management Committee was
respectively: Jan Byrski – 100%, Jakub Leonkiewicz – 100%, Łukasz Baszczyński – 100%,
Bartosz Zabłocki – 100%, Grzegorz Grabowicz – 100%, Katarzyna Dąbrowska – 100% and
Ewa Stefaniak – 100%.
The function of the Risk Management Committee is performed in the Company by the entire
Supervisory Board. Its main tasks include:
▪ drafting a document on the brokerage house's risk appetite;
▪ giving an opinion on the risk management strategy of the brokerage house
developed by the Management Board;
▪ supporting the Supervisory Board in overseeing the implementation of the brokerage
house's risk management strategy by the Management Board;
▪ reviewing the remuneration policy and rules for its implementation with a view to
aligning the remuneration system with the risks to which the brokerage house is
exposed, its capital, liquidity and the likelihood and timing of its income;
▪ discussing and approving the Statement of Acceptable Level of Risk;
▪ discussing and approving the ICAAP report.
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Management of XTB S.A.
The governing body of the Company is the Management Board acting on the basis
of the Regulations of the Management Board. Meetings of the Management Board are held
at least once a month at the Company's headquarters or, if all members of the Management
Board agree, elsewhere on the territory of Poland.
Rules of appointment and dismissal of the Management Board
The rules for appointing and removing members of the Management Board and their powers
are set forth in the Company's Articles of Association, which are available on the Company's
website ir.xtb.com in the Investor Relations section. The Management Board may consist of
three to six members, including the Chairman and two Vice Chairmen.
In accordance with its Articles of Association, at least two members of the Management Board
need to have: higher education, at least three years of experience of working for financial
market institutions, and a good opinion in connection with the positions held thereby.
Members of the Management Board are appointed and dismissed by the Supervisory Board.
The number of members of the Management Board is determined by the Supervisory Board
in the resolution on appointing members of the Management Board. A member of the
Management Board may also be dismissed or suspended from office by resolution of the
General Meeting.
The Management Board is appointed for a joint three-year term.
The mandates of members of the Supervisory Board shall expire on the date of the General
Meeting which approves the financial statements of the Company for the last full financial year
of their term of office and in other cases specified in the Code of Commercial Companies.
Composition of the Management Board during the reporting period
There were no changes in the composition of the Management Board in 2024. As at 1 January
2024 and as at the date of publication of this interim report, the composition of the
Management Board was as follows:
* On 10.01.2017, Omar Arnaout was appointed a member of the Management Board for the matters of Sales in the rank of
Vice-Chairman of the Management Board.
On 23.03.2017, he was appointed Chairman of the Management Board.
On 2 June 2022, the Supervisory Board of the Company adopted a resolution on the
appointment of the existing five person composition of the Company's Management Board for
a new joint term of office of three years, i.e. from 1 July 2022 to the end of 1 July 2025.
NAME AND
SURNAME
FUNCTION
DATE OF FIRST
APPOINTMENT
EXPIRATION
DATE OF THE
CURRENT TERM
Omar Arnaout
*
Chairman of the
Management Board
10.01.2017
01.07.2025
Filip Kaczmarzyk
Member of the
Management Board
10.01.2017
01.07.2025
Paweł Szejko
Member of the
Management Board
28.01.2015
01.07.2025
Jakub Kubacki
Member of the
Management Board
10.07.2018
01.07.2025
Andrzej Przybylski
Member of the
Management Board
01.05.2019
01.07.2025
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Competencies of the Management Board
The Management Board is authorized to conduct the affairs of the Company, represent the
Company and any matters not reserved by law or the Articles of Association of the Company
to the General Meeting or the Supervisory Board. The Management Board conducting the
Company's affairs, makes decisions in the interest of the Company, shall draft the Company's
development strategy and identifies the main goals of the Company.
Chairman of the Management Board shall convene meetings of the Management Board and
chair them. Chairman of the Management Board may authorize other members of the
Management Board to convene and preside over meetings of the Management Board. In the
absence of the Chairman of the Management Board, the meeting of the Management Board
shall be convened by the oldest member of the Management Board.
In particular, the Management Board shall have the power and shall be required to:
▪ act on behalf of the Company and represent the Company in dealings with third
parties,
▪ prepare periodic reports and statements of the Company within timeframes allowing
for their publication in accordance with relevant laws,
▪ submit financial statements to a statutory auditor for the purpose of their audit or
review,
▪ submit reports of the Management Board on the activities of the Company and the
financial statements, including an opinion and report of the statutory auditor
(if required by law), to the Supervisory Board for the purpose of evaluation,
▪ convene General Meetings, submit proposals to be considered by the General
Meeting and prepare draft resolutions of the General Meeting in a timely manner,
▪ submit reports of the Management Board on the activities of the Company and the
financial statements, including an opinion and report of the statutory auditor, for the
last financial year, to the General Meeting for the purpose of consideration and
approval,
▪ develop and adopt regulations related to the operations of the Company, unless such
authority has been reserved for any other body of the Company,
▪ prepare draft annual budgets, including the budget of the Company, budgets of
Subsidiaries and the consolidated budget of the capital group of the Company, to be
presented for approval to the Supervisory Board,
▪ fulfil reporting obligations imposed on brokerage houses,
▪ any other matters not reserved for other bodies of the Company.
The Management Board does not have a special competence in the issue and redemption of
XTB shares.
Activities of the Management Board in 2024
In 2024, the Management Board met at 76 meetings and adopted 258 resolutions. These
resolutions covered all areas of activity of the XTB Group. The resolutions concerned, among
others, the adoption of client documentation and a number of internal regulations and
procedures (including Climate Policy, Anti-Mobbing and Anti-Discrimination Policy, Diversity,
Equity and Inclusion Management Policy (“DEI Policy”), Anti-Corruption Policy). The
Management Board took part in the process of selecting an audit company and discussed the
offers submitted by audit companies and issued an assessment for the Supervisory Board
and the Audit Committee regarding the selection of an audit company. In addition, as part of
its work, the Management Board discussed issues related to the activities of the capital group,
including the establishment and acquisition of shares or the increase of the share capital of
subsidiaries. The Management Board read the periodic reports of the risk management
system, the compliance system, the internal audit system, the report on the functioning of the
information technology and security areas of the ICT environment and the management
reports in the field of AML/CFT. The Management Board also discussed and approved the
Company's periodic reports. At monthly meetings, the Management Board also reviewed the
state of court cases and analyzed client complaints. In 2024, the Management Board
convened a general meeting three times and presented the proposed agenda.
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Description of competencies and professional experience of XTB S.A. Management
Board Members
The main information on the education, qualifications and previously held positions of the
members of the Management Board is presented below:
:
Omar Arnaout
Chairman of the Management Board
Omar Arnaout graduated in 2005 with a master’s degree from
the Warsaw School of Economics – Banking and Finance. He
has been associated with the Company since January 2007. In
2007-2009, he held the position of the Sales Dealer. In 2009-
2010 he worked as the deputy director of the Romanian branch
of XTB and in 2010-2012 as deputy director of the Italian branch
of XTB. In 2012-2014 Mr. Omar Arnaout worked as the director
of the foreign branches office at Noble Securities Dom Maklerski
S.A. and in 2014, he also worked as Sales Director and Chairman of the Management Board
of xStore sp. z o.o. In 2014-2016 he held the position of the Retail Sales Director
in XTB Limited in the UK and in 2016 Mr. Omar Arnaout became the regional director of XTB
for Poland, Hungary, Germany and Romania.
Since 10 January 2017, he has been the Chairman of the Management Board of XTB S.A.
without interruption.
Filip Kaczmarzyk
Member of the Management Board in charge of Trading
Filip Kaczmarzyk is a graduate of the Warsaw School of
Economics majoring in Quantitative Methods in Economics and
Information Systems. He started his professional career at XTB
S.A. in 2007 in the Trading Department on the position of Junior
Trader. Since April 2009 he held the position of Deputy Chief
Trader. In November 2010 he began working in the CFH Markets
in London in the Client Support Department. From May 2011 to
May 2015 he worked at Noble Securities SA, initially as the
Director of the OTC Instruments Trading Office, and from November 2012 as the Director of
the Foreign Markets Department. Filip Kaczmarzyk returned to XTB in May 2015 for the
position of the Director of Trading Department.
Since 10 January 2017, he has served continuously as a member of the Management Board
of XTB S.A.
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Paweł Szejko
Chief Financial Officer and Member of the Management Board
at XTB.
Paweł Szejko graduated from the Economy Academy and the
Higher School of Banking in Poznań. Paweł Szejko also studied
at the Aarhus University in Denmark. He has the qualifications of
a Polish statutory auditor and an ACCA certificate in international
finance reporting. Paweł Szejko commenced his professional
career in 2003 in the audit companies (BDO and PwC), auditing
among others, financial institutions, including banks and
investment funds. In 2008-2014 he held the position of finance director and also a member of
the Management Board of P.R.E.S.C.O. GROUP S.A., managing the area of finance in the
capital group, both at the national and international level. In October 2014, Paweł Szejko
joined XTB and he took the position of CFO. He is responsible for financial matters in XTB
group.
Since 28 January 2015, he has served continuously as a member of the Management Board
of XTB S.A.
Since 28.01.2015, he has served continuously as a member of the Management Board of
XTB S.A.
Jakub Kubacki
Member of the Management Board responsible for Legal
Jakub Kubacki graduated in 2009 as a Master of Law from
Koźmiński University, then he completed his training advocate
and in 2013 passed the Bar exam at the District Warsaw Bar
Association he was admitted to the Bar. In 2010 he started his
professional career at XTB in the Legal and Compliance
Department, where since 2012 he has been the Compliance
Officer. From 25 April 2018 he became the Director of the Legal
Department. He specializes in capital market law. Jakub Kubacki
is responsible for legal affairs and internal control in the XTB Group.
Since 10 July 2018, he has served continuously as a member of the Management Board of
XTB S.A.
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Andrzej Przybylski
Member of the Management Board responsible for Risk
Management.
He graduated in 1994 with a master’s degree on Wroclaw
University of Technology and completed doctoral studies in
economics at the Warsaw School of Economics in 2011. Since
1995, Mr. Przybylski has a stockbroker license. Professionally
connected with brokerage houses and offices since 1995 until
1997 with DDM S.A. in Wrocław, then CBM WBK S.A., and until
1998 with Dom Maklerski BMT S.A. From 1998 he worked as a
stockbroker specialist at CDM Pekao S.A. and then since 2002 as a risk management
specialist. From 2007 to 2010 he worked at UniCredit CAIB Poland S.A. as a risk and
compliance manager. From 2010 to 2013 he worked at ING TFI S.S. and ING Investment
Management (Poland) S.A. as a senior specialist in risk management and performance
measurement. From 2013 to 2014 he was the Director of business project part of launching
a brokerage house and an expert on risk management at PGE Dom Maklerski S.A. From
2014 Mr. Przybylski became the Director of the Risk Management Department at XTB.
Since 1 May, 2019, he has served continuously as a member of the Management Board of
XTB S.A.
In the reporting period and until the date of submission of this report, there were no changes
in the composition of the Management Board.
The operation of the Management Board
The Management Board operates on the basis of the Regulations of the Management Board.
Meetings of the Management Board shall be held not less than once a month at the registered
office of the Company or if all members agree, elsewhere on Polish territory. The
Management Board may hold a meeting without being formally convened if all members are
present at the meeting and no one objects to holding the meeting or any of the proposed
items on the agenda. Management Board resolutions are passed by an absolute majority of
votes cast, and in the case of an equal number of votes "for" and "against" the vote of the
Chairman of the Board decides.
Board members may participate in adopting resolutions of the Board by casting their votes in
writing through another member of the Management Board. Casting a vote in writing may not
concern matters introduced to the agenda during the meeting of the Board. Resolutions may
be passed in writing or using means of direct remote communication. The resolution is valid
if all the members of the Board have been notified of the draft resolution.
In accordance with the Articles of Association, the Chairman of the Management Board
supervises the activities of the Management Board and determines the internal division of
tasks and powers among particular members of the Management Board, specifically, the
Chairman of the Management Board may entrust the management of specific departments to
particular members of the Management Board. Furthermore, the Chairman of the
Management Board calls and chairs meetings of the Management Board. Chairman of the
Management Board may authorize other members of the Management Board to convene and
preside over meetings of the Management Board. In the absence of the Chairman of the
Management Board or if the position of the Chairman of the Management Board is vacant,
the meetings of the Management Board are convened by the oldest member of the
Management Board. Additional, special rights of the Chairman of the Management Board in
terms of managing the work of the Management Board may be determined in the Regulations
of the Management Board.
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Two members of the Management Board acting jointly are authorized to make representations
on behalf of the Company.
Shares of the Company and related entitles held by the Members
of the Management Board
The table below presents the total number and nominal value of the Company's shares held
directly by the Company's managing and supervising persons, as at 01 January 2024:
NAME AND
SURNAME
FUNCTION
OWNED
NUMBER OF
ACTIONS
TOTAL NOMINAL
VALUE OF SHARES
(IN PLN)
Omar Arnaout
Chairman of the
Management
Board
30 261
1 513
Filip Kaczmarzyk
Member of the
Management
Board
21 182
1 059 476
Paweł Szejko
Member of the
Management
Board
19 130
957
Jakub Kubacki
Member of the
Management
Board
13 495
675
Andrzej Przybylski
Member of the
Management
Board
2 441
122
During the reporting period and up to the date of this report, there were the following changes
in the ownership of the Company's shares by management and supervisory personnel:
▪ on 25 April 2024, Omar Arnaout subscribed for 20 456 shares of the Company as
part of the incentive program;
▪ on 25 April 2024, Filip Kaczmarzyk subscribed for 14 319 shares of the Company as
part of the incentive program;
▪ on 25 April 2024, Paweł Szejko subscribed for 10 228 shares of the Company as
part of the incentive program;
▪ on 25 April 2024, Jakub Kubacki subscribed for 7 500 shares of the Company as
part of the incentive program;
▪ on 25 April 2024, Andrzej Przybylski subscribed for 4 888 shares of the Company
as part of the incentive program;
▪ on 8 November 2024, Andrzej Przybylski disposed of 1 500 shares of the Company.
The table below presents the total number and nominal value of the Company's shares held
directly by the Company's managing and supervising persons, as at 31 December 2024 and
at the date of this report:
NAME AND
SURNAME
FUNCTION
OWNED
NUMBER OF
ACTIONS
TOTAL
NOMINAL
VALUE OF
SHARES
(IN PLN)
Omar Arnaout
Chairman of the
Management Board
50 717
2 536
Filip Kaczmarzyk
Member of the
Management Board
35 501
1 775
Paweł Szejko
Member of the
Management Board
29 358
1 468
Jakub Kubacki
Member of the
Management Board
20 995
1 050
Andrzej Przybylski
Member of the
Management Board
5 829
291
Managers did not hold any shares or entitlements to shares in the Company as of the end of
the reporting period and as of the date of this report.
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Positions held by the Management Board Members of the issuer
in the Group companies
Below is information on the functions performed by members of the Management Board of
the parent company in the authorities of subordinated entities as at December 31, 2024 and
as at the date of submission of this report:
NAME AND
SURNAME
COMPANY
FUNCTION
Omar Arnaout
XTB Mena Limited
Member of the Management Board
Jakub Kubacki
XTB Mena Limited
Member of the Management Board
Filip Kaczmarzyk
XTB Limited, United
Kingdom
Executive Director of Trading
Andrzej Przybylski
XTB Limited, United Kingdom
Executive Director of SMF3
Members of the Parent Company's Management Board did not receive remuneration in 2024
and 2023 for their functions in the authorities of subordinate units.
Remuneration Policy
According to the internal system of remuneration, employees receive salary for the work
corresponding to the type of work performed and the qualifications required for its
performance, taking into account the quality and quantity of work performed.
Remuneration of the Management Board members
The remuneration model for XTB S.A.'s Management Board Members includes fixed
remuneration, variable remuneration and non-cash benefits. The principles and amount of
remuneration of the Members of the Company's Management Board are determined by the
Supervisory Board. Members of the Management Board receive remuneration on the basis
of employment contracts for an indefinite period.
The remuneration of the members of the Management Board is determined adequately to
their function and adequate to the scale of the company's activities, and consists of:
▪ fixed remuneration – which is part of the total remuneration of the members of
the Management Board, corresponds to the type of work performed by individual
members of the Management Board and the qualifications necessary for its
performance, as well as taking into account the quantity, evaluation and quality of
the work provided. An important factor taken into account is also the extent of the
organisational responsibility of the Board Member concerned. When determining
the amount of fixed remuneration, the Members of the Supervisory Board take into
account the situation on the local labour market in such a way that the level of
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remuneration does not encourage the Members of the Management Board to take
excessive risks in order to obtain the variable component of remuneration;
▪ variable remuneration – represents an annual bonus dependent on the
achievement of management objectives. The variable remuneration depends on
the balanced and risk-adjusted performance of the individual Board Members, as
well as the performance of the Company and the Group.
- The members of the Management Board are informed of the objectives
set and the evaluation principles on which the award and the amount of
the variable remuneration components depend. The variable components
of remuneration depend, inter alia, on the individual's performance, taking
into account the Company's business risks.
- The ratio of the variable remuneration components to the fixed
remuneration components may not exceed 200% with respect to each
Member of the Management Board and, in the case of the Member of the
Management Board responsible for Risk, the ratio may not exceed 100%.
- The payment of variable remuneration components is spread over
tranches, taking into account the long-term interests of the Company. The
entire variable components of remuneration were awarded in XTB's
treasury shares.
- At least 40% of the variable components of remuneration paid in the form
of financial instruments are settled and paid over a period of three to five
years, the period being determined taking into account the business
cycle, the nature and risks of the business and the responsibilities of the
individual concerned. Where the variable remuneration does not exceed
the PLN equivalent of EUR 50 000 and ¼ of the total annual remuneration
of the Board Member, it shall not be deferred. Where the amount of that
person's total remuneration in the previous financial year exceeds the
PLN equivalent of EUR 1 000 000 deferral applies to 60% of the variable
remuneration components.
▪ non-monetary benefits – the remuneration in the form of a non-monetary benefit
granted to the Members of the Management Board is a remuneration that includes:
- pension and retirement plan (PPK);
- additional non-wage benefits, including min. Private medical care, Multisport
card, insurance;
- the use of Company equipment, including a company car, computers,
telephones, as well as access to literature and trade press;
- opportunity to participate in training.
Remuneration in the form of non-cash benefits is also available to other employees of the
Company.
As non-competition agreements have been entered into with the members of the
Management Board, for compliance with this non-competition agreement, the members of
the Management Board are entitled to compensation upon termination of their employment,
the amount of which is set out as follows:
▪ The member of the Management Board - Mr Paweł Szejko – is entitled to
compensation
equal to 50% of the gross remuneration received by the employee prior to the
termination of the employment relationship for a period corresponding to the period
of the non-compete, payable in 12 monthly instalments.
The tables below provide information on the total remuneration payable to the members of
the Executive Board for 2024 and 2023. Fixed remuneration, consisting of base salary,
pension plan (PPK), additional non-cash benefits and variable remuneration. In 2024 and
2023, the members of the Management Board received remuneration on the basis of
employment contracts
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Fixed remuneration
NAME AND SURNAME
FIXED REMUNERATION RECEIVABLE
FROM THE COMPANY IN THE YEAR: (in
thousands PLN)
2024
2023
Omar Arnaout
1 222
1 124
Filip Kaczmarzyk
851
788
Paweł Szejko
626
566
Jakub Kubacki
611
510
Andrzej Przybylski
556
501
Variable remuneration
NAME AND SURNAME
VARIABLE REMUNERATION RECEIVABLE
FROM THE COMPANY IN THE YEAR: (in
thousands PLN)
2024
2023
Omar Arnaout
773
1 059
Filip Kaczmarzyk
541
741
Paweł Szejko
386
529
Jakub Kubacki
309
388
Andrzej Przybylski
275
253
The Company changed the principles of the Remuneration Policy, the Extraordinary General
Meeting adopted the amended Variable Remuneration Policy and the Regulations of the
Incentive Scheme on 31 July 2023. However, the new rules apply to variable salaries paid
from 2022 onwards. Since then, the variable remuneration is awarded in full in the
Company's treasury shares. The above-mentioned regulations were updated by a resolution
of the Extraordinary General Meeting of Shareholders on 12.04.2024. The shares granted
are subject to restrictions on their disposal. The disposition of 40% of the variable
remuneration is restricted for 3 consecutive years. The possibility to freely dispose of further
tranches of granted shares follows the date of publication of the annual report to the WSE
containing the consolidated financial statements for the subsequent financial years following
the year for which the variable remuneration is granted.
A member of the Management Board to whom, as part of the variable remuneration
components, property rights exercised through cash settlement (synthetic shares) have
been granted may make a first cash call to the Company after the grant date, i.e. after the
date on which the derivative financial instrument contract is signed. A further call may be
made after 12 months and a third call after 24 months from the date of the derivative financial
instrument agreement. Subsequent calls may be made 36 months after the conclusion of
the derivative financial instrument contract. The value of each synthetic share shall be equal
to the price of the Company's shares at the close of trading on the Warsaw Stock Exchange
on the seventh day after the date of publication of the report containing the Company's
consolidated financial statements for the preceding financial year or, if there is no such price
on that date, equal to the first closing price published by the WSE after that date. The value
of each synthetic share is invariable over time.
Non-salary benefits accruing to individual board members and key managers include health
benefits, holiday benefits, recreational and sports benefits and Christmas vouchers. In
addition, during the reporting period, board members Filip Kaczmarzyk, Jakub Kubacki had
a company car at their disposal.
Agreements concluded with the management, including
compensation in case of resignation or dismissal
from the position without a material ground or their removal or
dismissal is due to the Company’s merger by acquisition
As at 31 December 2024, and as at the date of publication of this report in the Parent
Company and the Group companies there were no agreements with management providing
for compensation in case of their resignation or dismissal from the position without a material
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reason or if their removal or dismissal is due to merger of the Parent Company by
acquisition.
Remuneration of the Supervisory Board members
The table below provides information on the remuneration due to members of the
Supervisory Board. It consists of fixed remuneration components and non-cash benefits. In
2024 and 2023, the members of the Supervisory Board of the Company received
remuneration by virtue of the appointment relationship. The principles and the amount of
remuneration of the members of the Supervisory Board are determined by the General
Meeting of Shareholders by resolution:
NAME AND SURNAME
FIXED REMUNERATION RECEIVABLE FROM
THE COMPANY IN THE YEAR: (in thousands
PLN)
2024
2023
Jan Byrski
77
27
Jakub Leonkiewicz
64
59
Łukasz Baszczyński
64
60
Bartosz Zabłocki
70
60
Grzegorz Grabowicz
68
59
Katarzyna Dąbrowska
11
-
Ewa Stefaniak
11
-
Information on liabilities arising from pensions
and similar benefits for former members of management,
supervisory and administrative bodies
As at 31 December 2024 there were no liabilities arising from pensions
and similar benefits for former members of management, supervisory or administrative
bodies, as well as no liabilities incurred in relation with these pensions.
Changes in the remuneration policy
On 12 April 2024, the Extraordinary General Meeting of the Company adopted changes to
the Variable Remuneration Award Policy and the Incentive Scheme Regulations for persons
with significant influence on the Company's risk profile.
Assessment of the remuneration policy
The general principles of the remuneration policy are aimed to ensure the coherence of the
system of remuneration and additional benefits for employees with the strategy of long-term
development of the company and taking into account the costs adopted in the financial plan,
while maintaining compliance of risk management and stability of the company.
Additionally, assumptions of the variable components of the remuneration for persons in key
positions, which should strengthen the relationship between the amount of the variable part
of the remuneration and the implementation of long-term company growth, contributes
significantly to the stabilization of the company's operations and its shareholder value
growth.
Evaluation of the remuneration policy is under the Supervisory Board, which exercises
ongoing supervision over the adopted remuneration policy, subjects them to review and
makes recommendations to the Management Board as to possible changes in order to
ensure a competitive level and effectiveness of remunerations, and ensuring their
transparency, compliance with legal regulations and internal justice. Additionally, the
remuneration policy for Members of the Management Board and Members of the
Supervisory Board is subject to adoption by a resolution of the General Meeting adopted by
a simple majority of votes. In addition, the Supervisory Board annually reviews the
application of the Remuneration Policy and prepares a remuneration report.
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Corporate culture and key policies for business conduct
Building a responsible corporate culture and ethics is supported by internal documents, inter
alia:
▪ Articles of Association of XTB S.A.,
▪ Code of Ethics,
▪ Diversity Policy (DEI),
▪ Anti-Mobbing and Anti-Discrimination Policy,
▪ Training Policy,
▪ Anti-Corruption Policy,
▪ Work Regulations,
▪ Staff Policy.
Company's Articles of Association
The current Articles of Association of XTB S.A. were adopted by the Extraordinary General
Meeting of XTB S.A. on 31 July 2023. The current content of the document is available on
the Company's Investor Relations sub-page at:
https://ir.xtb.com/lad-korporacyjny/statut-spolki/
Change in the company's Articles of Association
Amendments to the Company's Articles of Association, in accordance with the provisions of
the Commercial Companies Code, fall within the competence of the General Meeting.
A resolution to amend the Articles of Association is adopted by a three-quarters majority.
A resolution concerning an amendment to the Articles of Association which increases the
benefits of shareholders or depletes the rights granted personally to individual shareholders
pursuant to Article 354 of the Code of Commercial Companies requires the consent of all
the shareholders concerned.
Diversity, Equity and Inclusion Policy
XTB S.A. applies a diversity policy and a policy of equal treatment to all employees of the
company, its authorities and key managers, due to the deep belief that diversity as a
fundamental value of modern society significantly affects the development, competitiveness
and innovation of our organization.
The implementation of the diversity policy is manifested, among others, in the employment
of employees diverse in terms of gender, age, education, qualifications, professional
experience, nationality, ethnicity, religion, religion, non-religiousness, political beliefs,
health, psychosexual orientation, family status, lifestyle, place of residence, form, scope and
basis of employment and ensuring respect, tolerance and equal treatment in the workplace
for all employees, as well as creating a work environment conducive to the use of the above-
mentioned differences for the benefit of the organization.
The diversity policy implemented at XTB S.A. aims to fully utilize the potential of our
employees, their skills, talents, passions, knowledge and qualifications.
XTB creates an organizational culture focused on achieving the company's goals by building
internal teams that are diverse in terms of gender, age and qualifications, which allows for
more effective problem solving, a better working atmosphere, higher creativity of project
teams and effective knowledge sharing.
As part of implementing one of the important aspects of diversity policy, the company
employs students and graduates of universities with various professional profiles for
internships and internships and gives them the opportunity to develop their professional
careers within our organization.
As part of the policy of diversity, XTB S.A. also promotes and supports charitable initiatives
initiated by its employees.
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Managing diversity also consists of including provisions for preventing discrimination
and mobbing as well as other regulations which specify the standards for equal treatment,
protection against violence, harassment or unfair dismissal in the policies and procedures
in place at XTB. The principles of equal treatment in employment are described in the
Company’s internal documents, among others, in the Labor Regulations, and are freely
available to all employees. All employees and associates are required to react if they witness
the exclusion or stigmatization of associates in accordance with the applicable Anonymous
Reporting Procedure.
In the scope of diversification in connection with the selection of XTB S.A. authorities the
Company has implemented the Diversity Policy in relation to the Members of the
Management Board of the Company. The company provides a variety of qualifications and
competences in terms of education, professional experience and the skills of the selected
staff, including the managerial staff, in order to guarantee comprehensive and reliable
performance of the tasks entrusted to it. In addition, as part of the Diversity Policy during
recruitment to the authorities of the Company in XTB S.A. professional qualifications,
reputation, professional experience, predispositions to perform duties within a given position
or function, as well as gender, age, place of origin and education are taken into account.
The members of the Company’s authorities are specialists in various areas of knowledge
and are equipped with varied industry-specific experience which corresponds to the
functions they currently perform. The individual competencies of the members of the
Company’s authorities complement each other in such a manner as to ensure an
appropriate level of collegial management at XTB S.A.
Anti-Corruption Policy
The document is based, among others, on the United Nations Convention against
Corruption and comprehensively addresses the issue, and the system of reporting violations
has been combined with the system implemented by the internal Reporting Procedure to
ensure efficient, independent and objective investigation of incidents.
The Policy identifies areas particularly at risk of corruption:
▪ client relations;
▪ IT area;
▪ selection of suppliers and business partners;
▪ concluding commercial agreements;
▪ sponsorship and charity activities;
▪ employing, remunerating and rewarding employees;
▪ processing of information, including confidential and business secret information;
▪ judicial and administrative decisions.
In the fourth quarter of 2024, training in the field of counteracting corruption and bribery for
newly employed employees was implemented at the XTB SA Headquarters, and a decision
was made to send cyclical alerts to employees identified as particularly vulnerable.
Code of Ethics
The Company has a Code of Ethics that lays down the basic norms, rules of conduct and
values to be observed by all Employees and associates. All Employees of the Company 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 Company acts with due diligence to ensure that the conducted activities
comply with the law and accepted business conduct, which are standards reflected
in applicable binding legislation and internal regulations. Employees adhere to the principles
of social coexistence within the framework of mutual relations, loyalty, honesty and conflict
of interest.
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Other
information
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
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Audit company authorized to audit the financial statements
On February 21, 2024, the Supervisory Board of the Company, acting pursuant to § 19
section 2 letter h) the Articles of Association of the Company and in accordance § 8 sec. 2
letter h) Supervisory Board Rules of XTB, adopted a resolution and entrusted
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k.
based in Warsaw (hereinafter referred to as PWC) to carry out:
▪ audits of individual and consolidated financial statements for the years 2024-2025
and;
▪ reviews of condensed separate and consolidated semi-annual financial statements
for the period6 months ended June 30, 2024 and June 30, 2025 and;
▪ attestation service regarding the storage and protection of the assets of the
Company's clients in accordance with the Regulation of the Minister of Finance of
February 22, 2019 on the procedures and conditions of conduct of investment
firms, banks [...] and the issuance of a report for the year ended December 31,
2024, and December 31, 2025;
▪ attestation service regarding the remuneration report of the Supervisory Board in
accordance with the Act on Public Offering of July 29, 2005 and the issue of
a report for the year ended December 31, 2024, and December 31, 2025.
Selection of PWC in accordance with applicable law, i.e. in particular the Act of May 11,
2017 on statutory auditors [...], and based on internal policies and procedures.
Audit of financial statements
On 8 July 2024, an agreement was concluded between XTB and PwC for:
▪ auditing the financial statements and the consolidated financial statements of the
capital group of which XTB S.A. is the Parent Company for the financial periods
from January 1, 2024 to December 31, 2024, and from January 1, 2025 to
December 31, 2025;
▪ review of the condensed interim financial statements and the condensed interim
consolidated financial statements of the capital group of which XTB S.A. is the
Parent Company for the financial periods from January 1, 2024 to June 30, 2024,
and from January 1, 2025 to June 30, 2025.
▪ verification of the tagging of the annual consolidated financial statements for the
financial period 01 January 2021 to 31 December 2021, with XBRL tags in
accordance with the ESEF Regulation.
Assurance procedures for the safekeeping of client assets
On 30 July 2024, an agreement was signed for:
▪ performance of an assurance service and preparation of an independent statutory
auditor's report covering an assessment of compliance with the Company's client
asset custody requirements during the annual period ended 31 December 2024
and 31 December 2025;
Attestation procedures over the remuneration report
On 30 July 2024, an agreement was signed for:
▪ the implementation of all procedures for the remuneration report for the years
ended 31 December 2024 and 31 December 2025.
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The information on the significant court proceedings, arbitration authority
or public administration authority
As of December 31, 2024 and as at the submission date of this report the Parent company
and its subsidiaries were not a party to any significant proceedings pending before
arbitration authority. The most important of the ongoing proceedings are indicated below.
Court proceedings
The Company and Group companies are parties to several court proceedings
related to the Group’s operations. The proceedings in which the Company and Group
companies appear as defendants are above all related to employees’ claims and clients’
claims. As at the submission date of this report the total value of the claims brought against
the Company and/or the Group Companies amounted to PLN 15.1 million, which consists
of one proceeding on employee claims, with a value of approximately PLN 80 thousand,
seven suits brought by clients with the total value of circa PLN 12.2 million and moreover,
one proceeding regarding the alleged failure to apply financial security measures by the
Company in which the value of the dispute is PLN 2.8 million.
In addition, before the European Union Intellectual Property Office (EUIPO), there is one
action brought by the Company in the scope of invalidity of the conflicting trademarks
"XTRADE" used by Xtrade Europe Ltd.
The most significant proceedings are:
▪ lawsuit dated August 2019 regarding Company’s alleged illegal actions delivered
to the Company in December 2019 – value of the claim is PLN 7 million. The
Management Board finds client’s claims groundless. The only reason for the loss
of the client was his wrong investment decisions. This has been clearly
demonstrated, among others, during the audits of the Polish Financial
Supervision Authority (PFSA) in 2016, in the subsequent correspondence of the
company with the supervisor, and in the expertise of an independent consultancy
company, Roland Berger, which analyzed the client's transaction history. The
analysis confirmed that the client's transactions were not delayed, and the timing
of his orders was even faster than the average for other clients;
▪ lawsuit dated July 2020, delivered to the Company in November 2020 regarding
the alleged failure to apply financial security measures by the Company. Value
of the proceeding is approximately PLN 2.8 million. The damages were to consist
in the Company's failure to apply financial security measures, which lead to
effective appropriation of funds by an employee of the claimant, who was also a
client of the Company. The Company considers the charges made in the suit to
be completely unfounded. In June 2023, the court of first instance dismissed the
lawsuit, finding no material violations on XTB's part. On August 22, 2023, the
plaintiff filed an appeal. In September 2023, the files were transferred to the Court
of Appeal in Warsaw, which delivered the appeal to the holder of the power of
attorney of XTB in March 2024. On 9 April 2024, a response to the appeal was
submitted. The court set the date of the appeal hearing for 10 May 2024, then
the hearing was postponed to 21 June 2024, 9 July 2024 and 9 August 2024,
respectively. At the hearing on 9 August 2024 the court closed the hearing and
gave the parties the floor. The publication of the judgment was postponed until
September 9, 2024, November 8, 2024, and ultimately January 31, 2025. At the
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hearing on 31 January 2025, the judge opened a closed hearing for the third time
and adjourned the proceedings without a deadline.
Administrative and control proceedings
The Company and the Group Companies are party to several control proceedings
related to the Group’s business. The Company believes that below are presented the most
significant among them:
▪ On September 7, 2023, an inspection of the operations of the Company's Czech
branch began by the Czech National Bank (CNB). At the moment of submitting
the report, the inspection was completed. The Company is exercising its due
diligence to implement the post-inspection recommendations.
▪ On October 17, 2023, an inspection by the Office of the Polish Financial
Supervision Authority began, the purpose of which is to verify that the Company's
operations comply with laws, regulations, conditions set forth in permits, fair
trading principles or the interests of principals. At the moment of submitting the
report, the Company implements the post-inspection recommendations.
▪ On February 12, 2024, an inspection of the operations of the subsidiary XTB
International Limited with registered office in Belize by the International
Commission (IFSC), i.e. the authority supervising the capital market in Belize,
started. As at the date of submitting this report, the company implements the
post-inspection recommendations.
▪ On February 14, 2024, an inspection of the operations of the Company's Spanish
branch began by the National Commission for the Securities Market (CMNV) for
AML compliance. As at the date of publication of the report, the company
implements the post-inspection recommendations.
▪ On October 1, 2024, the tax inspection of XTB S.A. initiated by the Head of the
National Revenue Administration ("KAS") began. The scope of control includes
the use of the method of determining the transaction price between XTB S.A. and
related foreign entities recognized by the Head of KAS and resulting from the
APA decision issued by the Head of Kas. The audited period covers: 1 January
2019 - 31 December 2023. At the moment of submitting the report, the tax audit
is ongoing.
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Investor Relations
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Relationships
Table of contents
Letter from the President of the Management Board
Key ESG 2024 events
1. General information
1.1 Basis for the sustainability statement
1.2 Group management and supervision
1.3 Sustainability management
1.4 Strategy, business model and value chain
1.5 Key stakeholders
1.6 Material impacts, opportunities and risks
1.6.1 Double materiality assessment
1.6.2 Material impacts
1.6.3 Material opportunities and risks
1.7 ESRS compliance tables
2. Environment
2.1 Climate change
2.1.1 The XTB Group's climate policy
2.1.2 Fuel and energy consumption
2.1.3. Greenhouse gas emissions
2.2 Compliance of XTB Group's activities with the Taxonomy
2.2.1 Non-financial taxonomy
2.2.2 Financial taxonomy
2.2.3 Minimum Guarantees
3. Society
3.1 Our Employees
3.1.1 Employment structure
3.1.2 Diversity and equality
3.1.3 Working conditions
3.1.4 Staff training and development
3.1.5 Regulatory policies
3.1.6 Work safety and comfort
3.1.7 Incidents and complaints related to human rights
3.2 Consumers and end-users
3.2.1 Clients of the XTB Group
3.2.2 Consumer and end-user policies
3.2.3 Notification channels and remedial actions
4. Governance
4.1 XTB Group characteristics
4.2 Administrative, management and supervisory bodies
4.2.1 XTB S.A.'s Management Board and corporate bodies
4.2.2 Supervisory Board of XTB S.A.
4.3 Corporate culture and ethics
4.4 Risk management and internal control
4.5 Supplier relationship management
4.6 Due diligence statement
Annex 1
- Taxonomy tables
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Sustainability Statement 2024
/ General information
Investor
Relationships
Dear all,
I am pleased to present XTB Group's first sustainability statement prepared
in accordance with the requirements of the CSRD. The drafting of the report and,
above all, the analyses that preceded it, allowed us to gain a fresh perspective
on all our activities while confirming the validity of the decisions we had taken
previously.
At XTB, we provide clients from around the world with innovative financial products
that make their money work for them in many different ways. We are present in more
than a dozen markets, where we already employ more than 1 000 people
and the number of our clients exceeded 1.36 million last year. We already know that
2024 was a record year in many respects and that our business achievements
go hand in hand with ambitious sustainability targets.
In 2024, we updated the ESG Strategy, in which we identified strategic directions
and targets for the areas of environment, society and governance. In line with our
mission and vision, we want to be seen as a trustworthy partner and a provider
of reliable investment technology that supports investors in achieving their ambitions
in the financial markets whether they want to invest actively or passively. This is why
we are constantly expanding our offer by adding new products – last year alone
it was enriched with retirement accounts (IKE account in Poland) and products
for long-term investment under the tax umbrella (ISA account in the UK). Our clients
have also gained faster access to their funds and convenient payments in different
currencies thanks to the eWallet. By combining investing and payments, our clients
have gained the ability to manage their finances on a daily basis in one intuitive app.
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The year 2024 is an intensive time of preparation for the new requirements
and realities of sustainability reporting. During the Double Materiality Assessment,
we analysed the processes and invited our employees and external stakeholders
to the discussion. For the first time, we have calculated the pay gap and the full
carbon footprint at XTB Group scale so that we can effectively manage them
in the future. We strive to set realistic and measurable targets for reducing
our climate and environmental impact, including on the climate and the environment.
We also conducted a climate opportunity and risk analysis, a scenario analysis
and implemented XTB Group's first climate policy. In September 2024, we became
a strategic partner of the Responsible Business Forum in order to co-create
a platform for sharing knowledge, and experiences and building awareness
of sustainability. This is particularly important in view of such a changing regulatory
environment, but also in view of the staggering civilisational challenges
we're currently facing.
XTB's success is built on the commitment, talents and experience of our employees,
and ensuring their comfort and satisfaction is our top priority. This was demonstrated
by the introduction of a Diversity and Equal Treatment Policy and the launch
of a cyclical Health Day, during which we provided access to professional preventive
care examinations in our office. Building employee engagement, we invited
employees to celebrate Earth Day together and introduced "Inner Power" workshops
that allow colleagues to showcase their passions. These are just a selection
of the activities we intend to support and continue in the years to come. XTB is also
about the teams representing us on local markets, who are committed to building
social, environmental and governance awareness and supporting XTB's reporting.
In 2024, they were actively involved in, among other things, the "2 Hours
for the Family" campaign and the "Pink October" and “Movember” cancer prevention
campaign.
We see sustainability as a path that will only produce results if we follow
it consistently. This consistency also manifests itself in the activities of the XTB
Foundation, which has established strategic partnerships with the "Trampki
na giełdzie" ("Sneakers on the Stock Exchange") Foundation and the Polish
Economic Society in order to jointly educate Polish young people about investing
and managing finances on a daily basis.
I cordially invite you to continue reading. On behalf of the entire XTB team, thank
you for the trust you place in us.
Omar Arnaout
CEO of XTB S.A.
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Highlights of 2024:
"Last year was a landmark year for XTB in terms
of the sustainability challenges we faced. Today I can
confirm with confidence that we have achieved
our goals and we will not stop developing this area
of XTB's business further."
Paweł Szejko
Member of the Management Board
for Finance of XTB S.A.
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General
information
Annual Report 2024
/ General Information
1. General information
1.1 Basis for the Sustainability Statement
1.2 Group management and supervision
1.3 Sustainability management
1.4 Strategy, business model and value chain
1.5 Key stakeholders
1.6 Material impacts, opportunities and risks
1.6.1 Double materiality assessment
1.6.2 Material impacts
1.6.3 Material opportunities and risks
1.7 ESRS compliance tables
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1. General information
1.1. Basis for the Sustainability Statement
BP-1
The sustainability statement of XTB Group S.A. (hereinafter: "XTB", "Group", "XTB Group")
for the period from 1 January 2024 to 31 December 2024 has been prepared in accordance
with Chapter 6c of the Accounting Act of 29 September 1994 (Journal of Laws of 2023,
item 120, as amended). It presents information on XTB S.A. Capital Group companies in 2024
and has been prepared on the basis of the ESRS (European Sustainability Reporting
Standards), introduced by the Delegated Regulation 2023/2772 of the European Parliament
and of the Council (EU) of 31 July 2023. The statement has been subject to limited attestation
by the independent auditor, PricewaterhouseCoopers Polska sp. z o.o. Audyt sp.k.,
in accordance with the KSUA 3000 (Z) and KSUA 3002PL standards.
It has not made use of the possibility to omit specific information on intellectual property, know-
how or innovation results, in accordance with ESRS 1 Section 7.7 Classified and sensitive
information and information on intellectual property, know-how or innovation results,
and has not made use of the exemption under Art. 19a sec. 3 and Art. 29a, sec. 3 of Directive
2013/34/EU. Due to the complexity of the sustainability reporting process, XTB Group has
chosen to omit the information set out in the Regulation in accordance with the transition
periods contained therein. Information on the omissions used is disclosed with each ESRS
thematic area.
XTB Group has included in the statement the material impacts, risks and opportunities
associated with direct and indirect business relationships in the upstream and downstream
value chain identified during the 2024 Double materiality assessment.
Reporting limits
The statement presents information for the period from 1 January 2024 to 31 December 2024.
As of 31.12.2024, the XTB Group consisted of 21 entities (13 subsidiaries of XTB S.A.
and 7 foreign branches of XTB S.A.). Moreover in 2020 XTB S.A. appointed XTB Foundation.
The reporting boundaries adopted differ from the boundaries of the consolidated financial
statements and do not include foreign companies of the XTB S.A. Capital Group that were
non-operational or in the process of liquidation on the last day of the year under review.
XTB Foundation
foreign
branches
7
subsidiares
of XTB S.A.
13
parent
company
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As part of the XTB Group Statement, the following were
consolidated:
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BP-2
Comparability of data
Due to the alignment of the sustainability reporting process with EU regulations, the way data
is collected, aggregated and presented has changed. The replacement of XTB's existing
Non-Financial Information Standard (SIN) with the European Sustainability Reporting
Standard (ESRS) has translated into incomparability of the data to the corresponding
reporting periods of previous years, hence we consider 2024 as the base year. Where data
could not be obtained for the calculation of the XTB Group's greenhouse gas emissions,
an estimation method was used, as described in section 2.3.1. Greenhouse gas emissions.
The Group has not deviated from the medium and long-term time horizons set out in ESRS 1
Section 6.4. The measures in the report include value chain data, also estimated using indirect
sources, as described in a dedicated location in the document. Despite the existence
of estimated data in the area of carbon footprint calculations, the Group does not identify
measures and monetary amounts based on a high degree of uncertainty. The methodologies
and perspectives proposed in the Statement will enable maintaining a consistent approach
in future reporting periods to quantitative and qualitative measures.
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1.2. Governance and supervision
in the XTB Group
GOV-1
Management and supervisory bodies
The composition of the bodies of XTB S.A., the parent company for the branches
and companies of XTB S.A., which influences the strategy and operation of the entire XTB
Group, is set out below.
The Management Board of XTB S.A.
The Management Board has an executive function and is responsible for representing
and managing the affairs of XTB S.A. It makes decisions with the best interests
of the Company in mind, drafts development strategies and defines its main business
objectives. Full professional biographies of the Management Board members, a description
of their competences and information on the principles of operation of the Management Board
of XTB S.A. can be found in the Corporate Governance section of the Management Board’s
Statement, chapter Statutory Bodies of XTB.
The highest authority for managing sustainability issues is the Management Board of XTB
S.A., which translates into effective management of material impacts, opportunities and risks.
The direct management and supervision of the area of sustainability was entrusted to Paweł
Szejko, Member of the Management Board for Finance, as reflected in the Internal
Regulations of the Finance and Accounting Department. Board members have the opportunity
to expand their knowledge through training, the expertise of the ESG Team and external
experts in the areas of:
▪ aligning sustainability reporting with the requirements of the CSRD and ESRS
reporting standards;
▪ calculation of greenhouse gas emissions;
▪ financial taxonomy and the non-financial taxonomy of the European Union.
In 2024, as part of his competence development, Member of the Management Board
for Finance, who manage ESG Team, completed a course on sustainable development
reporting standards, requirements and application examples, conducted by the Education
Centre of the Polish Chamber of Statutory Auditors.
The management of the sustainability area is further described in section
1.3. of the Statement.
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In 2024 and as at the date of publication of the Statement,
the composition of the Management Board of XTB S.A.
remained unchanged:
Omar
Arnaout –
President
of the
Manageme
nt Board
Key management competencies related to
sustainability:
▪ directing and supervising the work of the Board and its members,
▪ strategic and operational management of XTB's sales activities,
▪ stakeholder relationship building and after-sales processes,
▪ human resources management and CSR activities,
▪ building responsible management practices and governance.
Filip
Kaczmarzyk
- Member of
the
Managemen
t Board for
Key management competencies related to
sustainability:
▪ quality management of XTB's investment services and
products,
▪ IT infrastructure management,
▪ development of XTB's investment products,
▪ building responsible management practices and governance.
Paweł
Szejko –
Member of
the
Managemen
t Board for
Finance
Key management competences related to
sustainability:
▪ management of the sustainability area,
▪ management of the financial and investor relationship areas of
XTB,
▪ management of the managerial information area and the
circulation of confidential information,
▪ building relationships with XTB S.A. investors,
▪ building responsible management practices and governance,
▪ CSR activities (XTB Foundation).
Andrzej
Przybylski –
Member of the
Management
Board for Risk
Management
Key management competences related to
sustainability:
▪ management and supervision of the risk area,
▪ building responsible management practices and governance,
▪ operational and strategic management of the activities
of XTB S.A.
Jakub
Kubacki –
Member of
the
Management
Key management competences related to
sustainability:
▪ management of compliance and legal areas,
▪ activities related to the Internal Control System (ICS),
▪ support of the Supervision Inspector in overseeing the operation
of the Supervision of Legal Compliance (SLC),
▪ building responsible management practices and governance.
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Supervisory Board of XTB S.A.
The Supervisory Board has ongoing oversight of XTB S.A.'s activities also in the area
of sustainability reporting. In carrying out this duty, the members of the Body are supported
by their wide-ranging competencies and experience gained in many fields. The CVs
and changes in the composition of the Supervisory Board in 2024 are described
in the Management Board Statement, chapter Statutory Bodies of XTB. As of the date
of publication, the composition of the Supervisory Board of XTB S.A. was as follows:
Aleksander
Chłopecki –
Chairman of
the
Supervisory
Board
Key competencies:
▪ extensive knowledge of financial markets,
▪ professional experience in commercial law,
▪ membership of supervisory boards of public companies.
Ewa
Stefaniak –
Member of
the
Supervisory
Key competencies:
▪ accounting and controlling.
Bartosz
Zabłocki –
Member of
the
Supervisory
Board
Key competencies:
▪ compliance and legal,
▪ governance.
Katarzyna
Dąbrowska –
Member of
the
Supervisory
Board
Key competencies:
▪ economics, finance and investment,
▪ management and marketing.
Grzegorz
Grabowicz –
Member of
the
Supervisory
Key competencies:
▪ accounting, finance,
▪ financial control and audit (certified auditor).
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As at the balance sheet date of 31.12.2024, the position of the Chairman of the Supervisory
Board was held by Mr Jan Byrski, who, in accordance with current report No. 1/2025, resigned
from his position with effect from 15.01.2025. As of 16.01.2025 (RB No. 3/2025),
Mr Aleksander Chłopecki took up the position of the Chairman of the Supervisory Board.
1.3. Sustainability management
The highest authority for managing sustainability issues is the Management Board of XTB
S.A. Within the organisational structures, the direct management of the area has been
entrusted to Paweł Szejko, Member of the Board of Management for Finance of XTB.
He manages and supervises the work of the ESG Team established within the organisational
structures of XTB S.A. and consults and presents the results of the work to the other members
of the Management Board.
In an effort to integrate sustainability into XTB's operational and strategic activities,
environmental, management and social criteria are reviewed by the Management Board
during ongoing management activities. Sustainability and impact management topics
are addressed at Board meetings as required, at least quarterly.
Key competencies:
▪ financial innovation law (FinTech),
▪ payment, banking and insurance markets,
▪ legal protection of information,
▪ administrative proceedings and consultancy.
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Governance and supervision structure
of the sustainability area
The area of sustainability is subject to ongoing and cyclical reviews:
▪ on several occasions per month, during the ESG Team's operational reviews
with the Management Board Member for Finance, who manages the area
of sustainability;
▪ at least quarterly, as a part of the XTB S.A. Management Board meeting;
▪ in accordance with current needs during individual meetings with members
of the Management Board responsible for a specific area of XTB's business;
▪ during selected meetings of the Supervisory Board or the Audit Committee
of XTB S.A.
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Table 1. Scope of responsibility of XTB S.A.'s bodies.
The Management Board of XTB S.A.
Supervisory Board of XTB S.A.
Setting directions, priorities and objectives
for the area of sustainability.
Supervision of the development direction,
priorities and objectives for the area of
sustainability.
Approval and supervision of the work of
the sustainability area.
Supervision of the sustainability reporting
process.
Ensuring sustainability reporting
compliance with legal requirements.
Monitoring XTB's sustainability activities.
Adoption and monitoring of the
implementation of the ESG Strategy.
All other tasks and responsibilities resulting
from the incumbent law, the Articles of
Association and other XTB S.A. corporate
documents.
Approval of sustainability area policies and
procedures.
All other tasks and responsibilities resulting
from the incumbent law, the Articles of
Association and other XTB S.A. corporate
documents.
Commitment of the Management Board and Supervisory Board of XTB S.A.
to the activities of the sustainability area in 2024 and up to the date
of publication:
▪ members of XTB S.A.'s Management Board took part in a Stakeholder Opinion
Survey;
▪ in-depth interviews were conducted with members of the Supervisory Board of XTB
S.A. as part of the Double Materiality Assessment;
▪ the results of the Stakeholder Survey and the Double Materiality Assessment were
presented to the Board for verification and validation;
▪ the ESG Strategy 2024-2027 was consulted and approved with Board members;
▪ the Board was consulted on emerging corporate policies and documents;
▪ direct consultation with Board members on ESG topics was conducted
in accordance with their division of competencies and responsibilities;
▪ Board members attended a workshop on greenhouse gas emissions carried out
in collaboration with an external expert;
▪ Board members attended a workshop on diversity and a webinar on inclusive
language (Diversity & Inclusion);
▪ the member of the Management Board for Finance received training to improve their
competences in the area of sustainability;
▪ one member of the Supervisory Board completed the postgraduate course
on "Professional Supervisory Board", where, among other things, he had
the opportunity to discuss sustainability issues;
▪ as of the beginning of 2025, the Director for Sustainability presented a summary
of the 2024 ESG activities at the XTB S.A. Audit Committee meeting and discussed
the results of the Double Materiality Assessment with the identified areas
of sustainability reporting for 2024.
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GOV-3 Incentive programmes for Company bodies
In 2024, the variable part of the remuneration of the members of the Management Board
of XTB S.A. was made conditional on the implementation of the ESG Strategy 2024-2027.
In addition to the above, no financial incentives linked to sustainability issues are applied
to members of the Management Board of XTB S.A. or the Supervisory Board of XTB.
1.4. Strategy, business model and value chain
SBM-1
XTB S.A. is a Polish brokerage house operating in the FinTech sector, listed on the Warsaw
Stock Exchange. It heads the international XTB S.A. Group, which offers investors from
all over the world constant and immediate access to international financial markets through
its proprietary online investment platform and mobile application.
For more than 20 years, we have based our business model on building solutions to meet
our clients' investment objectives through instant access to financial markets from around
the world. This happens with the help of our investment platform and application, which
are our key technology products that help us reach clients from all over the world.
The business model focusing on people as recipients of XTB's services corresponds closely
with the directions and objectives of the ESG strategy, which we describe further
in the Statement.
In our business, we place great emphasis on geographic diversification of revenues,
consistently pursuing a global brand-building strategy based on new capital group entities.
The recipients of our offer are individual and institutional clients from all over the world. XTB
Group's activities are regulated and subject to supervision by the competent authorities in the
markets in which it operates, including in EU countries under the so-called single European
passport.
Our ambition is to be the provider of a universal investment app offering clients easy, smart
and efficient ways to trade, invest and save while having instant access to their accumulated
funds. We combine our activities with financial education for investors and young people,
where we are increasingly making our presence felt. There were no significant changes
to XTB Group's business model in the reporting year.
From 2020 onwards, the XTB Foundation operates within the Group, with the help of which
we implement the objectives of the XTB Group ESG Strategy.
The object of the XTB Foundation's activities is, in particular:
▪ raising economic, financial and new technology awareness and knowledge,
▪ scientific and research activities and promotion of solutions developed as a part
of XTB Capital Group's operations;
▪ supporting and organising all initiatives related to the promotion of financial
institutions and new technologies;
▪ acting in the field of corporate social responsibility, sustainability;
▪ promotion of education and equal opportunities for development;
▪ initiating and supporting the activities of XTB Capital Group employees;
▪ charitable and social activities.
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TRUST – We offer over 20 years of experience in the investment industry,
high quality of our services and competitive terms of employment.
As a result, we are already trusted by more than one million clients
and more than a thousand employees and associates worldwide.
We are listed on the Polish Stock Exchange and regulated by the world's
largest financial market supervisors. We build a secure technological
base for our clients' investments and stable employment conditions
for our employees.
SUPPORT – We employ experts who are available for our clients 24/7,
five days a week. We share knowledge with investors through published
educational materials, but we also try to support the youth of Polish
schools with the help of the XTB Foundation in building their investment
knowledge. XTB employees are offered flexible employment terms and
access to training, encouraged to lead healthy lifestyles and share their
passions during internal Inner Power workshops.
TECHNOLOGY – We focus on quality, and we are best when it comes
to technology knowledge. Thanks to our experts, we are developing our
proprietary xStation platform and expanding our investment offering.
Over the past quarters, we have opened up to the needs of passive
investors and adjusted the offered services to support their needs
at every stage of their investment. We secure our IT infrastructure to
ensure the continuity of our services.
Business strategy and ESG
A responsible and modern business cannot function without incorporating ESG criteria into
its operations. As a fast-growing FinTech that understands the definition of innovation,
we identify the need to integrate sustainability into business objectives and integrate them
together. We started our journey in 2021 with the development of the first ESG Strategy.
Mission
Our mission is to provide clients around the world with access
to an advanced investment platform, professional service and
comprehensive financial education. We strive for sustainability
and excellence in service delivery, building trust and long-term
relationships with our clients to help them succeed in the
financial markets.
Vision
Our vision is to be a leading provider of investment products,
renowned for innovation, transparency and excellent client
service. We want to be seen as a trusted partner, enabling our
clients to achieve financial goals by providing an all-in-one
platform, knowledge and support needed to invest effectively,
with respect for sustainability.
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We integrate ESG in business
Responsible practices enable us to meet the strategic business objectives of the XTB Group
• Responsible management practices
• Legal and regulated activities
• Development of technology and investment product
portfolio
• Financial education
• Transparent communication
• Responsible marketing
• Fair competition
• Risk management
• Business ethics
• Human rights and competitive employment conditions
• Mature organisational culture
• Staff development and competence building
• Responsible payment practices
• Diversity and flexibility
We are strengthening our activities in the markets
of Central and Eastern Europe and Western Europe,
where we are already present
We are expanding into new markets, including those
in Latin America and Asia
We are developing the institutional business segment
with the help of X Open Hub Sp. z o.o.
We are expanding the Group's range of products
and services and developing new technologies
We are growing through mergers, acquisitions of other
entities and joint ventures
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Activities in the area of the three pillars of sustainability
ENVIRONMENT
SOCIAL RESPONSIBILITY
GOVERNANCE
• we support the rational management
of resources in the workplace;
• we strive for responsible
management of electro-waste;
• for the first time, we calculated the
organisation's full carbon footprint;
• we have identified the key
environmental and climate-related
impacts, opportunities and risks
• we engage in environmental action
as part of our employee volunteering
hours.
• we are developing XTB's
products and services;
• we provide workspace for more
than a thousand people from local
communities around the world;
• we engage in dialogue through, inter
alia, an annual employee satisfaction
study, surveys and in-depth
interviews with the community
representatives as a part
of the Stakeholder Survey;
• we provide instant access to financial
markets from around the world;
• we support financial education;
• we develop the activities of the XTB
Foundation, which conducts
educational activities for young
people;
• we employ experts and support their
development.
• we introduce responsible business
and management practices;
• the activities from the ESG area is
managed by the Member of the
Management Board for Finance;
• we have established an ESG Team
within the organisational structure
of XTB S.A.;
• we communicate with shareholders,
the market, regulators and financial
market supervisors;
• we improve internal regulations
and procedures;
• we have units responsible for internal
audit, compliance and risk
management;
• we are one of the largest listed online
brokers;
• we are subject to financial
supervision in the international
financial markets, including KNF,
FCA, DFSA, CySEC, Bappebti
Indonesia and SCA.
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ENVIRONMENT AND CLIMATE AREA
We are committed to sustainability through a responsible approach to the management
of electro-waste, environmental education of employees, effective resource management and
measures to enable the setting of greenhouse gas reduction targets within the XTB Group.
OBJECTIVES
Responsible management of electro-waste in the XTB Group.
Calculation of greenhouse gas emissions target in three scopes.
Implementation of XTB Group's climate change impact management system.
ACTIVITIES DURING THE REPORTING PERIOD:
▪ we have identified the impacts, opportunities and risks of the environment
and climate area;
▪ we developed and implemented the first XTB Group Climate Policy;
▪ we organised training for XTB Head Office employees on greenhouse gas
emissions;
▪ we have started the process of identifying and recalculating greenhouse gas
emissions;
▪ for the first time, we undertook to calculate XTB Group's full carbon footprint;
▪ we have updated the Equipment Procurement and Management Procedure
by adding provisions for the management of electro-waste;
▪ we have introduced special signs in the office space to encourage employees
to manage resources rationally;
▪ we updated our internal educational programme "Natural Investment" and invited
XTB Group companies to participate;
▪ we carried out educational mailings as a part of the "Natural Investment" programme;
▪ we organised a cleaning-up activity in the Kabaty forest in Warsaw, clothes
exchange as a part of our "Zero Waste" campaign and participated in a campaign
to collect electro-waste and batteries together with Elektroeko and UNEP/GRID
Warsaw.
AREA OF SOCIAL RESPONSIBILITY
We strive for social sustainability by creating a safe and inspiring working environment,
building sustainable social relationships, actively dialoguing with stakeholders and offering
services and products that meet client expectations.
OBJECTIVES
Updating remuneration policies at XTB S.A. Head Office, while measuring
and monitoring the Gender Pay Gap indicator for the entire Group.
Creating a safe and inclusive working environment for XTB S.A. Group employees.
Intensification of the educational and social activities of the XTB Foundation.
ACTIVITIES DURING THE REPORTING PERIOD:
▪ we carried out a survey and in-depth interviews as a part of the Stakeholder Survey
and Double Materiality Assessment;
▪ we have identified the impacts, opportunities and risks of the social area;
▪ we have started preparing a professional ESG service to be closer
to our stakeholders (expected date is mid-2025);
We have implemented the ESG Strategy
2024-2027
and identified strategic
directions and objectives for each area
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▪ we have started work on the development of an XTB quarterly performance
evaluation for a uniform remuneration policy for XTB Head Office employees;
▪ For the first time, we undertook to identify the pay gap for the entire XTB Capital
Group;
▪ we provided a space for our employees to share their passions at the “Inner Power”
workshop;
▪ we organised examinations and consultations for employees on the occasion
of XTB's regular Health Day celebrations;
▪ we organised health checks and workshops for our employees as part of cancer
prevention;
▪ once again, we organised flu vaccinations for our employees;
▪ for the subsequent year in a row, we took part in the "Two Hours for the Family"
campaign, for the first time, all Group companies participated;
▪ we organised first aid training for our employees;
▪ we held a workshop on equality and inclusive language as a part of Diversity
& Inclusion;
▪ as a part of the XTB Foundation, we undertook, among other things, to support
wards of orphanages, organised a food collection for residents affected by the flood
and supported an animal shelter;
▪ the XTB Foundation has entered into a partnership with "Sneakers on the Stock
Exchange" (pol. "Trampki na giełdzie") and is committed to creating educational
programmes for high school students;
▪ the XTB's Human Resources team once again conducted a Satisfaction Survey
among employees across the XTB Group;
▪ we have implemented an Anti-Mobbing and Anti-Discrimination Policy
and a Diversity Policy.
MANAGEMENT AREA
We are committed to sustainability and building long-term value through transparent and
responsible management of environmental, social and governance aspects at XTB S.A.
Group.
OBJECTIVES
Implementation of a comprehensive ESG approach to governance, taking into
account environmental, social and management aspects.
Inclusion of ESG risks in the internal Risk Management System of the XTB S.A.
Capital Group.
ACTIVITIES DURING THE REPORTING PERIOD:
▪ we have identified the impacts, opportunities and risks of the governance area;
▪ we have aligned the sustainability reporting process with ESRS standards;
▪ we have implemented a uniform Anti-Corruption Policy for XTB S.A. with a clearly
indicated channel for reporting violations;
▪ we have started the process of aligning ESG risks with the XTB S.A.'s internal risk
management system.
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Impact on strategy, business model
and value chain
One of XTB Group's key stakeholder groups is the clients to whom we target
our offering. Identifying their needs for investment portfolio diversification,
in 2024 we expanded our offering by developing technology, the app and our
trading platform. The area of sustainability did not determine the shape of the
XTB Group's product portfolio, but supported the development of the business
through e.g.:
▪ setting coherent strategic directions for business development while
taking into account the supportive role of ESG;
▪ strengthening dialogue (Double Materiality Assessment)
and identifying stakeholder needs;
▪ supporting staff development and innovation through flexible work
mode (where possible) giving them space to manage their time
and tasks conveniently;
▪ taking care of the well-being and comfort of employees – introducing
a cyclical Health Day, supporting employees' passions and interests
and promoting a healthy lifestyle;
▪ introduction of ratings expanding the XTB application functionality.
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Core products
and services
R
a
w
m
at
eri
al
s
Sh
are
s
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XTB Group offers approx.
6,500
investment products which
can be classified into three groups:
Group 1
investment
products
Group 2
passive
investing
Group 3
finance
management
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As part of the investment oering, 2024 XTB's portfolio included:
CFDs (Contracts For Difference)
A CFD is a contract between two parties, usually referred to as a "buyer" and a "seller", regarding
the movement of the price of a given asset. CFDs are a type of over-the-counter derivative.
It is important to note that CFDs are executed with leverage.
Group 1.
Shares
Shares are equity securities that give holders certain corporate and property rights (e.g. the right
to participate in the company's general meeting, dividends, participation in the distribution
of assets in the event of the company's liquidation). The subject of organized trading are shares
without a material form. Shares can be characterised by high stock price volatility, both
in the short and long term. XTB offers clients the opportunity to invest in more than 3,500 shares
of companies listed on 16 of the world's largest stock exchanges.
ETP (Exchange Traded Products)
ETPs are a group of investment products listed on stock exchanges, of which ETFs
(investment funds whose units are listed on regulated markets) are the best known. ETFs
allow investment in shares, stock indices or bonds, while ETPs additionally invest
in commodities, precious metals or cryptocurrencies. The essence of an ETF is to mirror
the return of a reference index by purchasing financial instruments that are part of that
index (physical replication) or by using derivatives based on the index (synthetic
replication). XTB offers clients the opportunity to invest in more than 1,350 ETFs.
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Relationships
XTB's passive investing/saving portfolio in 2024 included:
Investment Plans
XTB Investment Plans is a solution dedicated
to passive investing that allows you to build
an investment portfolio based on ETFs at a low
cost. Thanks to the broad market exposure,
the investor can achieve a market rate of return
with a relatively small commitment of time and
energy. The Investment Plans allow you
to create your own portfolio of ETFs from as
little as PLN 50. XTB offers nearly 350 different
ETFs to gain exposure to entire markets,
industries or geographical areas.
Retirement & investment products
In 2024, we introduced a retirement product
in Poland - the Individual Retirement Account (IKE).
In the UK, we implemented a solution dedicated
to long-term savings - the Individual Savings
Account (ISA).In an IKE account, the client has
the option to invest in more than 4,000 stocks and
ETFs. In addition, all free funds earn interest on it.
As part of the ISA account, XTB offers UK clients
a variant of the Flexible Cash and Stocks & Shares
ISAs, which allows account holders to withdraw
and re-deposit funds within one tax year without
affecting the annual contribution limit.
Interest on free funds
XTB pays clients interest on uninvested funds held
in their accounts. The interest rate, which
is the basis for determining the amount of interest,
is calculated on a daily basis and the interest itself
is paid cyclically during the five working days.
Interest on the investor's free funds is activated
automatically, and there are no minimum
or maximum limits on the amount of free funds.
Interest rates on free funds are variable and can be
changed weekly.
Group 2.
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Within the segment of funds handling, XTB's 2024 portfolio included:
Group 3.
Handling of funds
Virtual wallet with multi-currency card (eWallet)
XTB offers clients a virtual wallet with a card that supports cashless in-store payments,
mobile transactions and contactless cash withdrawals from ATMs around the world. The
eWallet service allows clients to maintain accounts in seven currencies: EUR, USD, GBP,
PLN, HUF, RON and CZK, as well as fast and free transfers of funds between accounts.
The eWallet service provides clients with instant access to their funds and payments
with a Mastercard-licensed card issued by DiPocket UAB, an Electronic Money Institution
registered with the Bank of Lithuania. The eWallet service is currently available for clients in
Poland, Czech Republic, Portugal, Romania, Slovakia, Germany and France.
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At the end of March 2024, the XTB Social service was launched to allow users in selected
markets to receive alerts on the trades of selected traders and to have an overview of their
portfolios and key statistics on the trades of the people they were observing while ensuring
full anonymisation. In June 2024, the Company decided to suspend this service
in the European Union following the Financial Supervision Authority statement of 29 May
regarding the conditions for the provision of social trading services by investment firms.
In the coming periods, after an in-depth review of this statement, XTB will make a decision
on the further implementation of the XTB Social service and its future shape.
Product plans
In subsequent periods, the passive investment offer will be enriched with pension products -
IKZE accounts (Individual Retirement Security Accounts) in Poland. We see the potential
for further development in the long-term investment segment, therefore, the pension product
offer will also be developed in other global markets, e.g. the PEA product (Plan d'Épargne
en Actions) in France. Options and cryptocurrencies are also planned for introduction in 2025.
Environmental and social aspects are not a dominant factor in designing the product offer.
Nevertheless, XTB's offer includes financial instruments (e.g. ETFs) enabling investments
in entities that are climate-conscious or entities classified in indices that take into account
ESG criteria. In 2023, the Company added information on the ESG rating for most
of the securities of companies in the offer and for ETF instruments to its investment platform.
In 2024 we offered more than 78 ETFs, which provide diversified exposure to stocks or bonds
of companies with high ESG ratings (3 and above) with reference to a specific benchmark.
Benchmarking the ESG ETFs involves removal of the companies that do not meet the ESG
criteria set out in the index methodology from a broader index (the so-called parent index).
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Markets served of XTB S.A. Group
As at the balance sheet date of 31.12.2024, XTB Group operated in the following countries:
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Table 2. Number of employees employed full-time divided between particular units
of XTB S.A. as of 31.12.2024.
Company/
Branch
Name
Country
Number
of employees
Company
XTB S.A.
Poland
703
Branch
XTB S.A. Organizačni Složka
Czech
Republic
33
Branch
XTB S.A. Succursale Française
France
26
Branch
XTB S.A. German Branch
Germany
22
Branch
XTB S.A. Organizačna Zložka
Slovakia
17
Branch
XTB S.A. Sucursal em Portugal
Portugal
20
Branch
XTB S.A. Sucursal en Espana
Spain
20
Branch
XTB S.A. Varsovia Sucursala
Bucuresti
Romania
14
Company
XTB Services Limited
Cyprus
8
Company
XTB Limited
Cyprus
2
Company
XTB Agente de Valores SpA
Chile
75
Company
XTB Limited
United
Kingdom
32
Company
XTB MENA Limited
UAE
32
Company
XTB International Limited
Belize
3
Company
PT XTB Indonesia Berjangka
Indonesia
7
Company
X Open Hub Sp. z o.o.
Poland
1
TOTAL STAFF
1 015
In order to avoid double counting of employees working simultaneously in several companies
within the XTB Group the assumption was made that the employee's employment status
and residence were dominant, and the employment contract was considered dominant over
other forms of cooperation.
XTB Group revenue structure
XTB Group offers investment solutions to more than one million clients globally. With more
than 20 years of experience in the industry, XTB's competitive advantage comes from its
knowledge, professionalism and ability to make innovative but responsible business
decisions. We create the Polish investment market by providing opportunities for our clients
and supporting the achievement of their investment goals.
69%
OF GROUP EMPLOYEES
WORK AT XTB HEADQUARTERS
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XTB Group's business segments
Main business segments and characteristics of their clients
CLI
EN
TS
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1.5. Key stakeholders
SBM-2
Since XTB's inception, stakeholder feedback has shaped our business, helping to develop our investment offering and motivating the Company to continue to grow. In relation to the different
groups of identified stakeholders, we recognise the different needs and opinions that are reflected in our operational and strategic activities. The collected opinions were analysed during
the Stakeholder Opinion Survey and the Double Materiality Assessment performed in 2024, which were presented to and accepted by the Management Board of XTB S.A.
We aim to build value for XTB's stakeholders through the activities we carry out across the different perspectives of our business, seeking to grow while respecting the needs of those involved.
OUR STAKEHOLDERS
Clients
retail and institutional
clients
Employees
employees and
associates of all XTB
Group subsidiaries
Market environment
branch organisations
suppliers, business
partners in local markets
Social environment
people interested in
financial education,
potential clients, social
partners, institutions
supporting cultural and
sporting events
universities and schools,
the XTB Foundation
Capital market
representatives
shareholders, individual
and institutional
investors in XTB S.A.,
the Warsaw Stock
Exchange, analysts and
rating agencies
Regulatory
environment
supervisory authorities,
i.e. FSA, local
supervisors in the
relevant markets
Media representatives
regional, national and
international sector
media
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Table 3. Key XTB Group stakeholder groups
MAIN CATEGORIES
OF STAKEHOLDERS
DETAIL
MAIN DIALOGUE METHODS
AND COMMUNICATION CHANNELS
EXAMPLES OF ENGAGEMENT METHODS
PURPOSE OF THE
ENGAGEMENT
Individual and
institutional clients
All retail
and institutional
clients
▪ Customer Service Centre
▪ Hotline and chatbot
▪ Mailings (e-mail)
▪ xStation application
▪ XTB's offer and product availability
▪ Webinars and educational material
▪ Advertising and promotional
activities
▪ Website
▪ Social media
▪ Surveys
▪ xStation application and platform
▪ Expert webinars on the YouTube
channel
▪ Educational material provided
▪ Articles on social media
▪ New products on offer from XTB
▪ Marketing campaigns and advertising
▪ Activation of existing
clients
▪ Acquisition of new clients
▪ Building trust in the XTB
brand
▪ Promoting investment
knowledge
Employees
and associates
All employees
and associates
regardless of the form
of cooperation with XTB
▪ Cooperation with employee
representatives
▪ Internal communication (mailings,
intranet)
▪ Direct meetings and evaluations
▪ Direct contact with the
Management Board
▪ Procedures and regulations
▪ Messages in the office space
▪ Employee surveys
▪ "Inner Power" series of internal
meetings
▪ Pro-worker initiatives
▪ Employee volunteering
▪ Integration events
▪ Opportunity to test XTB products
▪ Meetings with employee
representatives
▪ Communications via Intranet
▪ Annual employee satisfaction survey
▪ Thematic and sports workshops
"Inner Power"
▪ Celebration of “Earth Day” and
“Health Day” at XTB
▪ Health Day at XTB
▪ Commitment to the #2h4family
campaign
▪ Departmental integrations and
company-wide events
▪ Inviting employees to testing of XTB
technical solutions
▪ Getting to know and
analysing the opinions
and recommendations
of employee
representatives.
Integrating comments
into strategic processes
and decisions. Tailoring
the training to employees'
needs and supporting
the development of their
competences.
▪ Reinforcing satisfaction
and improving comfort
at work.
▪ Building awareness,
developing positive
attitudes and habits.
Media representatives
Representatives of the
sector and local media
▪ Press releases
▪ Direct contact with PR personnel
▪ Ongoing contact and answers to
queries
▪ Articles written by XTB employees
▪ Promoting the XTB brand
and building awareness
of XTB's activities.
▪ Ensuring access
to a direct, reliable
and trustworthy source
of information.
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Regulatory environment
The supervisory
authorities, i.e. FSA, local
supervisors in the relevant
markets
▪ Reports to the FSA
▪ Exchange of letters with the
authorities: FSA, Financial
Ombudsman, UOKiK
▪ Transparent communication and
reliable cooperation
▪ Action in compliance with the law
▪ Recurring reports sent to the FSA on
various areas of XTB S.A.'s
operations
▪ Transparency and responsiveness
▪ Building transparent
communication
with regulators
and supervisors
▪ Fulfilment of legal
obligations
Social environment
People interested in
financial education, our
potential clients, social
partners, institutions
supporting cultural and
sports events, universities
and schools, XTB
Foundation
▪ Stakeholder Opinion Survey
as a part of the Double
Materiality Assessment
▪ Product, investor relationships and
ESG websites
▪ Advertising and promotional
activities
▪ Social media
▪ Educational activities
▪ Pro-social campaigns
▪ Sponsorship
▪ Partnerships
▪ Participation in HR fairs
▪ Stakeholder survey questionnaire
▪ XTB Investing Masterclass
conference
▪ XTB IT Academy
▪ Support for the Koszalin University
of Technology Young Investors
Competition
▪ Webinars and training
▪ Participation in the Job Festival
– Jobicon Trade Fair
▪ Participation in the IT Job Fair
▪ Involvement in charity events,
e.g. supporting WOŚP
and donating gadgets for auctions
▪ Cooperation with KSW MMA
▪ Getting to know
the preferences
and expectations
of potential clients
▪ Adapting XTB's offering
to meet clients' needs.
▪ Undertaking strategic
partnerships.
▪ Searching for talent
in the labour market.
Market environment
Sector organisations,
suppliers, business
partners in local markets
▪ Participation in trade fairs
▪ Direct contact
▪ Advertising and promotional
activities
▪ Meetings, sector events and
webinars
▪ E-mail
▪ Digital Investing Revolution
conference in London
▪ GeeCON trade fair etc.
▪ CocoaHeads Kraków
▪ Partnership within the 4Developers
technology festival
▪ Building lasting business
relationships.
▪ Exchange of knowledge
and experience.
▪ Promoting and building
trust in the XTB brand.
Capital market
representatives
Shareholders, individual
and institutional investors
of XTB S.A., the Warsaw
Stock Exchange, analysts
and rating agencies
▪ Current and periodic reporting
▪ Transparent communication
▪ Broadcasts of General Meetings
(e-General Meetings)
▪ Investor conferences
▪ Investor materials
▪ Interviews and meetings
with Board members
▪ Investor relationships website
▪ Partnerships
▪ Current and periodic reports
▪ Investor presentations
▪ Investor's calendar
▪ Cooperation with the Association
of Individual Investors
▪ Partnership within XTB Wallstreet
▪ Accommodating shareholder
guidance
in creating XTB's policies
▪ Tailoring reporting
to shareholders' needs
▪ Building shareholders' trust.
▪ Carrying out due diligence
reporting and compliance
with legal obligations
▪ Transparency
in communication
with investors
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1.6. Material impacts, opportunities and risks
1.6.1. Double Materiality Assessment
IRO-1 / G1 IRO-1 / E1 IRO-1
In preparation for our obligation to report in accordance with the CSRD, European ESRS
standards and due diligence rules, we began the process of aligning sustainability reporting
with the new regulatory requirements in early 2024. In 2024, we conducted the first Double
Materiality Assessment in accordance with the methodology recommended in the ESRS
standard content. The input parameters were the identification of key stakeholder groups,
processes and the value chain that allowed to structure the process and, based
on the structure of the ESRS standards, become the guideline for the Study.
The double materiality assessment was divided into five stages:
During the survey, we focused on the overall operations of the XTB Group. A stakeholder
dialogue was conducted at all stages to identify topics for analysis (Stakeholder Surveys)
and to assess impacts, opportunities and risks.
Step 1: Understanding of the context of the organisation and identifying topics
for analysis
The preparatory stage included:
▪ an overview of the company's basic information,
▪ an analysis of XTB Group's business environment,
▪ an analysis of current sustainability practices,
▪ mapping of the value chain,
▪ identification and description of the key stakeholder group.
Step 2: Cross-sectional Stakeholder Survey
The stakeholder survey was in the form of an online questionnaire. The study group included:
▪ XTB Group employees,
▪ members of the XTB S.A. Supervisory Board,
▪ XTB clients,
▪ representatives of other stakeholders (suppliers or business partners/ local
communities and/or social partners/ media representatives/ shareholders
and investors).
The selection of questions and the group of stakeholders invited to the survey was preceded
by a preparatory workshop dedicated to mapping stakeholders and the value chain in terms
of mutual influences between them and the Group. In order to get the full perspective
of the stakeholders surveyed and as a complement to the survey research, we conducted two
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rounds of in-depth interviews. The first round included selected addressees of the online
survey, the second round took place after the E, S and G area workshops and included key
representatives of XTB S.A. branches and subsidiaries.
As the most relevant ESG issues for the XTB Group, invited stakeholders most frequently
identified during the survey:
In the area of ENVIRONMENT and CLIMATE:
▪ for stakeholders in general – responsible management of electro-waste
and minimising negative impacts on climate change;
▪ for employees – responsible management of electro-waste and minimising negative
impacts on climate change;
▪ for suppliers – reducing greenhouse gas emissions and sustainable ICT.
In the SOCIAL area:
▪ for stakeholders in general – security and confidentiality of personal data, effective
communication with employees and quality of service and client satisfaction levels;
▪ for employees – security and confidentiality of personal data and effective
communication with employees;
▪ for Suppliers – effective communication with employees.
In the area of MANAGEMENT:
▪ for stakeholders – business ethics, legal and regulatory compliance, anti-corruption
practices and counteracting corruption, bribery and money laundering. The
importance of these areas is highlighted in the responses of each stakeholder group;
▪ for clients – fair competition, anti-corruption, anti-bribery and anti-money laundering
and business ethics.
Among the important topics for the Group, stakeholders also identified the Group's
involvement in educational activities (both raising awareness of environmental issues among
employees and activities regarding financial management and aimed at children and young
people). Among the suggestions of the interviewed entities, the topic of greater involvement
of the Group in charitable and social actions (e.g. planting a forest, picking up waste in public
places, etc.) often came up.
The results of the Stakeholder Survey have directly influenced the current shape of the ESG
Strategy, helping to set development directions dedicated to the areas of environment, society
and governance, and objectives that will respond to identified stakeholder needs. They also
influenced the decision to intensify the activities of the XTB Foundation, especially in the area
of financial education.
Step 3: Preliminary double materiality assessment: Assessment of impacts, risks
and opportunities
To analyse the double materiality of sustainability issues, a series of workshops were held on
assessing the actual and potential impacts on people and the environment, and the Group's
risks and opportunities related to the social, environmental and organisational governance
issues identified in the ESRS standard. The 5 workshops related to areas E, S and G were
attended by managers and specialists from XTB's key areas and experts from the consultancy
companies, resulting in the identification of material ESG impacts, risks and opportunities
from a corporate perspective.
Steps 4 and 5: Selection of relevant topics and validation of the materiality matrix
In examining the materiality of an impact, we considered the likelihood of the impact
in question occurring by time horizon (for potential impacts) and the severity of the impact
in question (taking into account the scale, extent and nature (reversibility) of the negative
effects). Financial materiality was assessed based on the probability of the risk/opportunity
by time horizon and the scale of the financial effects on the company should the risk and/or
opportunity materialise. Appropriate cut-off thresholds were adopted to establish
the materiality of the topics.
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XTB S.A.'s Board members were involved in deciding on the final materiality
of the sustainability area topics and approved the final list of material topics that formed
the basis for identifying the ESRS disclosure list. The identified impacts, opportunities and
risks formed the basis of the updated ESG Strategy 2024-2027. The risks have been aligned
with the internal Risk Management System and will subsequently be incorporated into it.
An annual review of the effects of the materiality study will be carried out by the XTB ESG
Team, with results updated as required.
In 2024, based on the results of the Dual Materiality Study, we conducted a climate scenario
analysis of the identified climate risk based on the TCFD guidelines:
Physical risk - Risk of external events (business continuity risk) due to the possibility
of sudden, extreme weather events in the locations of some companies
and branches of the XTB Group.
Two scenarios were constructed that present probable, hypothetical development paths,
dependent on global emission paths and the resulting average temperature increase: the "2°C
or lower" scenario and the "4°C" scenario. These scenarios were selected due to the best
data availability. Key assumptions regarding the scenario analysis methodology and risk
assessment are presented in Chapter II Environment of this Statement.
1.6.2. Material impacts
SBM-3
The Study identified 11 material reportable topics on which XTB Group has a material impact
(impact materiality) or which materially affect XTB Group's business (financial materiality).
In order to identify the areas that, in our view, require the greatest commitment and increased
intensity of action, we have categorised the identified topics into 3 groups of varying
management priority:
I. High priority – topics of highest management priority against which appropriate
resources should be allocated; both new topics (previously unmanaged but relevant
to the organisation) and topics previously identified as crucial from the organisation's
perspective.
II. Moderate priority – covering important topics for which organisational resources
should be increased, but which are not the highest priority for the organisation.
III. Standard priority – covering topics already known and managed by the XTB Group
that are not core to the Group's business.
Analysing the impacts, opportunities and risks identified, we rate the resilience of our business
model as high, the ability to exploit opportunities alone as satisfactory.
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Table 4. Material topics and impacts for XTB Group arising from the Double Materiality Assessment.
Topic
identified in
the materiality
assessment
Description of
impact
Type of impact:
Negative
(actual and
potential)
Type of impact:
Positive
(actual and
potential)
Impact on
humans or
the
environment
Link to strategy
and business
model
Current and
anticipated
effects
Time perspective of
the impact and
action taken
Priority
Place of
origin of
the
impact
E1: CLIMATE
Climate change
mitigation.
Energy
The current impact
of climate change
on the XTB Group's
operations can be
observed particularly
in certain locations of
XTB's global offices,
which are particularly
at risk of extreme
weather events. XTB
Group's impact on
climate change is
related to its core
business based on the
use of IT infrastructure
(including servers) and
the expansion of XTB
Group's operations.
This involves
increased electricity
consumption and may
result in an increase in
the Group's
greenhouse gas
emissions.
Actual negative
impact
regarding
energy
consumption
of servers
as part of their
standard use
process.
Potential
negative impact
that may occur
as a result of
increasing
emissions from
activities due
to increased
electricity
consumption.
Potential
positive impact
that may result
from optimizing
energy
consumption.
Activity of the
XTB Group's
activities related
to the use of IT
infrastructure
and energy
consumption
has an impact
on the
environment.
The impacts are
linked to the XTB
Group's Business
Strategy
and business model
in the areas:
– expansion and
development of XTB
activities;
- ESG Strategy
objectives and
actions.
At the time of
publication of
the Statement,
the perceptible
effects of the
identified
impact are not
identified.
Anticipated
effects may
include an
increase in
energy
consumption
and the
severity
of extreme
weather events
at certain
Group office
locations.
We identify the
occurrence of the
impact in the short,
medium and long
term of our business.
Our activities:
– successive
replacement of the IT
infrastructure at the
end of its life cycle
with newer, more
energy-efficient
infrastructure;
– using RES energy
where possible;
– aiming to calculate
the full carbon
footprint of an activity,
which will enable to
observe emissions
trends of XTB Group
over several years.
Standar
d
priority
Own
operation
s
S1: OWN WORKFORCE
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Working
conditions
The XTB Group has
a strong, direct and
multifaceted impact
on employment
security, working time,
adequate pay,
dialogue, freedom
of association and the
work-life balance of its
own workforce (by
which we mean
employees under
employment contract
and coworkers
employed under civil
law contracts).
Potential
negative impact
that may occur
in the event
of deterioration
of employment
conditions.
Actual negative
impact through
differences in IT
employee
salaries relative
to other
employees,
resulting from
the
characteristics
of salary
formation
in the IT
industry.
Actual negative
impact of intra-
corporate
communication
that does not
keep up
with the
dynamic
development of
the XTB Group.
Potential
negative impact
that may occur
in the event of a
possible
reduction in the
number of
Actual positive
impact through
implemented
policies,
employee
regulations and
activities such
as cyclical
employee
assessment,
annual
employee
satisfaction
survey or work-
life balance
initiatives.
Actual positive
impact through
flexible
employment
conditions.
Actual positive
impact of
competitive
employment
conditions and
plans to update
the
remuneration
policy.
Actual positive
impact through
planned and
implemented
communication
activities.
We identify
a material
impact on our
own workforce
through:
– terms and
conditions of
employment
offered;
– flexible
working time
and mode;
– competitive
terms and
conditions of
employment;
– diversified
remuneration
rules for IT
employees and
other employees
(as a result of
the
remuneration
characteristics
of the IT
industry);
– on the one
hand, the actual
and planned
communication
activities, on the
other hand, the
insufficiently
rapid
development of
intra-corporate
communication
in relation to the
growth
dynamics of the
XTB Group;
The impacts are
linked to XTB's
Business Strategy
and ESG Strategy
through:
– business
objectives for the
development of the
Group's activities;
– the ESG
Strategy's objectives
of aligning
remuneration
principles across the
XTB Group and
structuring
employee policies.
XTB's impact
can translate,
on the one
hand, into
increased
employee
satisfaction,
strengthening
XTB's
corporate
culture and
position as an
employer, and
attracting talent
from the labour
market. On the
other hand, a
negative impact
can lead to a
loss of talent,
increased
turnover, an
outflow of
knowledge,
experience and
know-how from
the
organisation.
We identify the
impact in the short,
medium and long
term of our business.
Actions:
– actions taken
towards
harmonisation of
remuneration rules;
– competency audit
in the organisation;
- flexible working
conditions in most
positions (ability to
adjust start times and
working mode);
– annual employee
satisfaction survey;
– cyclical employee
appraisals;
– policies and
procedures
implemented and
improved;
– pro-employee
measures taken;
– employee
representatives
appointed;
– projects of the
Human Capital
Management
department, (e.g.
harmonisation of
remuneration rules
and pay gap
analysis);
– implementation of
an internal
communication
High
priority
Own
operation
s
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employee
representatives.
Potential
negative impact
that may occur
in the event
of insufficient
internal
regulations
regarding work-
life balance.
Actual positive
impact through
the activities of
a group of
selected
employee
representatives.
Actual positive
impact through
flexible
employment
conditions, the
ability to adjust
start times and
work mode
(remote/hybrid/s
tationary).
– employee
representatives;
– work-life
balance
measures.
platform and
informational
mailings;
– return to cyclical
meetings with the
CEO to discuss the
company's strategic
directions;
– stakeholder survey
as part of a double
materiality
assessment;
– "Helping Hand"
well-being platform.
Equal
treatment and
equal
opportunities
The XTB Group's
impact in the area of
equal treatment and
equal opportunities is
based
on the measures taken
to equalise
opportunities and
manage the pay gap,
the management of
the training area, but
also implementing a
uniform anti-mobbing
policy
and the diversity
policy.
Potential
negative impact
that could occur
if the pay gap
between women
and men
widens.
Potential
negative impact
that could occur
if there
is insufficient
training.
Actual positive
impact through
actions aimed
at equalizing
opportunities,
initiating
the process
of verifying
salaries in terms
of the pay gap.
Real positive
impact through
organized
training, the
possibility
of co-financing
employee
training and
actions
improving the
area of training.
We influence
XTB employees
and associates
through
activities aimed
at equalizing
opportunities,
identifying the
pay gap, funding
and access
to training,
introducing
the Anti-
Mobbing and
Anti-
Discrimination
Policy, activities
and introducing
the DEI Policy.
The impacts of this
area were translated
into the ESG
Strategy's objectives
of creating an anti-
mobbing policy, a
DEI policy and
identifying the wage
gap;
Identified
positive
impacts can
strengthen the
organisational
culture, and
translate into
increased
employee
competence,
greater
employee
comfort,
reduced
personnel
turnover and
increased
talent retention
in the
organisation.
On the other
hand, identified
negative
We identify the
impact in the short,
medium and long
term of our business.
Actions:
– work on calculating
the wage gap;
– review of
remuneration policy
and start of process
of building a process
of regular
assessment;
– training preference
survey carried out;
– clear rules for
subsidising training,
courses and
postgraduate studies;
– internal training
organised by the
training department.
High
priority
Own
operation
s
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impacts, e.g. a
potential
increase in
the pay gap
may translate
into
an increase
in the sense
of inequality,
negative
assessments
in the annual
employee
satisfaction
survey and
increased
employee
turnover.
– subsidised courses,
studies and training
at the employee's
request;
– whistleblowing
channel implemented
and communicated
to employees;
– Management Board
training in the area of
diversity;
– employee training
in inclusive language;
– invitation to female
members of company
bodies (Supervisory
Board of XTB S.A.).
– training on Diversity
& Inclusion;
– DEI policy
implemented
- Training policy
implemented.
ESRS S4: CONSUMERS AND END-USERS
Impact of
information
on consumers
or end-users
Social inclusion
of consumers
or end-users
XTB Group, as
a provider of financial
products and services,
influences clients
through the quality
of communication,
offerings and
documentation,
the level and
accessibility of
Customer Service,
the communication
channels made
available to clients,
educational materials
and activities,
Potential
negative impact
that may occur
in the event
of insufficient
listening
to the opinions
of XTB clients.
Potential
negative impact
that may occur
as a result
of insufficient
investment
knowledge
Actual positive
impact through
shared reporting
channels for
clients and
support from
the Customer
Service
department.
Actual positive
impact through
high level of
communication
with the client,
complete client
We influence
our clients
through XTB's
investment
product offering,
free educational
materials and
transparency in
communication.
The impacts are
reflected in the XTB
Group's Business
Strategy and ESG
Strategy objectives
and are driven by its
business model.
Failure to listen
sufficiently to
client feedback
can lead to a
mismatch
between
offerings and
market needs
and a loss of
clients.
Measures to
improve the
quality of
communication,
offerings and
client
We identify the
impact in the short,
medium and long
term of our business.
Activities:
– communication
channels made
available,
e.g. helpline;
– qualified Customer
Service department;
– analysis of client
feedback and
High
priority
Own
operations
Downstream
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decisions supported
by the analysis
of client opinions,
and access to
information.
of clients,
misunderstandin
g the specifics
of investment
products that
carry the risk
of loss.
Potential
negative impact
that may result
from
communication
bearing the
characteristics
of
greenwashing.
documentation
and shared
educational
materials.
Actual positive
impact through
building media
coverage based
on real actions
supported
by evidence
and the actions
of the XTB
Foundation
in the area of
financial and
investment
education.
relationships
can result in a
strengthening
of trust in the
XTB brand, the
acquisition of
new clients and
fewer
complaints.
presentation
of proposals;
– a channel for
irregularities and
complaints made
available;
Activities:
– transparent
presentation
of products
and XTB services;
– regulated activities
in compliance with
the law;
– complete client
documentation;
– free educational
materials, economic
commentary by XTB
experts;
– action-only
social media
communication;
– liaising with the
communications
department as part
of the ongoing
communication.
ESRS G1: CONDUCT OF BUSINESS
Management
of relationships
with suppliers,
including
payment
practices
The XTB Group
influences
relationships with
business partners
through timely
payments.
Non-identified
Actual positive
impact through
building
cooperation
with responsible
suppliers
and business
partners
and no delays
in payments.
The XTB Group
influences its
suppliers
by reducing
payment delays.
Building good
relationships
with XTB's
business
partners.
Practices resulting
from XTB's
responsible
governance.
Standa
rd
priority
Upstream
Own
operations
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Corruption
and bribery
As a financial services
provider, XTB Group
operates in a highly
regulated industry
where transparency
and integrity are
paramount. We
influence the anti-
corruption area
through the internal
regulations
implemented, the
whistleblowing
process and the
implementation of an
anti-corruption policy.
The potential impact in
the form of the
occurrence of
corruption could
undermine confidence
in XTB's operations
among clients and
investors.
Potential
negative impact
that may result
from possible
corruption
cases.
Actual positive
impact through
implemented
internal
regulations,
the process
of reporting
violations,
the
establishment
of units
responsible
for audit and
compliance, and
the implemented
Anti-Corruption
Policy at XTB
S.A.
The area of anti-
corruption
affects XTB
Group
stakeholders.
The impact
stems from
both the internal
regulations
implemented,
the
whistleblowing
process, the
appointment
of an audit
and compliance
unit and the
implementation
of an anti-
corruption
policy.
A potential
negative impact
may materialise
if a case of
corruption
occurs.
The impact of this
area is reflected in
the 2024-2027 ESG
Strategy objective
to create an anti-
corruption policy.
This target was met
in the last quarter
of 2024.
If cases
of corruption
occurring,
XTB's
reputation and
confidence in
the XTB brand
could be
damaged.
Failure to
comply with
these
regulations can
result in hefty
fines, sanctions
and even the
revocation of
operating
licences.
On the other
hand, a well-
secured anti-
corruption
action process
minimises the
risk of
breaches.
Actions:
– implementation of
XTB S.A.'s Anti-
Corruption Policy
– whistle-blowing
procedure and
incident register;
– internal audit,
compliance and legal
departments
overseeing
processes
and the timeliness
of procedures;
– planned update
of the Code of Ethics.
Standa
rd
priority
Upstream
Own
operations
Downstream
Other: Data
protection.
The XTB Group
processes data of
many groups of its
stakeholders in the
course of its activities,
including as a provider
of investment products
and services
processing personal
data of its clients. This
impact is secured by
implemented data
protection security
systems (including
Potential
negative impact
that may occur
as a result of
data processing
where there is
a risk of leakage
or breach of
personal data.
Actual positive
impact through
implemented
data protection
security systems
(including
personal data),
creation of data
back-ups in
the event of
unforeseen
circumstances,
diversification of
There is an
impact on
people as
a result of the
data protection
safeguards
implemented.
There may
be a potential
negative impact
in the event of
data leakage.
The impact is
related to XTB
Group's business
model, which
identifies offering
investment products
and investment
solutions to our
clients as the core
of XTB Group's
business, which
clearly involves data
processing.
In the event of
a data leak, the
impact results
in damage to
XTB's image,
disrupting client
trust in XTB.
Data processed
by the XTB
Group is
adequately
protected in
the event of
Activities:
– modern and
updated network
and system security;
– training
and information
campaigns among
employees.
Modera
te
priority
Upstream
Own
operations
Downstream
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personal data), back-
ups created or
diversification of XTB's
locations.
IT infrastructure
locations.
unforeseen
circumstances.
Other: Quality
of reporting
XTB S.A., as a public
interest entity listed
on the Warsaw Stock
Exchange, has
a sustainability
reporting obligation.
The XTB Group's
influence manifests
itself through the
quality
of its reporting process
and the reports
it publishes.
Potential
negative impact
that may result
from insufficient
ESG reporting.
Real positive
impact through
a transparent
reporting
process in
accordance
with the law.
The XTB Group
impacts people
through
the quality
of its reporting
process, its
compliance with
legislation, its
completeness
and its
transparency.
The impact is linked
to the ESG Strategy,
which underpins the
activities of the
XTB Group's
sustainability area.
XTB S.A. has
been compliant
with its
sustainability
reporting
obligation since
2020. Failure to
comply with
the law can
translate into
reputational
damage and
penalties.
Activities:
– keeping abreast of
legal developments
and trends;
– adapting and
improving the
sustainability
reporting process
in advance;
– working with
qualified advisors in
the reporting area;
– independent
auditor's
investigation.
– employing qualified
staff.
Modera
te
priority
Upstream
Own
operations
Downstream
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SBM-3 / E1 SBM-3 / S1 SBM-3 / S4 SBM-3
1.6.3. Material opportunities and risks
Table 5. Material opportunities and risks in the environment and climate area
Topic identified in the
materiality
assessment
Description of material
risk/opportunity
Link to
strategy and
business
model
Current and
anticipated
effects
Individual resilience and
risk/opportunity management
Current and
anticipated financial
effects
Location
where the
risk/opportunity
arises
Climate change
Risk of external events
(business continuity) due to
the possibility of sudden
extreme weather events at the
locations of some XTB Group
companies and branches
(violent storms, earthquakes,
hurricanes, floods). A locally
significant risk due to staff
safety and the potential for
possible loss of IT
infrastructure components.
The risk does
not arise from
XTB's strategy
and business
model.
Identifying a
target in the
ESG Strategy
for the creation
of a climate
policy.
No impact on
the business
model, value
chain or
decision-making
process.
i. flexible forms of employment,
especially when the threat of remote
working is identified;
ii. diversification of the locations of
XTB offices and branches;
iii. diversification of the locations of
XTB's IT infrastructure;
iv. XTB's main IT infrastructure
located in places not at risk from
extreme weather events;
v. security of IT equipment in offices
where there is a higher probability of
risk due to their location;
vi. implementation of the XTB Group
Climate Policy.
No current financial
effects. The Group is
unable to estimate
the financial effects of
the risks.
Own operations
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Climate change
Opportunity to increase
competitiveness and develop
reputation and business
resilience through climate
change action taken.
The
opportunity
stems from
the
assumptions
made in the
ESG Strategy.
No influence on
strategy,
business model,
value chain and
decision-making.
i. implementation of the XTB Group
Climate Policy
ii. promoting and building awareness
of resource efficiency
iii. digitalization of documents
iv. use of energy from RES
v. responsible management of IT
infrastructure and electro-waste
No current financial
effects. The Group is
unable to estimate
the financial impact of
the opportunity.
Own operations
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Table 6. Material opportunities and risks of the society area
Topic identified in the
materiality assessment
Description of material
risk/opportunity
Link to strategy
and business
model
Current and
anticipated effects
Risk/opportunity management
Current and
anticipated
financial effects
Location where
the
risk/opportunity
arises
Own workforce
Human resource and
reputational risks relating
to the loss of qualified staff
and increased personnel
turnover as a result of, for
example, insufficient
attention to employee
welfare and work-life
balance, insufficient training
or insufficient internal
regulations on mobbing and
discrimination.
The risk does not
arise from XTB's
strategy and
business model.
Identification of
strategic objectives
for implementing
a transparent
Remuneration Policy,
cyclical first aid
training and
introduction
of a DEI policy
(completed).
No impact on the
business model. The
possible impact of
risk on the
organisation's own
workforce and
decision-making
process.
i. competitive employment conditions
and benefits (including access to the
well-being platform "Helping-Hand");
ii. flexible forms of employment;
iii. annual employee satisfaction
survey;
iv. crew representatives representing
the interests of employees before the
Management Board;
v. pro-employee initiatives promoting
preventive health care and healthy
habits.
No current
financial effects.
The Group is
unable to estimate
the financial
effects of the
risks.
Own operations
Own workforce
An opportunity to attract
talent, strengthen the
organisational culture and
increase XTB's
attractiveness as an
employer through pro-
employee activities
implemented within the
ESG area.
The opportunity
stems from
actions
implemented as
part of the ESG
Strategy.
No influence on
strategy, business
model, value chain
and decision-making.
i. creating a modern and
developmental working environment
ii. ensuring competitive employment
conditions
iii. flexible forms of employment
iv. HR procedures and policies
v. activities and initiatives undertaken
vi. implementation of ESG strategies
No current
financial effects.
The Group is
unable to estimate
the financial
impact of the
opportunity.
Own operations
Consumers and
end-users
Product (client complaints)
and reputational risks
associated with client
complaints as a result of, for
example, the failure of
The risk does not
arise from XTB's
strategy and
business model.
No influence on
strategy and business
model. The possible
impact of risk on
value chain
i. continuous monitoring of IT systems
and infrastructure;
ii. clear and transparent and legally
compliant provisions of XTB
documents and agreements;
No current
financial effects.
The Group is
unable to estimate
the financial
Own operations
Downstream
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XTB's services,
misunderstanding of the
provisions of XTB's
documents and agreements
(despite their completeness,
availability and
transparency) or taking
investment risks despite
insufficient investment
preparation (e.g. by
investing in leveraged
financial instruments).
stakeholders and
organisational
decision-making.
iii. educational materials made
available to build investment
knowledge and awareness of
investment products and the risks they
entail;
iv. MiFID survey determining the
appropriateness of services to clients'
knowledge, experience and
preferences and their risk appetite.
effects of the
risks.
Consumers and
end-users
Risk of reputational
damage, loss of clients and
key business partners
associated with a reduction
in the quality of XTB
Group's services as a result
of deteriorating employment
conditions, ineffective
employee policies resulting
in increased turnover, loss
of talent and key
employees.
The risk does not
arise from XTB's
strategy and
business model.
No influence on
strategy and business
model. The possible
impact
of risk on value chain
stakeholders and
organisational
decision-making.
i. competitive employment conditions
and benefits (including access to the
"Helping-Hand" well-being platform);
ii. flexible forms of employment;
iii. annual employee satisfaction
survey;
iv. crew representatives representing
the interests of employees before the
Management Board;
v. pro-employee initiatives promoting
preventive health care and healthy
habits;
No current
financial effects.
The Group is
unable to estimate
the financial
effects of the
risks.
Own operations
Downstream
Consumers and
end-users
An opportunity to
strengthen XTB's brand and
competitive advantage by
building a position as a
responsible entity that stays
ahead of market and
regulatory trends, cares
about the quality of services
and security of transactions,
and takes into account
particularly critical client
feedback.
The opportunity
does not stem
from XTB's
strategy and
business model.
No influence on
strategy, business
model,
value chain and
decision-making.
i. developing XTB's technology
and innovation
ii. following trends and making
responsible management decisions
iii. hiring qualified experts
iv. monitoring the quality of services
and products
v. collecting client feedback
vi. sharing financial and investment
knowledge
No current
financial effects.
The Group is
unable to estimate
the financial
impact of the
opportunity.
Own operations
Downstream
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Consumers and
end-users
An opportunity to attract
new clients, improve XTB
Group's image and build a
competitive advantage by
enhancing investment
products with ESG
solutions. Activating clients
by combining investment
activities with charitable and
social activities.
The opportunity
does not stem
from XTB's
strategy and
business model.
No influence on
strategy and business
model. The possible
impact of risk on
value chain
stakeholders and
organisational
decision-making.
i. Sustainalytics rating: Morning Star
ii. plans for implementation of the ESG
website
iii. activities of the XTB Foundation
No current
financial effects.
The Group is
unable to estimate
the financial
effects of the
risks.
Own operations
Downstream
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Table 7. Material management opportunities and risks
Topic identified in the
materiality assessment
Description of material
risk/opportunity
Relation with
the strategy
and business
model
Current and
anticipated
effects
Risk/opportunity management
Current and
anticipated
financial effects
Location where
the
risk/opportunity
arises
Business conduct
Risk of abuse related to the
possibility
of occurrence of corruption cases in
the XTB Group.
The risk does
not arise from
XTB's strategy
and business
model.
No impact of
risk on strategy,
business model.
Possible impact
on the value
chain and
decision-making
process.
i. Internal regulations on corruption;
ii. implementation of Anti-Corruption
Policy;
iii. building a responsible organizational
culture based on values and good
practices.
No current
financial effects.
The Group is
unable to
estimate the
financial effects
of the risks.
Own operations
Business conduct
Security risk due to the possibility of
leakage of personal data of XTB
Group stakeholders of which it is the
controller as a consequence of a
cybercrime, human error or system
error.
The risk does
not arise from
XTB's strategy
and business
model.
No impact of
risk on strategy,
business model
and decision-
making.
Possible impact
on value chain
stakeholders.
i. network and data security and sealing
in place;
ii. breach notification procedure;
iii. internal awareness campaigns;
vi. GDPR compliant activities.
No current
financial effects.
The Group is
unable to
estimate the
financial effects
of the risks.
Own operations
Business conduct
Legal and reporting risks arising from
the failure to adapt XTB Group's
processes to the highly volatile
legislative environment, regulator
decisions on environmental, social
and governance activities, the lack of
knowledge of ESG practices and
ethics among XTB Group's partners,
and the failure to properly fulfil
reporting obligations.
The risk does
not arise from
XTB's strategy
and business
model.
No impact of
risk on strategy,
business model.
Possible impact
on the value
chain
and the
decision-making
process.
i. carrying out Double Materiality
Assessment;
ii. adapting reporting to EU ESRS
standards;
iii. keeping abreast of regulations and
changes in legislation;
iv. selecting partners of good repute;
v. assessing partners in ongoing
business relationships.
No current
financial effects.
The Group is
unable to
estimate the
financial effects
of the risks.
Own operations
Business conduct
Operational risk as a result of various
types of litigation and proceedings
before supervisory authorities, e.g.:
related to data leakage and breaches
of personal data protection, audits
and potential penalties imposed by
The risk does
not arise from
XTB's strategy
and business
model.
No impact of
risk on strategy,
business model,
value chain and
decision-making
process.
i. data safeguards in place;
ii. operations in compliance with laws
and good practices;
iii. transparent communication
with the supervisor;
iv. timeliness in meeting obligations.
No current
financial effects.
The Group is
unable to
estimate the
Own operations
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the FSA, UOKIK, negative outcome
of court proceedings.
financial effects
of the risks.
Business conduct
Product (client complaints) and
reputation risks related to the specific
nature of the investment products
offered by XTB, their negative
reputation in the market (e.g.
leveraged financial instruments) and
negative comments in forums and on
the web, due to the high investment
risk and the high probability of client
loss they entail.
Risks arising
from the
characteristics
of XTB S.A.'s
investment
products
which are part
of the
Company's
business
model.
No impact of
risk on strategy,
business model
and decision-
making.
Possible impact
on value chain
stakeholders.
i. provision of information material;
ii. refined, transparent client documents;
iii. MiFID survey determining the
appropriateness of services to clients'
knowledge, experience and preferences
and their risk appetite.
No current
financial effects.
The Group is
unable to
estimate the
financial effects
of the risks.
Own operations
Downstream
Business conduct
An opportunity to improve the quality
of management processes, increase
the flexibility and resilience of XTB
Group's operations through effective
management of the ESG area,
management of risks
and opportunities, implementation of
internal policies and procedures.
Opportunity
arising from
the ESG
Strategy.
No impact on
strategy,
business model
and value chain.
Possible impact
on decision-
making.
i. ESG strategy
ii. creation of an ESG Team
iii. empowerment of ESG governance at
the Management Board level
iv. double materiality assessment vs.
preparation for reporting under the CSRD
No current
financial effects.
The Group is
unable to
estimate the
financial effects
of the risks.
Own operations
Business conduct
2. An opportunity to improve
the sustainability reporting process
by monitoring and adapting it to
ongoing legal changes and
implementing best reporting
practices.
3. The
opportunity
does not arise
from XTB's
strategy and
business
model.
4. No
influence on
strategy,
business model,
value chain and
decision-
making.
i. preparation for reporting under the
CSRD
ii. cooperation with ESG area advisors
iii. double materiality assessment
5. No
current financial
effects. The
Group is unable
to estimate the
financial effects
of the risks.
6. Own
operations
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Business conduct
Opportunity for increased investor
interest and access to preferential
insurance terms as a result of proper
management of the ESG area.
The
opportunity
does not arise
from XTB's
strategy and
business
model.
Lack of impact
on strategy,
business model
and decision-
making process.
Possible impact
on the value
chain.
i. ESG strategy
ii. Risk of abuse related to the possibility
of occurrence of corruption cases in the
XTB Group.
planned implementation of ESG website
iii. ESG area activities and initiatives
iv. sustainability reporting
No current
financial effects.
The Group is
unable to
estimate the
financial effects
of the risks.
Own operations
Business conduct
An opportunity to increase the
efficiency, quality of XTB's services
and products by building a valuable,
diverse organisational culture based
on respect and ethical values.
The
opportunity
stems from the
assumptions
made within
the ESG
Strategy.
Lack of impact
on strategy,
business model,
value chain and
decision-making
process.
i. creation of diverse project teams
ii. creation of spaces to share knowledge
and passions of employees
iii. HR procedures and policies
iv. activities and initiatives undertaken
v. implementation of the ESG strategy
vi. signing of the Diversity Charter
vii. training in the DEI area
No current
financial effects.
The Group is
unable to
estimate the
financial impact
of the
opportunity.
Own operations
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1.7. ESRS compliance tables
IRO-2 Table 8. List of disclosure requirements met when preparing a sustainability statement following a materiality assessment
Disclosure no.
Name of disclosure
Chapter Statements
ESRS 2: General disclosure
BP-1
General basis for making sustainability statements
1.1.
BP-2
Disclosure in relation to special circumstances
1.1.
GOV-1
The role of the administrative, management and supervisory bodies
1.2. , 4.2.1.
GOV-2
Information provided to the entity's administrative, management and supervisory bodies and the sustainability issues
they undertake
1.3.
GOV-3
Mainstreaming sustainability-related outcomes into incentive schemes.
1.3.
GOV-4
Due diligence statement
4.6.
GOV-5
Risk management and internal controls over sustainability reporting
4.5.
SBM-1
Strategy, business model and value chain
1.4. , 2.1.
SBM-2
Stakeholder interests and opinions
1.5. , 3.2.
SBM-3
Material impacts, risks and opportunities and their interrelationship with the strategy and the business model
1.6., 3.1. , 3.2.
IRO-1
Description of processes to identify and assess material impacts, material risks and material opportunities
1.6.
IRO-2
ESRS disclosure requirements covered by the entity's sustainability statement
1.7.
ESRS E1: Climate change
E1-1
Transformation plan for climate change mitigation
2.1.
E1-2
Policies related to climate change mitigation and adaptation
2.1.1.
E1-3
Action and resources in relation to climate policy
2.1.1.
E1-4
Climate change mitigation and adaptation objectives
2.1.3.
E1-5
Energy consumption and energy mix
2.1.2.
E1-6
Gross Scope 1, 2 and 3 greenhouse gas emissions and total greenhouse gas emissions
2.1.3.
E1-7
Greenhouse gas removal and reduction
of greenhouse gas emissions projects financed through carbon credits
2.1.3.
E1-8
Internal setting of greenhouse gas emission charges
2.1.3.
E1-9
Anticipated financial effects from material physical risks and risks of
transition and potential climate-related opportunities
2.1.3.
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ESRS E2: Pollution
IRO-1 Description of processes for identifying and assessing significant impacts, significant risks and significant opportunities
1.6.
ESRS E3: Water and marine resources
.
IRO-1 Description of processes for identifying and assessing significant impacts, significant risks and significant opportunities
1.6.
ESRS E4: Biodiversity and ecosystems
IRO-1 Description of processes for identifying and assessing significant impacts, significant risks and significant opportunities
1.6.
ESRS E5: Resource use and the circular economy
IRO-1 Description of processes for identifying and assessing significant impacts, significant risks and significant opportunities
1.6.
ESRS S1: Own workforce
S1-1
Policies related to own workforce
3.1.5
S1-2
Procedures for working with own employees and employee representatives on impacts
3.1.5, 3.1.7.
S1-3
Processes for levelling negative influences and channels for reporting problems by unit staff
3.1.7.
S1-4
Taking action on the significant impacts on own workforce and applying approaches to mitigate material risks and
opportunities associated with own workforce, and the effectiveness of these actions
3.1.7.
S1-5
Objectives for managing material negative impacts, enhancing positive impacts and managing material risks and material
opportunities
3.1.7.
S1-6
Characteristics of the unit's employees
3.1.1
S1-7
Characteristics of non-employees who are the entity's own employees
3.1.1
S1-8
Scope of collective bargaining and social dialogue
3.1.7.
S1-9
Diversity indicators
3.1.2
S1-10
Adequate wages
3.1.3
S1-11
Social protection
3.1.6.
S1-13
Training and skills development indicators
3.1.4.
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S1-15
Work-life balance indicators
3.1.6.
S1-16
Wage indicators (wage gap and total wages)
3.1.3
S1-17
Incidents, complaints and serious impacts regarding human rights
3.1.7.
ESRS S4: Consumers and end-users
S4-1
Policies related to consumers and end-users
3.2.2, 3.2.3.
S4-2
Collaborative influencing processes with consumers and end-users
3.2.1.
S4-3
Remediation processes for negative impacts and channels for consumers and end-users to report problems
3.2.3.
S4-4
Taking action on material impacts on consumers and end-users and applying approaches to manage material risks and
opportunities related to consumers and end-users, and the effectiveness of these actions
3.2.1.
S4-5
Objectives for managing material negative impacts, enhancing positive impacts and managing material risks and material
opportunities
3.2.1.
ESRS G1: Governance
GOV-1
The role of the administrative, supervisory and management bodies
4.2.1.
G1-1
Corporate Culture and Business Conduct Policies
4.3.
G1-2
Supplier relationship management
4.5.
G1-3
Prevention and detection of corruption and bribery
4.3.
G1-4
Confirmed incident of corruption or bribery
4.3.
G1-6
Payment practices
4.5.
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Table 9. List of data points included in cross-cutting standards and thematic standards that stem from other EU legislation as per Appendix B
Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
ESRS 2 GOV-1
Board’s gender
diversity
paragraph 21 (d)
Indicator number 13 of Table
#1
of Annex 1
Commission Delegated
Regulation (EU)
2020/1816, Annex II
1.2., 4.2.1.
ESRS 2 GOV-1
Percentage of board
members who are
independent paragraph
21 (e)
Delegated Regulation (EU)
2020/1816, Annex II
4.2.2.
ESRS 2 GOV-4
Statement
on due dilligence
paragraph 30
Indicator number 10
Table #3 of Annex 1
4.6.
ESRS 2 SBM-1
Involvement in activities
related to fossil fuel
activities paragraph
40 (d) i
Indicators number 4 Table #1
of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453(6) Table 1:
Qualitative information on
Environmental risk and
Table 2: Qualitative
information on Social risk
Delegated Regulation (EU)
2020/1816, Annex II
Non-material
ESRS 2 SBM-1
Involvement in activities
related to chemical
production paragraph
40 (d) ii
Indicator number 9 Table #2
of Annex 1
Delegated Regulation (EU)
2020/1816, Annex II
Non-material
ESRS 2 SBM-1
Involvement in activities
related to controversial
Indicator number 14 Table #1
of Annex 1
Delegated Regulation (EU)
2020/1818(7), Article 12(1)
Delegated Regulation (EU)
2020/1816, Annex II
Non-material
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
weapons paragraph
40 (d) iii
ESRS 2 SBM-1
Involvement in activities
related to cultivation
and production of
tobacco paragraph 40
(d) iv
Delegated Regulation (EU)
2020/1818, Article 12(1)
Delegated Regulation (EU)
2020/1816, Annex II
Non-material
ESRS E1-1 Transition
plan to reach climate
neutrality by 2050
paragraph 14
Regulation (EU)
2021/1119, Article 2(1)
2.1.
ESRS E1-1
Undertakings excluded
from Paris-aligned
Benchmarks paragraph
16 (g)
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 1: Banking book-
Climate Change transition
risk: Credit quality of
exposures by sector,
emissions and residual
maturity
Delegated Regulation (EU)
2020/1818, Article12.1 (d)
to (g), and Article 12.2
2.1.
ESRS E1-4 GHG
emission reduction
targets paragraph 34
Indicator number 4 Table #2
of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 3: Banking book
– Climate change transition
risk: alignment metrics
Delegated Regulation (EU)
2020/1818, Article 6
2.1.3.
ESRS E1-5 Energy
consumption from fossil
sources disaggregated
by sources (only high
Indicator number 5 Table #1
and Indicator n. 5 Table #2
of Annex 1
2.1.2.
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SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
climate impact sectors)
paragraph 38
ESRS E1-5 Energy
consumption and mix
paragraph 37
Indicator number 5 Table #1
of Annex 1
2.1.2.
ESRS E1-5 Energy
intensity associated
with activities in high
climate impact sectors
paragraphs 40 to 43
Indicator number 6 Table #1
of Annex 1
2.1.2.
ESRS E1-6 Gross
Scope 1, 2, 3 and Total
GHG emissions
paragraph 44
Indicators number 1 and 2
Table #1 of Annex 1
Article 449a; Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 1: Banking book
– Climate change transition
risk: Credit quality of
exposures by sector,
emissions and residual
maturity
Delegated Regulation (EU)
2020/1818, Article 5(1),
6 and 8(1)
2.1.3.
ESRS E1-6
Gross GHG emissions
intensity paragraphs
53 to 55
Indicators number 3 Table #1
of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 3: Banking book
– Climate change transition
risk: alignment metrics
Delegated Regulation (EU)
2020/1818, Article 8(1)
2.1.3.
ESRS E1-7
GHG removals and
carbon credits
paragraph 56
Regulation (EU)
2021/1119, Article 2(1)
2.1.3.
ESRS E1-9
Exposure of the
Delegated Regulation (EU)
2020/1818, Annex II
2.1.3.
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
benchmark portfolio to
climate-related physical
risks paragraph 66
Delegated Regulation (EU)
2020/1816, Annex II
ESRS E1-9
Disaggregation of
monetary amounts by
acute and chronic
physical risk paragraph
66 (a) ESRS E1-9
Location of significant
assets at material
physical risk paragraph
66 (c).
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
paragraphs 46 and 47;
Template 5: Banking book -
Climate change physical
risk: Exposures subject to
physical risk.
2.1.3.
ESRS E1-9 Breakdown
of the carrying value
of its real estate assets
by energy-efficiency
classes paragraph 67
(c).
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
paragraph 34; Template
2:Banking book -Climate
change transition risk:
Loans collateralised by
immovable property -
Energy efficiency of the
collateral
N/A
ESRS E1-9 Degree of
exposure of the
portfolio
to climate- related
opportunities paragraph
69
Delegated Regulation (EU)
2020/1818, Annex II
N/A
ESRS E2-4 Amount
of each pollutant listed
Indicator number 8 Table #1
of Annex 1 Indicator number 2
Table #2 of Annex 1 Indicator
Non-material
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
in Annex II of the E-
PRTR Regulation
(European Pollutant
Release and Transfer
Register) emitted to air,
water and soil,
paragraph 28
number 1 Table #2 of Annex 1
Indicator number 3 Table #2
of Annex 1
ESRS E3-1
Water and marine
resources paragraph 9
Indicator number 7 Table #2
of Annex 1
Non-material
ESRS E3-1
Dedicated policy
paragraph 13
Indicator number 8 Table 2
of Annex 1
Non-material
ESRS E3-1
Sustainable oceans
and seas paragraph 14
Indicator number 12 Table #2
of Annex 1
Non-material
ESRS E3-4
Total water recycled
and reused paragraph
28 (c)
Indicator number 6.2 Table #2
of Annex 1
Non-material
ESRS E3-4
Total water
consumption
in m3 per net revenue
on own operations
paragraph 29
Indicator number 6.1 Table #2
of Annex 1
Non-material
ESRS 2- IRO 1 - E4
paragraph 16 (a) i
Indicator number 7 Table #1
of Annex 1
Non-material
ESRS 2- IRO 1 - E4
paragraph 16 (b)
Indicator number 10 Table #2
of Annex 1
Non-material
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
ESRS 2- IRO 1 - E4
paragraph 16 (c)
Indicator number 14 Table #2
of Annex 1
Non-material
ESRS E4-2
Sustainable land /
agriculture practices or
policies paragraph 24
(b)
Indicator number 11 Table #2
of Annex 1
Non-material
ESRS E4-2
Sustainable oceans /
seas practices or
policies paragraph 24
(c)
Indicator number 12 Table #2
of Annex 1
Non-material
ESRS E4-2
Policies to address
deforestation paragraph
24 (d)
Indicator number 15 Table #2
of Annex 1
Non-material
ESRS E5-5
Non-recycled waste
paragraph 37 (d)
Indicator number 13 Table #2
of Annex 1
Non-material
ESRS E5-5
Hazardous waste
and radioactive
waste paragraph 39
Indicator number 9 Table #1
of Annex 1
Non-material
ESRS 2- SBM3 - S1
Risk of incidents of
forced labour
paragraph 14 (f)
Indicator number 13 Table #3
of Annex I
Non-material
ESRS 2- SBM3 - S1
Risk of incidents of
child labour paragraph
14 (g)
Indicator number 12 Table #3
of Annex I
Non-material
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
ESRS S1-1
Human rights policy
commitments
paragraph 20
Indicator number 9 Table #3
and Indicator number 11
Table #1 of Annex I
3.1.5.
ESRS S1-1
Due diligence policies
on issues addressed
by the fundamental
International Labor
Organisation
Conventions 1 to 8,
paragraph 21
Delegated Regulation (EU)
2020/1816, Annex II
3.1.5.
ESRS S1-1 processes
and measures for
preventing trafficking
in human beings
paragraph 22
Indicator number 11 Table #3
of Annex I
Non-material
ESRS S1-1
workplace accident
prevention policy
or management
system paragraph 23
Indicator number 1 Table #3
of Annex I
Non-material
ESRS S1-3
grievance/complaints
handling mechanisms
paragraph 32 (c)
Indicator number 5 Table #3
of Annex I
3.1.7.
ESRS S1-14
Number of fatalities
and number and rate
of work- related
accidents paragraph 88
(b) and (c)
Indicator number 2 Table #3
of Annex I
Delegated Regulation (EU)
2020/1816, Annex II
Non-material
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/ General information
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
ESRS S1-14
Number of days lost
to injuries, accidents,
fatalities or illness
paragraph 88 (e)
Indicator number 3 Table #3
of Annex I
Non-material
ESRS S1-16
Unadjusted gender pay
gap paragraph 97 (a)
Indicator number 12 Table #1
of Annex I
Delegated Regulation (EU)
2020/1816, Annex II
3.1.3.
ESRS S1-16
Excessive CEO pay
ratio paragraph 97 (b)
Indicator number 8 Table #3
of Annex I
3.1.3.
ESRS S1-17
Incidents of
discrimination
paragraph 103 (a)
Indicator number 7 Table #3
of Annex I
ESRS S1-17
Non-respect of UNGPs
on Business and
Human Rights and
OECD paragraph 104
(a)
Indicator number 10 Table #1
and Indicator n. 14 Table #3
of Annex I
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1818 Art 12 (1)
3.1.7.
ESRS 2- SBM3 – S2
Significant risk of child
labour or forced labour
in the value chain
paragraph 11 (b)
Indicators number 12 and
n. 13 Table #3 of Annex I
Non-material
ESRS S2-1
Human rights policy
commitments
paragraph 17
Indicator number 9 Table #3
and Indicator n. 11 Table #1
of Annex 1
Non-material
ESRS S2-1
Indicator number 11 and
n. 4 Table #3 of Annex 1
Non-material
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
Policies related to value
chain workers
paragraph 18
ESRS S2-1
Non-respect of UNGPs
on Business and
Human Rights
principles and OECD
guidelines paragraph
19
Indicator number 10 Table #1
of Annex 1
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1818, Art 12 (1)
Non-material
ESRS S2-1
Due diligence policies
on issues addressed
by the fundamental
International Labor
Organisation
Conventions 1 to 8,
paragraph 19
Delegated Regulation (EU)
2020/1816, Annex II
Non-material
ESRS S2-4
Human rights issues
and incidents
connected to its
upstream and
downstream value
chain paragraph 36
Indicator number 14 Table #3
of Annex 1
Non-material
ESRS S3-1 Human
rights policy
commitments
paragraph 16
Indicator number 9 Table #3
of Annex 1 and Indicator
number 11 Table #1 of Annex
1
Non-material
ESRS S3-1
non-respect of UNGPs
Indicator number 10 Table #1
Annex 1
Delegated Regulation (EU)
2020/1816, Annex II
Non-material
242
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/ General information
Investor Relations
Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
on Business and
Human Rights, ILO
principles or and OECD
guidelines paragraph
17
Delegated Regulation (EU)
2020/1818, Art 12 (1)
ESRS S3-4
Human rights issues
and incidents
paragraph 36
Indicator number 14 Table #3
of Annex 1
Non-material
ESRS S4-1 Policies
related to consumers
and end-users
paragraph 16
Indicator number 9 Table #3
and Indicator number 11 Table
#1 of Annex 1
3.2.2, 3.2.3.
ESRS S4-1 Non-
respect
of UNGPs on Business
and Human Rights and
OECD guidelines
paragraph 17
Indicator number 10 Table #1
of Annex 1
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1818, Art 12 (1)
3.2.2
ESRS S4-4 Human
rights issues and
incidents paragraph 35
Indicator number 14 Table #3
of Annex 1
3.2.1.
ESRS G1-1
United Nations
Convention against
Corruption paragraph
10 (b)
Indicator number 15 Table #3
of Annex 1
4.3.
ESRS G1-1
Protection of whistle-
blowers paragraph 10
(d)
Indicator number 6 Table #3
of Annex 1
4.3.
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Disclosure
Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Chapter of Sustainability
Statement
ESRS G1-4
Fines for violation of
anti- corruption and
anti-bribery laws
paragraph 24 (a)
Indicator number 17 Table #3
of Annex 1
Delegated Regulation (EU)
2020/1816, Annex II)
4.3.
ESRS G1-4
Standards of anti-
corruption and anti-
bribery paragraph 24
(b)
Indicator number 16 Table #3
of Annex 1
4.3.
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Table 10. List of references
No
ESRS requirement
ESRS data point
Document referred to
1.
GOV-1 The role of the
administrative, management
and supervisory bodies
GOV-1 20b
GOV-1 21c
Management Report of XTB
Group and XTB S.A. in 2024,
chapter: Governance
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Environment
Annual Report 2024
/ Environment
2. Environment
2.1 Climate change
2.1.1. The XTB Group's climate policy
2.1.2. Fuel and energy consumption
2.1.3. Greenhouse gas emissions
2.2 Compliance of XTB Group's activities
with the Taxonomy
2.2.1 Non-financial taxonomy
2.2.2 Financial taxonomy
2.2.3 Minimum Guarantees
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2. Environment
2.1. Climate change
The XTB Group's core business, based mainly on the operation of IT infrastructure (including
servers) and office operations, means that we do not identify any significant impact
of our activities on the environment or climate change. Due to the non-production nature
of our business, there is no demand for and consumption of raw materials and materials.
In providing our services, we use IT infrastructure, office supplies and electricity,
which is essential for the continuity of our operations.
To date, we have not taken climate issues into account in XTB Group's decision-making
processes, and climate considerations are not included in the remuneration of members
of the administrative, management and supervisory bodies. Nevertheless, it is our intention
to reduce our impact on the environment (including climate change).
E1-1 In July 2024, the XTB Group published its ESG Strategy 2024-2027, where
we identified one of the key targets for calculating the Group's full carbon footprint in scopes
1, 2 and 3. This is our next step, which will enable the development of a decarbonisation plan
with measurable greenhouse gas reduction targets in Scopes 1, 2 and 3 in the coming years,
and will support our move towards net zero emissions by 2050 in accordance with the Paris
Agreement. As this is a new area of interest for the XTB Group, we have not yet developed
a transformation plan for climate change mitigation purposes, but over the next 5 years
we will analyse the feasibility of developing and implementing one after developing
a decarbonisation plan.
E1 GOV-3 In 2024 no financial incentives related to the area of environment and climate
were applied to members of the Management Board of XTB S.A. and the Supervisory Board
of XTB. Due to the lack of greenhouse gas emission reduction targets, the activities
of the above-mentioned bodies in this area were not assessed either.
2.1.1. XTB Group's Climate Policy
E1-3 / MDR-A Action and resources in relation to climate policy
We are at the beginning of our journey towards decarbonisation and climate change is a new
area of focus. In 2024, we have taken steps to develop a climate issue management system
in line with the updated ESG Strategy for 2024-2027 that would support us in reducing
our impact on climate change, i.e. identification of climate and environmental risks, scenario
analysis, creation of Climate Policy. These activities had a scope consistent
with the geographical scope of the XTB Group's operations. The next stage will
be the management of identified risks within the XTB Group's location and monitoring
the XTB Group's impact on the environment and climate using data collected for the purposes
of sustainable development reporting.
We are an investment company and our core business can be categorized as a typical office
and administrative business. XTB's operational processes, key for business continuity,
service and product development are based on maintaining the necessary IT infrastructure.
Accordingly, the most significant identified areas of the Group's climate and environmental
impact are the consumption of purchased electricity and the management of electro-waste.
Consequently, our direct activities generate limited and indirect climate and environmental
impacts relative to highly energy-intensive industries.
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As part of its double materiality assessment, the organisation identified energy efficiency
measures, i.e., seeking to replace servers with less energy-intensive ones at the end
of the life cycle of existing equipment, locating XTB S.A.'s headquarters in a certified building,
locating selected offices of foreign units in more energy-efficient buildings, among others.
During the reporting period, the XTB Group did not use decarbonization levers,
but in the future it will consider taking actions based on decarbonization levers depending
on identified needs and available possibilities.
E1-2 / MDR-P
Understanding the need to address progressive climate change, despite our limited influence
in the area, in 2024 we undertook a process of identifying climate opportunities and risks
and developing a Climate Policy and scenario analysis. We believe that these steps will allow
us to systematise our activities and set the perspective for the further development
of the impact XTB has on the climate change. Risks have been aligned to and will be
implemented in the internal Risk Management System. No policies related to climate change
mitigation and adaptation other than the Climate Policy apply in the XTB Group. Its guidelines
are intended to improve the management of the Group's climate change impact and to support
XTB Group's operational processes and activities. As part of the work on the Policy, we carried
out a scenario analysis in cooperation with an external expert (taking into account the two
extreme scenarios that are part of the document), which is intended to form the basis
for future decisions on the Group's climate adaptation measures.
The analysis took into account 3 time perspectives:
▪ short-term - in which the time horizon was assumed to be 2027 (the assumed year
of implementation of the ESG strategy adopted by XTB);
▪ medium-term - in which the time horizon was assumed to be 2030 (an intermediate
year in the implementation of the assumptions of the European Union Climate Policy)
▪ long-term - in which the time horizon was assumed to be 2050 (the year in which
according to the assumptions of the EU Climate Policy and the Paris Agreement,
climate neutrality, i.e. zero net emissions, will be achieved).
The analysis was carried out based on the TCFD Guidelines (Guidance on Scenario Analysis
for Non-Financial Companies) and the IPCC RCP and SSP scenarios.
ESG Team is responsible for implementation of the Policy. The policy was adopted
by a Resolution of the Management Board of XTB S.A. in December 2024. The XTB Group's
ability to implement climate change mitigation and adaptation measures depends solely
on the availability of energy (including renewable energy). In 2024, the XTB Head Office
has covered 100% of its electricity consumption with renewable energy sources (wind power).
In 2024, the XTB Group did not incur any significant capital and operating expenditure
required to implement the activities undertaken.
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Table 11. XTB Group projects completed in 2024
Project
Implementation status
An update of the "Natural Investment" in-house educational
programme
Completed in 2024
Double Materiality Assessment of areas E, S, G
Completed in 2024
Carrying out an analysis of climate opportunities and risks
Completed in 2024
Reporting of greenhouse gas emissions under the GHG
Protocol Corporate Accounting and Reporting Standard in
scope 1, scope 2 and scope 3
Started in 2024
ESG Strategy Update 2024-2027
Completed in 2024
Scenario analysis of the resilience of the business model and
the Group's strategy to climate change assuming an increase
in average global temperatures of less than 2ºC and more
than 2ºC compared to the pre-industrial period
Completed in 2024
Implementation of the XTB Group Climate Policy
Completed in 2024
In 2024, we have identified a list of topics relevant to climate change and the environment
and identified a key climate opportunity and risk as part of our Double Materiality Assessment.
The project involved an in-depth dialogue with representatives of the Group's subsidiaries
and a series of workshops were held within the XTB Company operating in Poland to explore
potential or actual climate and environmental impacts.
SBM-1 / SBM-3
In the course of our work, we identified one key physical risk in the climate area from the point
of view of the double materiality assessment, defined as "External event risk (business
continuity risk) due to the possibility of sudden extreme weather events at the locations
of some XTB Group companies and branches." It’s physical climate risk related
to the possibility of extreme and unforeseen weather events that may affect XTB offices
located in locations, particularly at risk of being impacted. We identify that XTB's assets
and business are not materially at risk by virtue of not having significant IT assets
or infrastructure at the identified locations, but due to the fact that employees are employed
at these locations, we have decided to consider this risk to be material. We identify that
the physical risk identified do not and will not materially affect XTB Group's strategy
and business model of XTB Group. During the reporting period, no critical assumptions were
identified regarding the impact of the transition to a low-carbon economy on macroeconomic
trends, energy consumption, the energy mix and on assumptions about technology
deployment.
The objectives of the Climate Policy are to guide the Group's efforts to:
1) mitigate and adapt to the climate change;
2) achieve the objectives set out in the XTB Group's ESG Strategy for 2024-2027;
3) achieve the climate neutrality by XTB Group's in the future.
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E1-1 The objectives of the Policy will be implemented through actions focused on:
1) calculation of the Group's carbon footprint in all three scopes;
2) identification of the opportunities to reduce/compensate for the Group's carbon
footprint;
3) cyclical reviews of climate and environmental opportunities and risks and time
scenarios as recommended by the Task Force on Climate-related Financial
Disclosures (TCFD);
4) integration of climate and environmental risks into the climate change risk
management system;
5) exploiting the opportunities and possible positive effects of climate change.
Climate commitments
1) From 2024 onwards, the XTB Group plans to calculate and monitor its carbon
footprint annually in all three scopes.
2) The XTB Group has the ambition to strive for climate neutrality understood
as net zero emissions in scopes 1, 2 and 3 according to the GHG Protocol standard.
3) The Group will improve the data collection processes for calculating the carbon
footprint and aim to cover as wide a range of emissions as possible in the analysis.
E1-2 / MDR-P The Climate Policy covers the entire XTB Group. The geographical areas
adopted in the Policy are the Group's area of operations - specific office locations subjected
to scenario analysis. The addressees of the Policy are external and internal stakeholders:
clients, employees, media representatives, capital market representatives, representatives
of our social environment and the regulatory and market environment. The XTB Group
Climate Policy is a publicly available document adopted by a Resolution of the XTB S.A.
Management Board and known to XTB Group employees. ESG Team is responsible
for its implementation. We also encourage XTB's business partners to support the Policy's
objectives and to set their own climate targets and solutions within their business.
Due to the lack of measurable goals of the XTB Group Climate Policy, we intend to monitor
its effectiveness through an annual review of the document and the effectiveness
of the actions declared therein, also in relation to significant impacts, risks and opportunities
in the area of the environment and climate. The ESG Team is responsible for the above
analysis, which, in cooperation with the employees of the XTB Group, will support
the XTB Group's pursuit of the goal of developing the area of climate and environmental
management. Over time, when it is possible to set greenhouse gas emission reduction
targets, they will become one of the indicators measuring the level of effectiveness
of the Policy.
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E1-2 MDR-P / E1-3 MDR-A
In order to implement the commitments, we take or intend to take actions such as:
• XTB Group's annual greenhouse gas emissions calculation.
• Setting emission reduction targets based on XTB Group's accumulated GHG
emissions data from several periods.
• Initiatives to support our drive to reduce our carbon footprint in scopes 1, 2 and 3.
• Analysis of the need for a transition plan in relation to the administrative and office
nature of XTB Group's business.
• Annual climate risk review.
• Deepening of the dialogue on reducing the negative climate impact in the value chain
(upstream and downstream), in particular with stakeholders responsible for key
Scope 3 emissions, in order to implement real changes leading to CO2 reductions.
• Strengthening awareness of climate change within the organisation through, among
other things, the "Natural Investment" programme.
• Responsible management of equipment and waste (including waste segregation,
extending the life of electronic equipment through repair, reuse of equipment) and
control of resource consumption at all sites.
• Using renewable energy and gradually increasing its share in the Group's energy
mix as far as feasibility and solution availability allow.
• Increasing the Group's energy efficiency, including by replacing servers with newer,
less energy-intensive ones; locating XTB offices in more energy-efficient buildings
(e.g. XTB Head Office in Warsaw).
The above activities are elements of the XTB Group's development process in the area
of Environment and Climate. They will be implemented either continuously or over
a 5-year period (including setting emission reduction targets).
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/ Sustainability Statement for 2024
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2.1.2. Fuel and energy consumption
E1-5 MDR-M
The sources of direct fuel consumption in the XTB Group are limited to a small number
of company cars and generators. However, XTB S.A. Group's core administrative and office
operations and IT infrastructure are responsible for the most significant electricity and heat
consumption. The measurement of the indicator related to energy consumption and energy
mix was not verified by any external entity other than the advisor in cooperation with whom
we carried out the calculations. In the absence of data, estimates were made based on actual
data from other companies with a similar location (geographical location) and similar
parameters (heat energy included/not included in electricity). In the further part of the chapter
there is as information on the direct consumption of electricity, heat and fuel consumption
in the XTB S.A. Group is given below.
XTB Group does not operate and does not generate revenues from activities in sectors
with a significant climate impact and therefore does not show sectors with a high climate
impact in the Statement.
Table 12. XTB Group energy mix
Reporting period
01.01.2024 – 31.12.2024
Unit
Consumption
Fossil energy consumption
MWh
1 494
Energy consumption from nuclear
sources
MWh
0
Percentage of fossil sources
in total energy consumption
%
86
Percentage of energy consumption
from nuclear sources in total energy
consumption
%
0
Renewable energy consumption,
including:
MWh
248
Consumption of fuel from renewable
sources (biomass, industrial and
municipal waste of biological origin,
biofuels, biogas, hydrogen from
renewable sources, etc.)
MWh
0
Consumption of purchased electricity,
heat, steam and cooling from
renewable sources
MWh
248
Consumption of self-generated
renewable energy without fuel
MWh
0
Share of energy from renewable
sources in the total energy
consumption
%
14
Total energy consumption
related to own operations
MWh
1 742
252
Management Report of XTB Group and XTB S.A. in 2024
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Relationships
XTB Group's Scope 1 Biogenic Emissions
Biogenic emissions are emissions outside the Scopes resulting from the combustion
of biocomponent added to fuels commonly available at service stations and used in vehicles
owned or controlled by the company.
Tabela 13. Biogenic emissions of XTB Group in 2024
Company
Unit
Biogenic emissions
XTB S.A. HQ
t CO2e/
year
0,28
Branches of XTB S.A.
t CO2e
/year
0,72
Other companies of XTB S.A.
t
CO2e/year
0,00
TOTAL
t
CO2e/year
1,00
Scope 2 Biogenic Emissions
Biogenic emissions occur due to the combustion of biomass during energy production. Since
national institutions do not provide information on the fuel mix,in particular the percentage
of biomass burned in total energy production, it is not possible to calculate biogenic emissions
in Scope 2.
Scope 3 Biogenic Emissions
Biogenic emissions may occur in transport, i.e. they may concern categories 4, 6, 7 and 9
of Scope 3. It is not possible to separate these emissions because the exact value of fuel
consumption and its biocomponent content is not known. Emissions in these categories are
calculated per km or pkm (passenger.km), not per litre of fuel consumed, because such data
is unavailable. Additionally, biogenic emissions may occur in categories 1 and 2 of Scope 3
for individual purchased products, services and capital goods, but we do not have information
about these emissions from suppliers.
XTB Group energy basket
The year 2024 for the XTB Group's energy mix disclosures is the base year. In the reporting
period, all electricity used within the scope of the XTB Headquarters operations came from
renewable energy sources, which was confirmed by guarantees of origin of energy.
In the Headquarters (Skyliner office building in Warsaw), the energy used by XTB within
the scope of the leased area can be considered as coming from renewable sources
in proportion to the energy used in the entire building. The share of consumption of externally
purchased electricity from renewable sources (wind energy) confirmed by a certificate
of guarantee of origin and approved by the Polish Power Exchange is approx. 16% in the total
consumption of externally purchased energy of the XTB S.A. Capital Group. In addition,
the energy consumption in the building is reduced by the energy-saving LED lighting used
in the building.
In an effort to reduce electricity consumption and greenhouse gas emissions, we have been
gradually phasing out older, energy-intensive servers and replacing them with new, more
energy-efficient servers from certified EU suppliers. In addition to increased energy efficiency,
they are also characterised by state-of-the-art solutions such as the smart adjustment
of energy consumption in relation to load, which also translates into electricity savings.
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/ Sustainability Statement for 2024
Investor Relations
2.1.3. Greenhouse gas emissions
E1-4 / MDR-T
In 2024, we have for the first time undertaken a full-scale calculation of greenhouse gas
emissions and therefore do not identify changes from previous reporting periods, we didn’t
reduce emissions and have not set reduction targets.
Limits of reported emissions:
▪ Data includes XTB S.A., its branches and subsidiaries according to operational and
financial control (100% of the issue of each entity).
Scope of reported emissions:
▪ Scope 1 – direct emissions from the combustion of fuels in stationary or mobile
sources owned or controlled by the company, technological process emissions
or refrigerant leaks.
▪ Scope 2 – indirect greenhouse gas emissions from the consumption of imported
(purchased or externally supplied) electricity and heat – district heating. In practice,
greenhouse gas emissions are created at the point of production of these utilities.
▪ Scope 3 – other indirect emissions arising along the value chain.
Data on the consumption of electricity and heat (district heating), solid fuels, purchased goods
and services, transport, waste came mainly from internal registers of the XTB Group.
The calculations were developed using recognized international standards and best practices
for calculating the company's carbon footprint based on operational data. The calculation
model was subject to additional verification in accordance with the internal quality control
procedures of the external advisor to the XTB Group for calculating greenhouse gas
emissions. The assumptions used by the advisor, in particular regarding electricity
consumption, solid fuels, purchases, transport, waste and employee commuting to work,
were verified by members of the XTB S.A. project team.
The XTB Group's carbon footprint calculations were carried out in cooperation
with an external expert and included:
▪ education - an online educational workshop for all interested employees
and a workshop for the project team;
▪ identification of emission sources - an analysis of the XTB Group's business
model and business profile was performed, identifying all processes that could
generate greenhouse gas emissions. A process map was created, which included
all possible emission sources divided into Scopes and categories of Scope 3;
▪ data collection and verification - collection of data from all organizational units
of the XTB Group necessary for carbon footprint calculations using personalized
data collection templates and verification;
▪ carbon footprint calculations - creation of a tool adapted to the XTB Group's
operations, collection of appropriate emission indicators and double verification
of calculations.
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Table 14. Sources of emission factors used to calculate XTB's carbon footprint
in 2024
Source
Link
Comment
B. Urban, K. Roth, 2019,
Residential Consumer
Electronics Energy
Consumption in the United
States in 2017
(last access: 07.02.2025
r.)
Residential Consumer
Electronics Energy
Consumption in the United
States in 2017
Average power
consumption by:
-laptop,
-computer,
-screen
-smart TV
Department for
Environment
Food & Rural Affairs
(DEFRA) – United
Kingdom:
Greenhouse gas
reporting:
conversion factors 2024
(last access: 21.02.2025
r.)
DEFRA 2024
*Emission factors for fuels
burned in stationary
sources for the UK
*Emission factors for fuels
burned in mobile sources
*Emission factor for waste
water
*WTT emission factors for
fuels
*Emission factors for waste
*Direct emission factors
and WTT for individual
means
of transport
*Conversion factors for
individual fuels
E.ON Polska S.A., 2024,
fuels structure in 2023
https://eon.pl/-
/media/Eon/Dokumenty/La
nding-pages/ekologicznie-
i-
oszczednie/Struktura_pali
w_2023.ashx
Supplier emission factor
for electricity produced
Ecoact, 2020,
Homeworking emissions
Whitepaper
Homeworking emissions
Average electricity
consumption
per lamp
EDF, 2024, Emissions
index of electricity
produced in 2023
https://www.edf.fr/en/the-
edf-group/producing-a-
climate-friendly-energy
Supplier emission factor
for electricity produced
EDP Comercial, 2024,
Emissions index of
electricity produced in
2024
https://www.edp.pt/origem-
energia/?sector=17026&y
ear=2023&trimester=2
Supplier emission factor
for electricity produced
Ember, 2024, Emissions
of electricity produced
2022-2023
Ember 2024
National emission
indicators
for electricity produced
Enerdata 2024,
(last access:
07.02.2025 r.)
Enerdata
Value of transmission
losses
for countries other than
Poland
Exchange-rates.org, 2024,
World currency exchange
rates and currency
exchange rate history
(last access:
21.02.2025 r.)
https://www.exchange-
rates.org/
Average monthly exchange
rates
Exiobase, 2022
exiobase
Expenditure indicators for
purchased goods, services,
capital goods and business
trips
FEDENE Reseaux de
chaleur & froid, 2023,
Enquete des reseaux de
chaleur et froid EDITION
2024
Enquete des reseaux de
chaleur et froid EDITION
2023
Location-based emission
factor, WTT and percentage
of transmission losses for
district heating in France
Globales Emissions-
Modell integrierter
Systeme (GEMIS) v.5.1,
March 2023
(last access:
07.02.2025)
GEMIS 5.1 v. 03.2024
* Emission factors for fuels
burned in stationary
sources for Germany
*Direct and indirect
emission factor for district
heating
Hotel Sustainability
Benchmarking Index
2024
(last access:
21.02.2025)
https://greenview.sg/servic
es/chsb-index/
Emissions factors
for business travel
accommodation
https://m9v7b6.a2cdn1.se
cureserver.net/wp-
content/uploads/2019/12/
SDS-
https://m9v7b6.a2cdn1.se
cureserver.net/wp-
content/uploads/2019/12/
SDS-
Composition of R410A
refrigerant
255
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Investor Relations
R410A.pdf?time=1689191
439
(last access:
07.02.2025)
R410A.pdf?time=1689191
439
https://www.gea.com/pl/art
icles/natural-
refrigerants/natural-
refrigerants-
hydrocarbons.jsp
(last access: 07.02.2025)
https://www.gea.com/pl/art
icles/natural-
refrigerants/natural-
refrigerants-
hydrocarbons.jsp
Composition of refrigerant
R600A (Isobutane)
IEA, 2024, Life Cycle
Upstream Emission
Factors (Pilot Edition)
IEA 2024, Life Cycle
Upstream Emission
Factors (Pilot Edition),
Total upstream factors for
Poland, 2022 estimated
WTT emission factors for
electricity
IPCC AR6, 2023, The
Earth’s Energy Budget,
Climate Feedbacks and
Climate Sensitivity
Supplementary Material
IPCC AR6 The Earth’s
Energy Budget, Climate
Feedbacks and Climate
Sensitivity Supplementary
Material
GWP values for individual
greenhouse gases
IPCC, 2006, Guidelines
for National Greenhouse
Gas Inventories, Chapter
2 Stationary Combustion
2006 IPCC Guidelines for
National Greenhouse Gas
Inventories, TABLE 2.4
DEFAULT EMISSION
FACTORS FOR
STATIONARY
COMBUSTION IN THE
COMMERCIAL/INSTITUTI
ONAL CATEGORY
Default CH4
and N2O emission
factors for natural gas
Apple Device EPD Cards
(last access: 21.02.2025)
Apple environment
*Cradle-to-gate emission
factor
of purchased equipment
*Emission factors in the
disposal phase for a given
type of equipment
DELL Device EPD Cards
(last access: 21.02.2025)
DELL product carbon
footprints
*Cradle-to-gate emission
factor
of purchased equipment
*Emission factors in the
disposal phase for a given
type of equipment
Google Device EPD
Cards
(last access: 21.02.2025)
https://sustainability.googl
e/reports/
*Cradle-to-gate emission
factor
of purchased equipment
*Emission factors in the
disposal phase for a given
type of equipment
Lenovo Device EPD
Cards
(last access: 21.02.2025)
Lenovo eco-declaration
*Cradle-to-gate emission
factor
of purchased equipment
*Emission factors in the
disposal phase for a given
type of equipment
Samsung Device EPD
Cards
(last access: 21.02.2025)
Samsung sustainability
*Cradle-to-gate emission
factor
of purchased equipment
*Emission factors in the
disposal phase for a given
type of equipment
National Centre for
Emission Balancing and
Management (KOBIZE),
2024, Calorific values
(WO) and CO2 emission
factors (WE)
in 2022 for reporting under
the Emissions Trading
Scheme for 2025
https://www.kobize.pl/uplo
ads/materialy/materialy_d
o_pobrania/monitorowanie
_raportowanie_weryfikacja
_emisji_w_eu_ets/WO_i_
WE_do_monitorowania-
ETS-2025.pdf
Calorific values (CV) and
CO2 emission factors (EC)
in 2022
for reporting under the
Emissions Trading Scheme
for 2025 Warsaw,
December 2024
National Center for
Emission Balancing and
Management (KOBIZE),
2024, Emission indices of
CO2, SO2, NOx, CO and
total dust
for electricity based
on information contained
in the National database
on greenhouse gas
emissions and other
substances for 2023
Emissions Index for
Electricity
Emission indicators of CO2,
SO2, NOx, CO and total
dust for electricity based on
information contained in the
National database on
greenhouse gas emissions
and other substances for
2023
256
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/ Sustainability Statement for 2024
Investor Relations
M.Weiss, K. C. Cloos, E.
Helmers, 2020, Energy
efficiency trade-offs in
small to large electric
vehicles
Energy efficiency trade-
offs in small to large
electric vehicles
Average power
consumption by:
-electric car,
-electric bike,
-electric scooter
Ministry of Environment,
Waters and Forests
National Environmental
Protection Agency, April
2023, Romania's
Greenhouse Gas
Inventory 1989-2021,
National Inventory
Romania 2023 National
Inventory Report (NIR)
Emission factor for fuels
burned
in stationary sources in
Romania
National Centre for
Emissions Management,
Institute
of Environmental
Protection National
Research Institute, 2024,
Poland's National
inventory report 2024
https://cdr.eionet.europa.e
u/pl/eu/govreg/inventory/e
nvzfry5q/NIR_2024_POL.
pdf
Emission factor for fuels
burned
in stationary sources for
Poland
Naturgy Iberia S.A., 2024,
Wskaźnik emisyjności
wyprodukowanej energii
elektrycznej w 2023 roku
https://www.naturgy.pt/pt/
mercado_energetico/rotul
agem/rotulagem_naturgy
Supplier's emission factor
for electricity produced
Netzdienste Rhein-Main
(Mainova AG), 2024,
Wskaźnik emisyjności
wyprodukowanej energii
elektrycznej w 2023 roku
https://www.mainova.de/d
e/stromkennzeichnung-
der-mainova-strommix-im-
ueberblick
Supplier's emission factor
for electricity produced
Odbor Emisie A Biopaliva,
15. April 2023, National
Inventory Report 2023
Slovak Republic,
Submission under the
UNFCCC
Slovakia 2023 National
Inventory Report (NIR)
Emission factor for fuels
burned in stationary
sources in Slovakia
PGE Polska Grupa
Energetyczna S.A., 2024,
Struktura paliw w 2023
roku
https://www.gkpge.pl/bip/st
ruktura-paliw
Supplier's emission factor
for electricity produced
Smartest Energy, 2024,
Emissions index of
electricity produced in
2023
https://www.smartestenerg
y.com/en_GB/fuel-mix/
Supplier's emission factor
for electricity produced
Statcounter
Operating System Market
Share Worldwide |
Statcounter Global Stats
*Global Phone OS Market
Share
*Global Tablet OS Market
Share
Sustainable Web Design,
2024, Estimating Digital
Emissions
(last access 07.02.2025)
sustainablewebdesign.org
Electricity consumption
for data transmission
The Scottish Environment
Protection Agency
(SEPA), 2024, Conversion
factors
for waste
https://www.sepa.org.uk/m
edia/163323/uk-
conversion-factors-for-
waste.xlsx
Municipal waste density
Umweltbundesamt, 2023,
Emissionsbilanz
erneuerbarer
Energietrager,
Bestimmung der
vermiedenen Emissionen
im Jahr 2023
Emissionsbilanz
erneuerbarer
Energieträger 2023
Location-based emission
factor, WTT and percentage
of transmission losses for
district heating in Germany
Energy Regulatory Office,
2025, Thermal energy
in numbers - 2023
2023 - Thermal energy in
numbers - Energy
Regulatory Office
Thermal energy emission
index - Poland's district
heating for 2023
Vattenfall, 2024,
Emissions intensity of
electricity produced in
2023
https://www.vattenfall.de/st
romkennzeichnung
Supplier emission factor
for electricity produced
VEOLIA ENERGIA
WARSZAWA S.A., 2024,
fuel structure in 2023
https://www.energiadlawar
szawy.pl/wp-
content/uploads/2024/11/
Wplyw-na-Srodowisko-
2023-1.pdf
Supplier emission factor
for produced thermal
energy - district heating
Západoslovenská
energetika, a.s., 2024,
Emissions index of
electricity produced
in 2023
https://www.zse.sk/dokum
enty/zse-energy-mix-en-
version.pdf
Supplier emission factor
for electricity produced
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According to information provided from the DEFRA database, emission factors for fuels used
in cars owned or controlled by the XTB S.A. Capital Group distribute the percentage share
of biomass.
Scope 3 of the carbon footprint described in this report included:
▪ Category 1: Purchased goods and services
Issues related to the purchase of goods and services include, but are not limited to: marketing,
research, consulting, recruitment, legal, accounting, telecommunications, cleaning, security
and maintenance services. In addition, emissions from water consumption, the purchase
of paper, magazines, books, subscriptions, software, low-value office equipment and low-
value IT equipment were included. The scope of this category results from the accounting
principles adopted in the XTB S.A. Capital Group.
▪ Category 2: Capital goods
Issues related to the purchase of capital goods include, but are not limited to, computer
equipment such as laptops, desktop computers (PCs), monitors, smartphones, tablets,
as well as server room equipment, including devices such as servers and switches.
In addition, other electrical appliances and furniture are also affected by these emissions.
▪ Category 3: Energy and fuel-related emissions not included in Scope 1 and 2
▪ Upstream emissions of purchased fuels (extraction, production and transport
of fuels) consumed at stationary and mobile sources owned or controlled
by the company.
▪ Upstream emissions of purchased energy (extraction, production and transport
of fuels used to generate electricity and heat – district heating).
▪ Direct and upstream emissions (extraction, production, transport of fuels used
to generate electricity and heat – district heating) resulting from losses associated
with the transmission and distribution (upstream activities and combustion)
of electricity and heat – district heating.
▪ Category 4: Upstream - transport and distribution
Emissions resulting from the transport and distribution of products purchased in the first half
of the reporting period, in vehicles that are not owned or controlled by the XTB S.A. Group.
Postal services and courier services are also included in this category.
▪ Category 5: Waste arising from the company's activities
Emissions resulting from the production of wastewater, municipal waste generated at facilities
used by XTB Group S.A. and electro-waste.
▪ Category 6: Business travel
Issues related to business travel and accommodation of XTB S.A. Group employees.
▪ Category 7: Employees commuting
Emissions associated with employee commuting include the use of various modes
of transport such as cars, trams, city buses, rail, bicycles and scooters. In addition, emissions
generated by remote working are also included.
▪ Category 11: Use of products sold
Emissions associated with end-user use of the app were estimated based on current-year
data, without consideration of full lifecycle assumptions. The analysis included the energy
consumption of electrical devices (such as phones, tablets, computers and smart TVs) as well
as emissions resulting from data transmission when using the app.
Calculation standards used
The GHG Protocol standard was used to calculate the Group's carbon footprint. A Corporate
and Reporting Standard, revised edition, March 2004. World Resources Institute and World
Business Council for Sustainable Development. (Changes and amendments: Required gases
and GWP values, February 2013) and:
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▪ Scope 2: Market-based approach (use of purchased electricity emission factor
by rate from energy supplier) and Location-based approach (use of purchased
electricity emission factor by national rate) according to the GHG Protocol. Scope 2
Calculation Guidance. An amendment to the GHG Protocol Corporate Standard,
2015. World Resources Institute.
▪ Scope 3: GHG Protocol. Corporate Value Chain (Scope 3) Accounting and Reporting
Standard. Supplement to the GHG Protocol Corporate Accounting and Reporting
Standard, 2011. World Resources Institute and World Business Council
for Sustainable Development.
▪ GHG Protocol. Technical Guidance for Calculating Scope 3 Emissions (version 1.0).
Supplement to the Corporate Value Chain (Scope 3) Accounting & Reporting
Standard, 2013. World Resources Institute and World Business Council
for Sustainability.
As part of the XTB Group's carbon footprint calculation, all greenhouse gases listed
in the GHG Protocol standard were included, that is:
▪ Carbon dioxide (CO2),
▪ Methane (CH4),
▪ Nitrous oxide (N2O),
▪ Sulphur hexafluoride (SF6),
▪ Perfluorocarbons (PFCs),
▪ Hydrofluorocarbons (HFCs),
▪ Nitrogen trifluoride (NF3).
1
Department for Environment Food & Rural Affairs (DEFRA) – United Kingdom: Greenhouse gas reporting: conversion
factors 2024, https://www.gov.uk/government/publications/greenhouse-gas-reporting-conversion-factors-2024.
The relative greenhouse effect values expressed as Global Warming Potential (GWP) per 100
years used for individual greenhouse gases were taken from the Sixth Report of the IPCC
(Intergovernmental Panel for Climate Change), as recommended by the GHG Protocol.
The exceptions are:
▪ For Scope 3 emission factors derived from the DEFRA 2024
1
database, in which
the Fifth Report of the Intergovernmental Panel for Climate Change (IPCC) was
used.
2
According to the GHG Protocol standard, which indicates to use the latest
published GWP values of the GHGs concerned in the carbon footprint calculations,
the emission factors should be recalculated according to the values given in the Sixth
Report of the Intergovernmental Panel for Climate Change (IPCC). For Scope 3
categories 4, 6, 7 and 9, this is not possible with the assumption of calculating GHG
emissions from the entire life cycle of the fuels, as the emission factors from direct
combustion are presented by value for the individual GHGs concerned,
while the WTT emission factors are only given in the CO2e units.
▪ EXIOBASE 202211
3
indicator database, which uses an average GWP value
for methane of 27.9. Due to the difficulty of assigning fossil and non-fossil values,
it was decided to use an average value such as one given in Table 7.SM.7
of the Sixth Report of the Intergovernmental Panel for Climate Change.
Based on analyses of the Group's operations, its business model, financial materiality,
reputational risks, etc., the following Scope 3 categories relating to XTB S.A.'s operations
were selected for inclusion in the Group's carbon footprint:
2
IPCC, 2014: Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and III to the Fifth
Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, R.K. Pachauri and L.A.
Meyer (eds.)]. IPCC, Genewa, Szwajcaria, 151 ss.
3
https://www.exiobase.eu/
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• Category 1 – Purchased materials and services
• Category 2 – Capital goods
• Category 3 – Energy and fuel-related emissions not included in Scope 1 and 2
• Category 4 – Upstream – Transport and distribution
• Category 5 – Waste arising from the company's activities
• Category 6 – Business travel
• Category 7 – Employee commuting
• Category 11 – Use of products sold
Selection of emission factors
The GHG emission factors used in the study, among those commonly available,
are characterised by:
• temporal materiality – indicators relevant/closest to the period for which the carbon
footprint is calculated,
• geographical materiality – indicators representative of the area for which
the carbon footprint is being calculated,
• technological materiality – indicators that take into account the technology used,
for which the carbon footprint is calculated.
These coefficients come from recognised, peer-reviewed, officially published sources:
• national and international research centres,
• sector associations,
• centres responsible for regulation, monitoring and statistics in relevant areas.
4
GHG Protocol: A Corporate Accounting and Reporting Standard
This approach is in line with the provisions of the GHG Protocol methodologies
4
. Following
the principle of temporal relevance, the emission factors used (within availability) are valid
for the reporting period, in this case 2024. Where factors have not been published
for a particular reporting year, the latest available emission factors have been used.
Emissions calculated based on primary data represent 1.01% of total Scope 3
emissions.
When calculating the carbon footprint of the XTB S.A. Capital Group, the following
assumptions and/or exclusions were made:
Scope 1
▪ Stationary combustion (fuel consumption in emergency power generators
and fuel consumption for heating buildings):
o In one XTB location, the fuel consumption in emergency power generators was
provided, which applies to the entire building, not the area rented
by the company. Due to the lack of information on the percentage of space rented
by XTB S.A. in relation to the total area of the building, it was decided that
emissions from this XTB S.A. location will be calculated based on whole building
consumption.
o In one of the XTB S.A. locations, fuel consumption in emergency power
generators for the entire year 2023 was given with the information that data
for 2024 would be available at the end of 2025. In connection with the above,
the consumption for 2024 was estimated taking the value for the entire year 2023.
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o In one of the branches of XTB S.A., the consumption of natural gas for heating
purposes in the building was estimated based on data on the percentage share
of space rented by the company in comparison to the area of the entire building.
▪ Mobile combustion:
o Most XTB branches do not have vehicles in their car fleet.
o In some branches, fuel consumption in private passenger cars for business
trips was provided. Therefore, it was decided to include emissions from this
source in category 6 of Scope 3.
▪ Refrigerant leaks:
o In one of XTB S.A.'s locations, the value of refrigerant leakage was estimated
based on information on the value of leakage for specific storeys of the building
and the percentage ratio of the area rented by the company to its total area.
o At one XTB location, the refrigerant leakage value was reported for the entire
building, not the area rented by the company.
o Due to the lack of information on the percentage of space rented by XTB
in relation to the total area of the building, it was decided that emissions from
this location would be calculated based on the reported refrigerant leakage
for the entire building.
o Due to the lack of data in some XTB S.A. locations. on refrigerant leaks,
it was decided that emissions from these locations will be excluded from
the calculation of the XTB S.A. Group's carbon footprint for 2024.
▪ Renewable energy production:
o None of the companies in the XTB S.A. Capital Group have been recorded
as having an installation that generates electricity from renewable sources
and is owned or controlled by any of the companies in the XTB S.A. Group.
Scope 2
▪ Electricity:
o In one of XTB S.A.'s locations, there was a lack of data on the name
of the electricity supplier. Therefore, emissions from this location were
calculated with the location-based indicator appropriate for this location.
o In the absence of data on electricity consumption, it was estimated either
based on information on the climate zone and type of heating, where
consumption was calculated based on another company with similar
characteristics or estimated based on data for the second half of 2023.
o In the absence of data for part of the reporting period, results from the same
period of previous years were extrapolated.
o In the absence of information on the emissions of electricity produced
by a given supplier for XTB Group companies, it was decided to use location-
based indicators for the given countries.
o Due to the lack of information from both electricity suppliers and national
non-CO2 greenhouse gas emission factors, only CO2 emissions were
included in the calculations of electricity emissions, both in the market-
and location-based approaches.
o The average emission factors for the countries include transmission losses,
which according to the GHG Protocol should be included in Scope 3 Category
3. It was not possible to separate out the electricity transmission losses,
so they had to be included in the Scope 2 calculations.
o Due to the lack of other information from electricity suppliers, it was assumed
that transmission losses are already included in the suppliers' emission
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factors. Therefore, direct emissions from transmission losses were not
included again in Scope 3 Category 3.
▪ Thermal energy – district heating:
o Due to the lack of data for the consumption of heat energy - district heating
for 2024 in some XTB S.A. locations, they were estimated based on data
for the consumption of heat energy - district heating based on data from the
period 01.06-31.12.2023 or for 2023.
o In the absence of the name of the district heating supplier, it was decided
to use the location-based indicator for countries.
o Due to the lack of information from both district heating suppliers
and in the national indicator for Poland on greenhouse gas emissions other
than CO2 in the calculations of emissions from district heating,
both in the market- and location-based approach, only CO2 emissions were
included.
o The average emission factor for the country includes transmission losses,
which according to the GHG Protocol should be included in Category 3
of Scope 3. It was not possible to separate the emissions from district heating
transmission losses, so they had to be included in the Scope 2 calculations.
o In the absence of other information from the district heating supplier,
it was assumed that emissions from transmission losses are already included
in the supplier's emission factor. Therefore, direct emissions from transmission
losses were not included again in Category 3 of Scope 3.
Scope 3
Category 1: Purchased goods and services:
▪ The calculations were made based on a list of expenditure cost accounts from
the accounting settlements provided. Due to the lack of information
on the country of origin of the purchased products, the emission indicators were
adjusted in accordance with the country of operation of the company/ branch,
based on the Exiobase database.
▪ According to the GHG Protocol standard, data for calculations using
the expense-based method should refer to net amounts. On the other hand, XTB
S.A. and its subsidiaries, as financial entities providing mainly VAT-exempt
services, use the deduction of input VAT according to the structure or do not
deduct VAT. As a result, the companies' costs are increased by the part of input
VAT that is not deductible. In connection with the above, it was decided that the
expense data will refer to various types of amounts.
▪ All items that do not generate emissions and fees and costs of ongoing
maintenance (e.g. rent and utilities - emissions from these sources are included
in the calculations of Scopes 1 and 2), business trips (accommodationnand
transport - included in Category 6), expenses related to the operation of cars
(including fuel - included in Scope 1), fixed lump sums and vehicle insurance
were excluded from the calculations. The costs of drinking water, municipal
sewage (emissions from these sources were calculated based on consumption
data) and postal and courier services (included in Category 4) were also
excluded.
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▪ In the case of missing or incomplete data regarding water consumption, it was
decided to estimate these deficiencies based on data from other XTB S.A. entities
or by extrapolation.
▪ No formal cut-off point was used to exclude expenses. However, for some purchase
categories for which no explanation was obtained, a decision was made to exclude
them, provided that they accounted for less than 5% of total expenditure.
▪ Due to the impossibility of separating the amounts related to the transport
of purchased materials and products, they were included in this Scope 3 category
Category 2: Capital goods
• Calculations were made based on fixed asset lists prepared by accountants
of individual companies/branches. Emissions of almost 47% of fixed assets were
calculated based on EPD cards prepared by manufacturers. Emissions of about 25%
of fixed assets were calculated using average indicators per device.
In turn, the method based on expenditures was used to calculate emissions
from the remaining 28%.
5
Średni wskaźnik na urządzenie został wyznaczony na podstawie kart EPD innych urządzeń należących
do tej samej kategorii.
Table 15. Distribution of methods used for emission calculations in Scope 3
category 2
IV.Method
V.Number
of fixed assets
VI.% share
VII.Emissions
[kg
CO2e/year]
VIII.% share
IX.EPD Cards
X.513
XI.47,37%
XII.84 249,22
XIII.16,03%
XIV.Average rate
per device
5
XV.269
XVI.24,84%
XVII.
XVIII.123 069,99
XIX.
XX.23,41%
XXI.Expenditure-
based method
XXII.301
XXIII.27,79%
XXIV.318 361,75
XXV.60,56%
According to the GHG Protocol standard, data for calculations using the expense-based
method should refer to net amounts. On the other hand, XTB S.A. and XTB S.A. subsidiaries,
as financial entities providing mainly VAT-exempt services, use the deduction of input VAT
according to the structure or do not deduct VAT. As a result, the companies' costs are
increased by the part of input VAT that is not deductible. The same applies to the value
of fixed assets. In connection with the above, it was decided that the expense data will refer
to various types of amounts.
Category 3: Energy and fuel emissions outside Scope 1 and 2
▪ Category was calculated using the location-based method
6
▪ Electricity:
6
Więcej informacji w GHG Protocol Scope 2 Guidance, Appendix B
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o For WTT emissions from transmission losses in Poland, information
on the amount of losses from KOBIZE was included.
o For WTT emissions from transmission losses, information was included
on the amount of losses for a given country from Enerdata.
▪ Thermal Energy – district heating:
o Due to the lack of information on greenhouse gas emissions other than CO2,
only CO2 emissions were assumed in the average indicator for Poland.
o The WTT (generation) emission factor for district heating was calculated based
on the percentage increase in emissions from heat supplied to the network
compared to the amount of emissions from heat produced. This percentage was
applied accordingly to the average emission factor for district heating in Poland
for 2023.
o For WTT emissions from transmission losses for Poland, information
on the amount of losses from URE was taken into account.
o For WTT emissions from transmission losses for Germany, information
on the amount of losses from Umweltbundesamt was taken into account.
o For WTT emissions from transmission losses for France, information
on the amount of losses from FENEDE was taken into account.
Category 4: Upstream – transport and distribution
▪ This category partly takes into account data provided by companies and data based
on cost accounts. Therefore, the amounts given are not net amounts in all cases,
as required by the GHG Protocol standard.
Category 5: Waste generated as a result of business activities
• For all branches and companies of XTB S.A., it was assumed that wastewater
production is equal to water consumption given in category 1 of Scope 3
of the carbon footprint of the XTB S.A. Capital Group for the year 2024.
• GHG emission factors for the waste disposal method as landfill/landfill include
collection, transport and GHG emissions from landfills, while for other disposal
methods only transport emissions are taken into account.
• In the absence of data, estimates were made by extrapolating consumption from
the given period to the entire year 2024 or estimating based on other companies
of the XTB Group.
• For mixed municipal waste and bio-waste with the selected disposal method
as recycling, due to the lack of an emission factor for this given fraction
with the selected method of management of this waste, the indicator for the disposal
method of incineration was used, which takes into account the same emissions
as the indicator for recycling, i.e. transport alone.
• In the absence of data on the weight of electronic waste, it was estimated based on
information on the average weight of a given type of device calculated on the basis
of data on the weight of devices that were purchased in a given year 2024.
• For electronic waste such as laptops, monitors, servers, docking stations and PCs,
average emission factors for product disposal were used, derived from information
provided in the EPD cards of electronic devices that were purchased in 2024
by all branches and companies of XTB S.A. For the remaining electronic waste,
emission factors provided by the DEFRA 2024 database were used.
• Category 6: Business trips
In some companies, travel calculations include data based on cost accounts.
Therefore, the amounts given are not net amounts in all cases, as required
by the GHG Protocol standard.
▪ For accommodation, in the absence of information on the country in which
the delegation took place, the country in which the given branch or subsidiary of the
XTB Group operates was assumed. In some companies, accommodation
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calculations include data based on cost accounts, therefore, the amounts given are
not net amounts in all cases, as required by the GHG Protocol standard.
Category 7: Employee commuting
▪ Emissions in this category were calculated based on a survey on commuting
and remote work, which was completed by employees of the XTB S.A. Capital
Group. 56% of employees completed the survey on commuting to work, and then
the collected data was extrapolated to all employees.
▪ This category includes direct emissions from fuel combustion and the production
of consumed electricity, but also indirect emissions for these sources,
i.e. WTT emissions and direct and WTT emissions from losses in the transmission
of electricity.
▪ According to the GHG Protocol, WTT emissions for this Category do not have
to be included, but may be included, while in the calculations for the XTB S.A. Capital
Group they were included and amount to approx. 126 t CO2e, which is approx. 20%
of total emissions in this Scope 3 category.
Category 8:
Due to the adopted organisational boundaries, emissions associated with operating leased
assets are already included in Scope 1 and Scope 2.
Category 9:
XTB S.A. Capital Group does not conduct any activities related to the transport of products
to customers, therefore this category does not apply to it.
Category 10:
This category does not apply to the activities of XTB S.A. Capital Group, because
the company does not produce or sell goods requiring further processing by customers.
Category 11: Use of sold products
▪ Emissions were calculated in accordance with the international ICT standard, based
on actual application usage data collected in 2024. The input data on which
the calculations were based includes the average user login time from each country,
divided into interfaces: mobile application (APP) and xStation platform (WEB).
The analyses carried out, which were carried out separately for individual and retail
customers, refer only to the aforementioned annual period, which means that
the results represent emissions related only to this time.
▪ For devices with Linux, Macintosh, or Windows operating systems, we assume that
the user is using a desktop computer and monitor, because laptops have much lower
power consumption. We do not have data on the actual share of laptops
in the market, so we take a conservative approach and assume the use of a PC plus
monitor set.
▪ For phone-type devices, due to the lack of data on power consumption during use,
we determined average values for individual operating systems. We then calculated
a weighted average, taking into account each system's share of the global phone
market. We used the same procedure to determine the average power consumption
for tablets.
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▪ Due to the lack of detailed information on the electricity consumption of end-user
devices when using the app, it is assumed that the electricity consumption attributed
to the app is equal to the total energy consumption of the device. Emissions resulting
from data transfer are also included in this category, with the average data transfer
per session determined based on the test conducted.
▪ Under the Corporate Value Chain (Scope 3) Accounting and Reporting Standard,
emissions reported by a reporting company in Category 11 that arise from the use
of products sold include Scope 1 and Scope 2 end-user emissions. Therefore, WTT
emissions are not included in this Category.
Category 12:
In accordance with the ICT Sector Guidance built on the GHG Protocol Product Life Cycle
Accounting and Reporting Standard, software end-of-life emissions are only included
if the software was distributed on physical media, and the end-of-life emissions of these media
should be taken into account. However, the XTB S.A. Capital Group does not provide software
in physical form, therefore this emission category does not apply to the Group.
Category 13:
XTB S.A. Capital Group does not conduct any activity related to the rental of assets, hence
this category does not apply to the Group.
Category 14:
XTB S.A. Capital Group does not conduct franchise activities, therefore franchise-related
emissions do not apply to the Group.
Category 15:
At XTB S.A. Capital Group shares are purchased on a trust basis, to which their rights are
assigned to clients as fractional shares. The XTB S.A. Capital Group, in accordance with
the agreement, accepts an order to purchase fractional shares and undertakes to acquire
the entire share of the company selected by the client. Thanks to this, the client has
the opportunity to benefit in proportion to the share portion. Thus, the XTB S.A. Capital Group
does not have the ability to select companies and manage the portfolio, because they are the
result of client transactions on fractions. According to information provided by the XTB S.A.
Capital Group, the scale of shares held by the XTB S.A. Capital Group from such transactions
is small.
In addition, XTB S.A. invests part of its cash in bank deposits and financial instruments,
i.e. treasury bonds, bonds guaranteed by the State Treasury and corporate bonds guaranteed
by banks, which are a capital investment, among others, protecting the funds held
by the Company against inflation. The above bonds are instruments measured at fair value
through profit or loss.
In accordance with the standard Financed Emissions The Global GHG Accounting
& Reporting Standard Part A published by the Partnership for Carbon Accounting Financials
and approved by GHG Protocol in connection with compliance with the GHG Protocol
Corporate Accounting and Reporting Standard:
▪ The company should have the discretion to decide which shares of companies
it buys.
▪ Items that are small may be excluded from the financial calculations of emissions.
▪ Emissions from assets that are held for a short period or those that are intended
for sale are not taken into account.
▪ Emissions from assets that are measured at fair value are not taken into account.
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In connection with the above, the XTB S.A. Capital Group is not required to report greenhouse
gas emissions from the above shares and bonds held on the balance sheet of the XTB S.A.
Capital Group as at 31.12.2024 in Category 15 of Scope 3.
E1-6 From 2024, the XTB Group began calculating the full greenhouse gas emissions
generated by its operations. In the course of calculating all emission ranges of the XTB Group,
only publicly available spreadsheets (MS Excel) were used. To assess the level of emissions
intensity, the GHG emission factor per 1 million net revenue is used at the XTB Group level.
In recalculation of XTB Group's emissions, data were estimated in the following scopes and
categories: Scope 1 (stationary combustion, fugitive emissions), Scope 2 (electricity, district
heating), Scope 3 cat. 1 (water consumption), Scope 3 cat. 5 (waste generated) and Scope 3
Cat 7 (employee commuting and remote working).
The greenhouse gas emission calculations are not subject to approval by an independent
external entity, except for the sustainability certification. The calculations were carried out with
an external expert who certified the calculations as confirmation of their correctness.
E1-6 / MDR-M In 2024, all electricity consumed within the XTB Headquarters operations
came from renewable energy sources, which was confirmed by guarantees of origin of energy.
At the Headquarters (Skyliner office building in Warsaw), in proportion to the energy used
in the entire building, the energy consumed by XTB within the leased space can also
be considered as coming from renewable sources. The share of consumption of externally
purchased electricity from renewable sources (wind energy) confirmed by a guarantee
of origin certificate and approved by the Polish Power Exchange is 15.64% in the total
consumption of externally purchased electricity of the XTB S.A. Capital Group.
Both the purchased electricity and OZA energy came from the same supplier. The XTB Group
does not resell energy to third parties. Data on electricity consumption in the XTB Group,
collected for the purposes of calculating greenhouse gas emissions in 2024, were also used
to monitor the identified significant impact of the XTB Group on the climate and environment
related to the energy-intensive IT infrastructure.
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Table 16. Scope 1, 2 and 3 greenhouse gas gross emissions and total
greenhouse gas emissions.
Unit
Base year
(2024)
Comparative
information
N
(2024)
Y/Y difference
(%)
Scope 1 greenhouse gas emissions
Scope 1 GHG gross emissions.
t CO
2
equivalent
not applicable
none
110,08
not applicable
Percentage of Scope 1 GHG emissions from regulated emissions
trading schemes
%
not applicable
none
0,00
not applicable
Scope 2 GHG emissions
Scope 2 GHG gross emissions by location-based method
t CO
2
equivalent
not applicable
none
729,40
not applicable
Scope 2 GHG gross emissions as per the market-based method
t CO
2
equivalent
not applicable
none
496,11
not applicable
Significant Scope 3 GHG emissions
Total gross indirect GHG emissions (scope 3)
t CO
2
equivalent
not applicable
none
25 248,96
not applicable
Category 1. Purchased goods and services
t CO
2
equivalent
not applicable
none
20 551,73
not applicable
Category 2. Investment goods
t CO
2
equivalent
not applicable
none
525,68
not applicable
Category 3. Fuel and energy activities (not included in scope 1
or 2)
t CO
2
equivalent
not applicable
none
169,29
not applicable
Category 4. Upstream transport and distribution
t CO
2
equivalent
not applicable
none
19,05
not applicable
Category 5. Waste generated by the operation
t CO
2
equivalent
not applicable
none
77,14
not applicable
Category 6. Business travel
t CO
2
equivalent
not applicable
none
612,35
not applicable
Category 7. Employee commuting
t CO
2
equivalent
not applicable
none
627,57
not applicable
Category 8. Leased senior assets
t CO
2
equivalent
not applicable
none
not applicable
not applicable
Category 9. Downstream transport
t CO
2
equivalent
not applicable
none
not applicable
not applicable
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Category 10. Processing of products sold
t CO
2
equivalent
not applicable
none
not applicable
not applicable
Category 11. Usage of products sold
t CO
2
equivalent
not applicable
none
2 666,15
not applicable
Category 12. Processing of sold products at end of life
t CO
2
equivalent
not applicable
none
not applicable
not applicable
Category 13. Leased downstream assets
t CO
2
equivalent
not applicable
none
not applicable
not applicable
Category 14. Franchises
t CO
2
equivalent
not applicable
none
not applicable
not applicable
Category 15. Investments
t CO
2
equivalent
not applicable
none
not applicable
not applicable
Total greenhouse gas emissions
Total greenhouse gas emissions
(location-based method)
t CO
2
equivalent
not applicable
none
26 088,44
not applicable
Total greenhouse gas emissions (market-based method)
t CO
2
equivalent
not applicable
none
25 855,14
not applicable
GHG intensity per net revenue
Total greenhouse gas emissions (location-based) per net revenue
(tCO2-equivalent/ mln net revenue)
t CO
2
equivalent
not applicable
none
13,93
not applicable
Total greenhouse gas emissions (market-based) per net revenue
(tCO2-equivalent/ mln net revenue
t CO
2
equivalent
not applicable
none
13,80
not applicable
Scope 1 emissions, i.e. emissions directly related to fuel consumption in buildings
and transport in 2024 in the XTB Group, amounted to 110,08 t CO2e, representing 0,43%
of the XTB Group's total greenhouse gas emissions (Scope 1 + Scope 2 market-based
+ Scope 3).
Scope 2 emissions, or indirect emissions, resulted from the generation of purchased electricity
and heat. In 2024, they amounted to 496,11 t CO2e, representing 1,92% of the XTB Group's
total greenhouse gas emissions (Scope 1 + Scope 2 market-based + Scope 3).
The vast majority of the XTB Group's emissions in 2024 were Scope 3 emissions, i.e. indirect
emissions across the value chain, amounting to 97,65% of all emissions. Based
on the completed calculations, there is clear variation between the emissions in the different
Scopes and Scope 3 categories. Category 1 of Scope 3 dominates, accounting
for 20 551,73 t CO2e, which is approx. 79,49% of the organisation's overall carbon footprint.
The high values in this category are due to the nature of the company's business, which
generates significant expenditure on services, primarily marketing.
The other categories are characterised by much lower emission values fluctuating
between 19,05 (Category 4. Transport and distribution in upstream) and 2 666,15 t CO2e
(Category 11. Use of products sold). Although these categories and Scopes contribute
to the total emissions, their share is much smaller, accounting for only 18,16%
of the organisation's emissions.
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Table 17. Calculation methods for individual Scope 3 emission categories
Categories
of Scope 3
Name of the method
Category 1
Average-data method (zużycie wody)
Supplier-specific method
Spend-based method
Category 2
Supplier-specific method
Average-product method
Average spend-based method
Category 3
Average-data method
Category 4
Spend-based method
Category 5
Waste-type-specific method
Category 6
Fuel-based method
Distance-based method
Spend-based method
Category 7
Distance-based method
Category 11
Products that directly consume energy (fuels or electricity)
during use
The following is a summary of the methods for
7
calculating GHG emissions
for purchased goods and services and capital goods.
7
The methods are derived from the GHG Protocol. Technical Guidance for Calculating Scope 3 Emissions (version 1.0).
Supplement to the Corporate Value Chain (Scope 3) Accounting & Reporting Standard, 2013. World Resources Institute
and World Business Council for Sustainability.
Table 18. Emission calculation methods for purchased goods, services
and capital goods
Method
Data
Calculation of emissions
Supplier-specific method
Supplier-specific data on GHG
emissions of its
products/services/capital
goods
Cradle-to-gate capital
product GHG emissions
from suppliers of goods/
services/ capital goods
Hybrid method
GHG emission data from
suppliers + secondary data in
case of lack of data from
suppliers
Scope 1 GHG emissions
and 2 produced by
suppliers, primary
emissions from supplier
activity data
Average-data method
Data on the weight or other
relevant units of goods and
services and capital goods
purchased
Assumption based on
mass multiplication by
average emission factor
per unit of good or service
Spend-based method
Data on the economic value of
goods and services and capital
goods purchased
Economic value multiplied
by average emission
factors per monetary value
of goods
The supplier-specific method has the best data quality, while the spend-based
method is the least precise.
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Calculation methodology
E1-7 / E1-8
The XTB Group does not engage in greenhouse gas removal and mitigation projects funded
through carbon credits and does not internally set a greenhouse gas fee. As 2024 is the base
period for the comprehensive calculation of the XTB Group's greenhouse gas emissions,
no emission reduction targets have been set.
E1-9 In the first reporting periods, the XTB Group uses the exemption within the framework
of the anticipated financial effects from significant physical risks and transition risks as well
as from potential climate-related opportunities.
2.2. Compliance of XTB Group's activities
with the Taxonomy
2.2.1. Non-financial taxonomy
Contextual information – indicators for non-financial companies
The analyses conducted in relation to the EU Taxonomy were based on the package of EU
Taxonomy provisions in force at the time of preparation of this Statement, i.e.:
▪ Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June
2020 on establishing a framework to facilitate sustainable investment;
▪ Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing
Regulation (EU) 2020/852 of the European Parliament and of the Council
by establishing technical eligibility criteria for determining the conditions under which
an economic activity qualifies as making a significant contribution to climate change
mitigation or adaptation and whether that economic activity does not cause
significant harm to any other environmental objective;
▪ Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 – supplement
to the Regulation (EU) 2020/852 of the European Parliament and of the Council
clarifying the content and presentation of the information on environmentally
sustainable business activities to be disclosed by companies subject to Art. 19a
or 29a of the Directive 2013/34/EU and to specifying the method for compliance with
this disclosure obligation;
▪ Commission Delegated Regulation (EU) 2022/1214 of 9 March 2022 amending
Commission Delegated Regulation (EU) 2021/2139 as regards economic activities
in certain energy sectors;
▪ Commission Delegated Regulation (EU) 2023/2485 of 27 June 2023 amending
Delegated Regulation (EU) 2021/2139 laying down additional technical eligibility
1 873 436 475 PLN
Net revenues used to calculate greenhouse gas
emissions intensity
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criteria for determining the conditions under which certain economic activities qualify
as making a significant contribution to climate change mitigation or adaptation,
and whether those activities do not cause significant damage to any other
environmental objective;
▪ Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023. supplementing
Regulation (EU) 2020/852 of the European Parliament and of the Council
by establishing technical qualification criteria to determine the conditions under
which an economic activity qualifies as making a significant contribution
to the sustainable use and conservation of water and marine resources,
to the transition to a closed loop economy, to the prevention and control of pollution,
or to the protection and restoration of biodiversity and ecosystems, and whether that
economic activity does not cause serious harm to any other environmental objective,
and amending Commission Delegated Regulation (EU) 2021/2178 as regards
the public disclosure of specific information in relation to those economic activities;
▪ OECD Guidelines for Multinational Enterprises and UN Guiding Principles
on Business and Human Rights, including the principles and rights set out in the
eight fundamental conventions identified in the Declaration of the International Laur
Organisation on Fundamental Principles and Rights at Work and the International
Bill of Human Rights.
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The assessment of compliance with the non-financial taxonomy has been carried out on the
basis of existing regulations, including Regulation (EU) 2020/852 on establishing a framework
to facilitate sustainable investment and related delegated acts. As a part of the assessment,
regulated business activities were identified. The qualification process took into account
companies that are part of the XTB Group and whose activities were defined
as "non-financial", namely:
▪ XTB Agente de Valores SpA (Chile)
▪ XTB Services Limited (Cyprus)
▪ X Open Hub Sp. z o.o. (Poland)
▪ XTB Digital Limited (Cyprus)
▪ Tasfiye Halinde XTB Yonetim Danismanligi A.S. (Turkey)
Based on interviews, workshops with representatives of the Companies and an analysis of the PKD codes (and their relationship to NACE codes), the following were finally qualified for taxonomic
evaluation:
Table 19. Activities eligible for the Taxonomy
Name of activity according to PKD classification
Name of activity according to EU taxonomy classification
62.01.Z – Software activities (X Open Hub Sp. z o.o.)
Software activities, IT consultancy and related activities
62 – Computer programming, IT consultancy and related activities (X Open Hub Sp. z o.o.)
63 – Information service activities (X Open Hub Sp. z o.o.)
Data processing; website management (hosting) and related activities
For qualified activities, a detailed analysis was carried out to confirm whether the qualified activity:
▪ makes a significant contribution to one or more of the six environmental objectives,
▪ does not cause serious harm to any environmental objective,
▪ is carried out in accordance with minimum guarantees and
▪ meets the technical eligibility criteria.
The necessary evidence was collected to demonstrate compliance and, where documentation was not available, statements and checklists were used to verify compliance with the criteria and/or
the implementation of the relevant procedures.
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Based on the data collected, it was determined that:
Table 20. Activity evaluation
Name of activity according to EU
taxonomy classification
Meeting the criteria for a significant
contribution
Complying with the DNSH (Do No
Significant Harm) principle
Compliance with minimum guarantees
Computer programming, IT consultancy and
related activities
YES
(demonstrated for objective 2: climate
change adaptation)
YES
YES
Data processing; website management
(hosting) and related activities
NO
NO
YES
Accordingly, the activities qualified for assessment were identified as:
Table 21. The result of assessing compliance with the Taxonomy
Name of activity according to EU taxonomy classification
Final evaluation of activities
Computer programming, IT consultancy and related activities
Eligible, in line with the eligible taxonomy, aligned
Data processing; website management (hosting) and related activities
Eligible, not in line with taxonomy
eligible, not aligned
The above assessments formed the basis for the preparation of taxonomic disclosures based on three key indicators (KPIs), described below.
For the purpose of calculating non-financial indicators, no disaggregation of data was carried out. For none of the activities included in the Taxonomy was production for so-called own consumption.
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a) Turnover rate
Table 22. Turnover ratio – the percentage of turnover complying with the scheme in 2024 relative to the same period in the previous year.
2024
2023
Value of revenues
[PLN thousand]
Share of revenue
[%]
Value of revenue [PLN
thousand]
Share of revenue [%]
Activities aligned
with the systematics
5 061
0,27
0
0,0
Activities not aligned
with the systematics
1 868 375
99,73
1 618 385
100,0
Total:
1 873 436
100,0
1 618 385
100,0
For the turnover rate:
▪ based on the Group's total consolidated revenue in 2024 as disclosed in the consolidated financial statements, i.e. PLN 1,873,436 thousand;
▪ For the purpose of the numerator analysis in respect of 2024, revenue from the sale of products and the provision of services related to XTB Group's activities assessed to be in line with
the Taxonomy entitled: Software, IT consultancy and related activities was identified.
XTB Group companies have not issued organic bonds or debt securities to finance specific identified activities aligned with the systematics.
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b) Capital expenditure ratio
Table 23. Capital expenditure ratio – the percentage of capital expenditure in 2024, aligned with systematics, relative to the same period in the previous year.
2024
2023
Capital Expenditure
[PLN thousand].
Share of capital expenditure [%]
Capital expenditure
[PLN thousand].
Share of capital expenditure [%]
Activities aligned
with the systematics
4.82
0.02%
0
0
Activities not aligned
with the systematics
20 656
99.98%
14 567
100%
Total:
20 661
100%
14 567
100%
For the capital expenditure indicator:
▪ the basis was capital expenditure in the XTB Group totalling approx. 20 661 thousand calculated on the basis of the IAS/IFRS provisions indicated in the Annex to Regulation 2178;
▪ for the purposes of the 2024 numerator analysis, revenue was identified from the sale of products and provision of services related to XTB Group's activities assessed to be in line with
the Taxonomy entitled: Software, IT consultancy and related activities.
XTB Group has not adopted a capital expenditure investment plan as referred to in paragraph 1.1.2 of Annex 1 to Regulation 2178. Group companies did not issue green bonds or other securities
to finance specific identified capital expenditures aligned with the systematics.
c) Operating expenditure ratio
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Table 24. Operating expenditure ratio – the percentage of operating expenditure in 2024, aligned with the systematics, relative to the same period in the previous year.
2024
2023
Operational expenditure
[PLN thousand].
Share of operational expenditure
[%]
Operational expenditure
[PLN thousand].
Share of operational
expenditure
[%]
Activities aligned with the systematics
4 907
0,55%
0
0
Activities not aligned
with the systematics
881 793
99,45%
694 230
100%
Total:
886 701
100%
694 230
100%
For the operational expenditure indicator, a component item analysis of operational expenditure was carried out as defined by the EU Non-Financial Taxonomy, resulting in a denominator value
for the operational expenditure indicator of approx. PLN 886,701 thousand.
For the purposes of the 2024 counter analysis, revenue was identified from the sale of products and provision of services related to XTB Group's activities assessed to be aligned with the Taxonomy
entitled: Software, IT consultancy and related activities.
Performance tables for the turnover, capital expenditure and operating expenditure indicators respectively are included in in a further part of this report.
2.2.2. Financial taxonomy
Contextual information – indicators for investment companies
Art. 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June
2020 establishing a framework to facilitate sustainable investment, 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 compatible with business activities
that qualify as environmentally sustainable under Art. 3 and 9 of the same Regulation.
It should be clarified that, given XTB Group's specific business model, which includes
operating on the OTC market, the key disclosure indicators related to its asset portfolio
resulting from its proprietary trading activities differ significantly from the significance of such
data for other financial companies and investment firms.
In particular, it should be pointed out that while XTB holds a portfolio of financial assets,
this portfolio of assets does not have the character of a classic investment portfolio. XTB
Group is not in the business of financing business activities or investment projects.
On the other hand, given the XTB Group's business model, income of an operational nature
is generated from its portfolio of financial assets. The result on financial assets at fair value
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through profit or loss represents the result on financial instruments from transactions with
clients and brokers.
Table 25. Information on the portfolio of assets measured at fair value through profit or loss. The assets included in this portfolio correspond to those invested in the investment company's
proprietary trading business.
As for 31.12.2024
As for 31.12.2023
Value [in PLN
thousand]
Share of in total
Group assets
[%].
Share in financial assets
valued at fair value
through financial
outcome
Value [in PLN
thousand]
Share in total
Group assets
[%]
Share in financial
assets valued at fair
value through financial
outcome
Derivatives contracts for differences
(CFDs)
521 792
7,8%
46,4%
485 303
10,3%
53,7%
Debt instruments (government bonds
and corporate bonds)
429 648
6,5%
38,2%
401 265
8,6%
44,4%
Shares and ETPs
172 483
2,6%
15,4%
16 687
0,4%
1,9%
Total assets invested in the proprietary
trading business of an investment firm
1 123 923
16,9%
100%
903 255
19,3%
100%
Total assets (balance sheet total)
6 645 632
100%
n.a.
4 688 658
100%
n.a.
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The structure of the portfolio of financial assets indicated above consists of: Derivatives – for
which the percentage of total assets invested within the activities of investment firms for
proprietary trading exposure referred to in Art. 7 sec. 2 of Regulation 2021/2178,
i.e. derivatives, is 46.4%.
government and corporate bonds – the percentage of total assets invested within the activities
of investment firms for proprietary trading exposure referred to in Art. 7 sec. 1 of Regulation
2021/2178, i.e. exposures to central governments, central banks and supranational issuers,
is 38.2%.
The remainder of XTB's asset portfolio consists of equities and Exchange Traded Product
(ETP) units. The shares and ETP units held are responsible for approx. 15.4% of the portfolio
above and 2.6% of total assets. The shares held in the portfolio in question are collateral
for a transaction in which an XTB client acquires a so-called synthetic share. Thus,
the composition of the equity portfolio is mainly driven by the structure of orders received from
clients and brokers. The composition of the equity portfolio held is adjusted on an ongoing
basis to meet subsequent client orders. Accordingly, the Issuer does not, at any stage
of the creation of the portfolio in question, assess or take into account aspects that would
be linked to the eligibility or compatibility of the assets concerned from the point of view
of the Financial Taxonomy. The above significantly differentiates XTB Group's asset portfolio
from the loan portfolio of a credit institution or the investment portfolio of an investment fund
or analogous entity. In practice, the composition of the portfolio of non-financial assets within
the XTB Group may change on a daily basis, significantly and unintentionally. The structure
of the portfolio, in particular equity portfolio, is therefore almost random from the point of view
of the eligibility of individual issuers' activities to the Financial Taxonomy.
For reporting purposes, an assessment was made for taxonomy eligibility and XTB Capital
Group's activities were classified as a Financial Enterprise pursuant to the provisions of Art.
5 of Commission Delegated Regulation (EU) 2021/2178, resulting in the need to complete
the templates contained in Annex VIII of that regulation.
Pursuant to Art. 7 sec. 1 to 3 of Commission Delegated Regulation (EU) 2021/2178,
exposures to central governments, central banks and supranational issuers are not included
in the numerator and denominator of the key performance indicators, in addition,
this numerator also does not include derivatives and exposures to corporates that are not
subject to the obligation to publish non-financial information pursuant to Art. 19a or 29a
of the Directive 2013/34/EU.
Pursuant to Art. 7 sec. 6 of Commission Delegated Regulation (EU) 2021/2178, the numerator
and denominator of the key performance indicators are divided into the exposure categories
listed in the provision.
Transactions concluded for own account:
The asset-related key performance indicators described in Art. 2 Annex VII of the Commission
Delegated Regulation (EU) 2021/2178, have not been calculated, because XTB S.A. Group
Companies did not execute proprietary transactions in 2024 other than:
▪ bond purchase,
▪ transactions related to orders from clients on derivatives,
▪ the purchase of shares and ETPs of an ancillary nature for the execution of retail
client orders.
Bonds may not be included in the numerator and denominator of key performance indicators
in accordance with Art. 7 sec. 1 of Commission Delegated Regulation (EU) 2021/2178.
Transactions for the own account of XTB S.A. Group companies were therefore in 2024
primarily transactions related to client orders in derivatives. However, derivatives may not be
included in the numerator of key performance indicators pursuant to Art. 7 sec. 2
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of Commission Delegated Regulation (EU) 2021/2178 which reads: "Derivatives shall
be excluded from the numerator of key performance indicators of financial corporations".
By definition, derivatives do not constitute investments in companies within the meaning
of Art. 2 Annex VII of Commission Delegated Regulation (EU) 2021/2178, as they are
a financial instrument value of which depends on the value of the underlying instrument, which
may be a stock, bond, currency or stock index, and the purpose of using derivatives is not
to transfer capital but to transfer risk. Also, the purchase of shares and ETPs in an ancillary
capacity in order to execute retail clients' orders does not constitute proprietary trading,
as it only concerns the taking of positions in order to trade for clients' accounts.
According to the information above, there is no grounds to calculate the key performance
indicators related to assets, as indicated in formula 1 in the Annex VIII of Commission
Delegated Regulation (EU) 2021/2178.
The main key performance indicator titled Total environmentally sustainable assets are 0%,
as the Art. 7 sec. 1 and 2 of Commission Delegated Regulation (EU) 2021/2178 stipulating
that it is excluded from the numerator and denominator and derivatives are excluded from the
numerator in the calculation of key performance indicators of financial corporations,
and in 2024 there were no transactions made on the company's own account other than those
listed above.
Transactions other than those made on company's own account:
XTB S.A Group companies in 2024 performed transactions other than those on its own
account, namely transactions related to orders from and for clients in the formula contained
in Annex VIII of Commission Delegated Regulation (EU) 2021/2178 that provides
performance indicators on revenue.
The amount of revenue generated in 2024 for the types of services listed below, required
for investment companies, is:
▪ reception and transmission of orders in relation to one or more financial instruments
– non applicable;
▪ execution of orders on behalf of clients: approx. PLN 15 741 thousand (including
PLN 0 from institutional clients) – at the end of 2024;
▪ trading on company's own account - (the following occurred: purchase of bonds
(approx. PLN 26 million – as at the end of 2024), derivative instruments (approx.
PLN 1,770 million, including approx. PLN 78 million from institutional clients – as at
the end of 2024), purchase of shares and ETPs of an ancillary nature in order
to execute client orders (approx. PLN 15 million – as at the end of 2024, including
PLN 0 from institutional clients);
▪ portfolio management – non applicable;
▪ investment advice - non applicable;
▪ underwriting of financial instruments or underwriting of financial instruments with
a guarantee of assumption of issue - non applicable;
▪ underwriting of financial instruments without a guarantee of assumption of issue –
non applicable;
▪ running the MTF – non applicable;
▪ running the OTF – non applicable.
Other revenues in addition to the above, i.e. those that are not required to be reported for
investment companies in the template included in the Annex VIII of Commission Delegated
Regulation (EU) 2021/2178 and thus not eligible for the Taxonomy, amounted to approx. PLN
73 million – stock at the end of 2024.
The XTB S.A. Group Companies executed in 2024 transactions on their own account, which
were related to client orders in the field of derivatives, for 45 institutional clients – listed in item
(c) in sec. 1 above. For the 4 institutional clients subject to the publication obligation,
a published ESG Report with taxonomic disclosures is available, so a questionnaire
requesting information on taxonomic disclosures was sent to 41 institutional clients. One client
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completed the taxonomic disclosure tables in response to the survey. Other clients do not
publish and have not provided taxonomic disclosures in their survey responses.
The main key performance indicator titled Total revenue from environmentally sustainable
activities and services is 0%, due to Art. 7 sec. 2 of Commission Delegated Regulation (EU)
2021/2178, stipulating that Derivatives are excluded from the numerator of key performance
indicators of financial corporations. Revenue from executing orders on behalf of clients,
amounted to PLN 0 from institutional clients and thus it is not possible to calculate the indicator
according to the method imposed by Art. 2.4 Annex VII of the Commission Delegated
Regulation (EU) 2021/2178: "the numerator shall be defined as the weighted average
of the revenues (fees, commissions other monetary benefits) earned by the investment firm
in relation to the total value of business consistent with the systematics within client business".
If there are no institutional clients in the category of revenue from the execution of orders
on behalf of clients, because they are exclusively individual clients, it is not possible to obtain
information on compliance with the systematics within the clients' activities. In contrast, in the
category of income from trading on company's own account, there is only income from
derivatives, excluded from the main performance indicator by Art. 7 sec. 2 of Commission
Delegated Regulation (EU) 2021/2178, the purchase of shares and ETPs of an ancillary
nature for the execution of orders of retail clients and the purchase of bonds,
which are excluded in the calculation of key performance indicators of financial undertakings.
Assignment to the relevant environmental objective of the revenues eligible for
systematisation in the corresponding row for revenues from transactions conducted on one's
own account in formula No. 2 contained in Annex VIII of Commission Delegated Regulation
(EU) 2021/2178 is based on the taxonomic disclosures of four institutional clients for which
there is a published ESG Report with taxonomic disclosures and one client not subject
to the publication obligation who has completed the taxonomic disclosure tables. The amount
of revenue from trading on company's own account, i.e. approx. 78 million at the end of 2024,
represents the sum of the revenues eligible for systematisation in formula No. 2 contained in
Annex VIII of Commission Delegated Regulation (EU) 2021/2178, but not in line with
the systematics, due to the exclusion of derivatives from the numerator. On the other hand,
revenue from the execution of orders for the account of clients is not included under revenue
eligible for systematics, as this revenue category does not include institutional clients, only
individual clients, for which it is not possible to obtain information on compliance with
systematics in the client activity reports.
Income from fractional shares related to individual clients only, there were no transactions
with fractional shares on behalf of institutional clients and therefore not included in the income
qualifying for the Taxonomy.
Given the assumption made regarding the non-qualification of assets for systematics,
the Issuer has also assumed that the percentage of total assets of the exposure referred
to in Art. 7 sec. 3 of Regulation 2021/2178, i.e. exposures to companies that are not subject
to the obligation to publish non-financial information pursuant to Art. 19a or 29a of Directive
2013/34/EU amounts to 0%.
The XTB Group did not modify the presentation of the indicators above compared
to the previous financial year.
The XTB Group does not engage in third-party financing activities.
The XTB Group companies did not issue green bonds and green debt securities to finance
certain identified activities and the XTB Group companies did not make investments in green
bonds and green debt securities issued by third parties. The XTB Group neither granted nor
has any special purpose loans in its portfolio.
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2.2.3. Minimum guarantees
Human and labour rights
XTB S.A. implements a due diligence process based on:
▪ due diligence in management, operational and strategic processes and implemented
corporate documents;
▪ cooperation with stakeholders (Stakeholder Survey, Employee Satisfaction Survey);
▪ identification of adverse impacts, taking action to mitigate them, risk management,
internal audit and compliance;
▪ monitoring the effectiveness of efforts and processes undertaken, updating
corporate documents, analysing reports received;
▪ taking appropriate remedial action.
We operate in accordance with the UN Guiding Principles on Business and Human Rights
and the OECD Guidelines. We are committed to respecting all human rights as recognised
and defined in internationally recognised documents such as:
▪ The 10 principles of the UN Global Compact,
▪ the Universal Declaration of Human Rights,
▪ the UN Guiding Principles on Business and Human Rights,
▪ the OECD Guidelines for Multinational Enterprises,
▪ the principles related to fundamental rights at work contained in 8. ILO
Fundamental Conventions as set out in the Declaration on Fundamental
Principles and Rights at Work and to avoid/minimise potential negative impacts
of XTB's activities on human rights.
As of 2019, XTB S.A. Head Office has a Code of Ethics in place, which sets out the basic
standards, principles of conduct and values. An implemented anonymous whistleblowing
procedure sets out the rules for making anonymous reports for actual or potential breaches
of the law, including breaches of anti-money laundering and counter-terrorist financing
regulations, internal procedures and ethical standards. Violations are reported in a dedicated
electronic form allowing anonymity.
Integrating accountability principles into management systems
XTB's governance system is based on transparent principles with a formal and legal
background to ensure transparent and responsible practices. The 2024 Double Materiality
Assessment, based on interviews, surveys and workshops with XTB stakeholders, detailed
material risks, material opportunities and material impacts. The analysis refers
to the indicators of the European Union ESRS sustainability reporting standards to ensure its
completeness. The results of the work made it possible to prepare sustainability reporting,
but also to update XTB's strategic directions and objectives, which reflect the organisation's
needs and plans over the assumed time horizon. In fostering relationships based on mutual
trust, we emphasise regulatory compliance, quality and accountability, reflecting the nature
of XTB's business as an investment firm.
Identification and assessment of negative effects
Within the framework of identified negative effects related to XTB's activities, we assess them
and take or plan adequate preventive actions. These actions are based on the company's
internal communication, procedural and formal background, and internal and external
whistleblowing procedure under whistleblower protection. The Head Office also has a Risk
Management Strategy and a Risk Management System in place, covering employees
and XTB subsidiaries. Its objective is to design and implement processes, design, develop
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and implement internal documents for, among other things, measuring, estimating, mitigating
and controlling risks.
Intervention, prevention and mitigation of effects
At XTB S.A., we do not tolerate any manifestations of discrimination or negative behaviour
detrimental to colleagues. We take preventive measures including internal communication,
procedural and regulatory back-up, as and a good working atmosphere within the
organisation. In the event of a reported breach, we undertake to carry out an internal
investigation, including interviewing witnesses, collecting evidence and analysing the
documentation collected, and to take appropriate remedial action, i.e. to carry out additional
employee training selected on the basis of the findings.
A key role in monitoring the compliance of XTB's activities with the law is played
by a Supervisory Inspector representing XTB's compliance area. Supervisory Inspector
performs their duties on the basis of the regulations implemented, the purpose of which is,
among other things, to establish a system for the supervision of compliance with the law,
aimed at disclosing and preventing breaches by XTB of its obligations under the laws
governing the conduct of brokerage activities.
The objectives of the business compliance oversight system at XTB are achieved through,
among other things:
▪ taking action to ensure that the Company complies with its obligations under the
laws governing the conduct of brokerage activities,
▪ consulting and ongoing assistance for persons carrying out activities as part of XTB's
brokerage activities in fulfilling their obligations in accordance with the legal
provisions governing their conduct,
▪ examining and regularly assessing the adequacy and effectiveness
of the compliance system adopted, as well as the actions taken to comply with XTB's
obligations under the laws governing the conduct of brokerage activities.
Ensuring the proper operation of the compliance system in XTB branches is the responsibility
of the person designated in the structure of the XTB branch concerned, who in this respect
reports directly to the Supervisory Inspector.
XTB's compliance risk management process includes identifying compliance risks, assessing
the likelihood of their occurrence, assessing the consequences of the occurrence of a given
compliance risk, assigning weights to individual risks, applying risk mitigation measures and
documenting the measures applied.
As part of XTB's compliance system, control proceedings are carried out at XTB's business
units in accordance with generally applicable regulations.
In 2024, one of XTB S.A.'s subsidiaries was the subject of a discrimination case, which was
concluded with a settlement at the beginning of 2025. In addition, there was a single labour
law proceeding in one branch and two incidents that ended with the withdrawal of a lawsuit
and a settlement, respectively. All submissions were reviewed and assessed by XTB.
There have been no enquiries from either the OECD National Focal Point or the Business
and Human Rights Resource Centre towards the Head Office or Group companies within the
last 12 months. The Company is subject to inspections by state institutions and the company
complies with all follow-up recommendations.
XTB S.A. is not active in the controversial arms manufacturing sector.
Anti-corruption
The Company has anti-corruption procedures and policies in place, i.e. XTB S.A.'s Anti-
Corruption Policy and XTB S.A.'s Code of Ethics. They include measures concerning gift
policy, as well as management of conflict of interest and corporate ethics. In addition,
an incentive management policy and conflict of interest management regulations have been
adopted at XTB. In addition, all centralised purchases (i.e. made in Poland) are carried out in
accordance with a dedicated procedure for the purchase of goods and services.
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XTB is an obliged institution within the meaning of the Anti-Money Laundering and Terrorist
Financing Act. In view of the need to ensure compliance with the aforementioned regulations,
XTB has adopted an AML/ CFT Procedure setting out detailed solutions, including
the responsibilities of employees of individual departments in the area of anti-money
laundering and terrorist financing. The rules for anonymous reporting of violations, including
Anti-Money Laundering and Counter-terrorist Financing violations, are set out
in a dedicated procedure.
XTB's suppliers, in accordance with the wording of their contracts with XTB, have been
obliged to familiarise themselves with the contents of XTB S.A.'s Anti-Corruption Policy and
to act in accordance with its provisions and to report any suspicions of corruption
and to support investigations.
No cases of corruption had been identified at XTB S.A.'s companies and branches during
the reporting period under review and no proceedings related to corruption-related offences
are pending.
Data and systems security
XTB pays the utmost attention to data and system security. Speaking of digital security,
access to the XTB xStation application is protected by authorising access with a password,
fingerprint or code. Connections between XTB servers and the XTB xStation application
are fully encrypted. XTB clients' funds are protected. The funds can only be withdrawn
to the client's account. Key information is authenticated in multiple stages. XTB's website has
content dedicated to XTB S.A.'s cyber security. The company provides information about
the types of digital risks at: https://pl.xtb.com/bezpieczenstwo-w-sieci
XTB S.A. has its own Cookies Policy and Privacy Policy. The Privacy Policy has been
prepared in accordance with the information obligation resulting from Art. 13 and 14
of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016
on the protection of natural persons with regard to the processing of personal data and on the
free movement of such data and repealing Directive 95/46/EC (General Data Protection
Regulation) (hereinafter: "GDPR"). A Data Protection Officer has been appointed at XTB S.A.
Tax area
XTB S.A. has a set of identified and described processes and procedures for managing
the fulfilment of its obligations under tax law and is able to ensure that internal controls for the
tax function are functioning properly. It has the appropriate personal, technical and financial
resources necessary to implement them and maintain oversight of the correct implementation
of tax obligations. XTB's tax strategy is to strive to create and maintain an effective and
transparent tax function within the company, which ensures compliance with tax regulations
and control of tax risks. In accordance with applicable law, we draw up and make public
information on the tax strategy implemented.
The company has tax risk management processes in place and tax governance and tax
compliance are an important element of tax supervision. XTB S.A.'s tax strategy is to strive
to create and maintain an effective, efficient and transparent tax function within the company,
which in effect ensures compliance with tax regulations and the certainty of tax risk control.
The Company has implemented appropriate management and control processes to ensure
that the operation complies with the applicable tax legislation, that the required tax returns
and information are submitted correctly and on time, and that taxes are paid. The Company's
books of account are kept in a reliable manner and enable the proper performance of any tax
obligations imposed on XTB. All business processes and ventures at XTB are carried out
taking into account the requirements for fulfilling obligations and tax processes.
The primary tax function within the Company's structure is the Tax Team which operates within
the Finance and Accounting Department and is managed by the Director of Taxes, supervised
by the Member of the Management Board for Finance (who is also the Chief Financial Officer).
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In order to manage the performance of tax obligations under tax law, the Company has
developed and implemented appropriate procedures, including an Instruction defining
the scope of responsibility for the performance of tasks on the subject of XTB S.A.'s tax liability
settlements. The roles, duties as well as responsibilities of the employees related
to the execution of the tax function are included in the document: Internal Organisational
Regulations of the Finance and Accounting Department dated 28 June 2024.
The Company also has other procedures in place, which are further elements of the tax
governance implemented, to address tax issues such as e.g. Internal Procedure for dealing
with non-compliance with the obligation to provide information on tax schemes.
Tax risks are identified and assessed on an ongoing basis, in the course of the day-to-day
work of the Tax Team staff, as well as being discussed during regular meetings between
the Tax Team staff and the Director of Taxes and between the Director of Taxes
with the Member of Management Board for Finance.
Starting from October 2024, a tax audit is underway at XTB S.A. regarding corporate income
tax regarding the application of the method of determining the transaction price between XTB
S.A. and related foreign entities recognized by the Head of the National Revenue
Administration resulting from the decision received by the Company on APA. The tax audit is
conducted on the basis of the provisions of the Act of August 29, 1997, the Tax Ordinance
(Journal of Laws 2023.2383, as amended) (art. 281 et seq.) in connection with art. 104 sec.
1 item 2 of the Act of October 16, 2019 on resolving disputes regarding double taxation and
concluding advance pricing agreements (Journal of Laws 2023.948).
Environment and climate
The XTB Group has implemented a Climate Policy, which sets out, among other things,
the challenges it faces in relation to climate change, or targets for the coming years. For more
information, please refer to Chapter 2 of this Statement.
The XTB Group published an ESG Strategy and, from 2022, published sustainability reports
in line with the SIN reporting standard, part of which included a carbon emission report. From
2024 onwards, XTB Group publishes the full carbon footprint of its operations calculated
in cooperation with an external expert specialising in this area in three scopes, which
has been subject to limited assurance attestation. Both reports and strategies are publicly
available on the company's website.
Fair competition
There is no policy in place at XTB S.A.'s Head Office governing the prevention of unfair
competition. During the 2024 reporting period under review, no violations of fair competition
rules were identified and no proceedings were conducted in this regard.
Minimum Guarantees of the non-financial company X Open Hub Sp. z o.o.
The operational activities of X Open Hub Sp. z o.o. reflect OECD and UN human rights
guidelines and International Labour Organisation conventions. Actions are implemented
as part of due diligence, including: identifying and assessing risks, implementing remedial
actions, monitoring effectiveness and ensuring access to remedies. The Company
has reviewed the policies and procedures in place and all activities are monitored
and reported in accordance with internal regulations. These activities cover key areas such
as human rights, employment and labour relations, environmental protection, anti-corruption,
consumer interests, science and technology development, competition and taxation.
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XTB Group Minimum Guarantees
On the scale of the XTB S.A. Capital Group – XTB S.A.'s subsidiaries and branches – analysis
of their documents (policies, procedures, regulations) is underway. If necessary, upon
completion of the analysis, recommendations will be made to all units with regard
to the implementation of the missing corporate documents (after alignment with local laws).
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3. Society
3.1 Our Employees
3.1.1 Employment structure
3.1.2 Diversity and equality
3.1.3 Working conditions
3.1.4 Staff training and development
3.1.5 Regulatory policies
3.1.6 Work safety and comfort
3.1.7 Incidents and complaints related to human
rights
3.2 Consumers and end-users
3.2.1 Clients of the XTB Group
3.2.2 Consumer and end-user policies
3.2.3 Notification channels and remedial actions
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3. Society
3.1. Our Employees
4. One of XTB Group's key stakeholders are its employees. It is their commitment,
competence and individual personality traits that create our organisational culture and have
been influencing the business results of XTB's operations for more than 20 years.
As an employer employing and cooperating with over 1,000 people worldwide, we are aware
of our impact on the quality and balance of their professional and private lives. A pro-employee
working atmosphere, stable and competitive employment conditions, and non-wage benefits
mean that as many as 87% of employees would recommend XTB as a good place to work.
This is the result of an employee satisfaction survey conducted at the beginning of 2024
in the XTB Group. At XTB, we also take care of maintaining appropriate occupational health
and safety standards in the workplace through training and the introduction of periodic first
aid training for our employees.
During the double significance analysis, we did not identify significant impacts in the area of
respecting human rights, although we attach importance to maintaining the highest standards
of cooperation in our team, and we treat respecting human rights as a priority. Our employees
are treated with respect and respect for the principles of equality, and the basic criterion for
employment or promotion is their competence. Our commitments to respect human rights in
accordance with international standards are described in Chapter 2.2.3. Minimum Guarantees
and in the XTB S.A. Diversity Management, Equal Treatment and Inclusion Culture Policy
(DEI).
We are working on strengthening communication with our employees in the face
of the dynamic increase in employment in the XTB Group. The largest employment is
characteristic of the XTB Headquarters in Warsaw, which dominates in this respect over
branches and foreign companies. The interests of individual employees of the Headquarters
before the Management Board of XTB S.A. are represented by employee representatives,
direct superiors and the Director of the Management Department
Human Capital, which ensures continuity of dialogue and cooperation with the team
of employees. Due to the dynamic development of our business, we strive to improve
communication activities with employees. Our messages are created bilingually,
we have implemented an internal intranet platform and we use internal mailings. Employees
have direct contact with their superiors and members of the Management Board if necessary.
In order to strengthen the organizational culture, occasional integration meetings are also
organized.
SBM 3 S1-1 In 2024, we updated the ESG Strategy for 2024-2027. It was based
on the results of the stakeholder survey, and its objectives were consulted with employees
responsible for a given area of interest of the Strategy. These individuals are operationally
involved in the implementation of the strategic objectives and report progress to the ESG
Team. By employee area, we mean all employees of the XTB Group employed under an
employment contract, on whom XTB as an employer has a significant influence, as well as
non-employees who constitute its own employee resources (individuals cooperating on the
basis of B2B contracts and civil law contracts). Both actual and potential identified significant
influences in the employee area allowed us to update and adjust the ESG Strategy for 2024-
2027, without affecting the organization's business model. The links between opportunities
and risks and the strategy and business model are included in the IRO tables in Chapter 1.6
of this Statement.
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Building relationships and a good working atmosphere is very important to us. That is why
we have implemented initiatives and projects related to the employee area in 2024 at XTB
Group, also in collaboration with the XTB Foundation:
▪ "Inner Power" workshops series to encourage employees to share their passions
and interests;
▪ sports activities, chess activities, going to matches together;
▪ health examinations and consultations for XTB Head Office employees;
▪ workshops and research on cancer prevention for employees as a part of the "Pink
October" and "Movember" campaigns;
▪ first aid training as part of a regular event;
▪ flu vaccination at the office;
▪ employee volunteering actions, i.e. cleaning up the Kabaty forest in Warsaw;
SBM-3 S1-1 Staff representatives took part in workshops and in-depth interviews
for the Double materiality assessment, which allowed us to identify risks and opportunities
related to our own employees. These are described in the ESRS 2 SBM-3 disclosure
in section 1.6. of the Statement.
The Management Board of XTB S.A. and the Human Capital Management and HR Tech
departments supervise employee engagement at every stage of employment:
▪ during the recruitment, employment and implementation process,
▪ during work through surveys, periodic interviews, ongoing conversations
with superiors,
▪ during the termination of cooperation.
This engagement is visible in the participation of employees in organized initiatives
and employee satisfaction survey assessments.
At the time of publication of the Statement, we do not identify the possibility of the impact
of a potential transition plan to reduce the negative impact on the environment on employees
and associates of the XTB Group. There is no possibility of forced labor or child labor
in the XTB Group, either in terms of type of activity or geographical location. During the Double
Materiality Study, the XTB Group analyzed its value chain and business model
with understanding, unanimously agreeing
that there is no such risk, including from the regulated nature of the XTB Group's activity,
the location of its offices, the nature of work that cannot be performed by children due
to the need to have specific competences and cooperation with partners with impeccable
reputations.
2024 is the first year for which we are presenting data according to ESRS standards, therefore
we are not reporting changes to the methodology for calculating the indicators of this chapter.
Characteristics of the XTB Group employees
SBM-3
Employees, as defined by XTB, are natural persons employed at branches and Group
companies under a contract of employment.
By own workforce, we mean persons cooperating with XTB Group entities on the basis of,
inter alia, self-employment, contracts for specific work, contracts of mandate, appointments,
etc.
Among the employees working at XTB S.A. branches and companies, a distinction is made
between employees in the IT area and administrative and clerical staff of various
specialisations.
We do not have operations that may be at significant risk of incidents of forced labour,
compulsory labour or child labour, and we do not identify an employee group on which
we may have a particularly negative impact.
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3.1.1. Employment structure
S1-6 Poland is the only country where the XTB Group has more than 50 employees
representing at least 10% of the total XTB Group employment. Therefore, we do not present
information on the number of employees by country. Detailed employment information
is presented in the following published tables and includes data on employees employed
at the end of the reporting period, i.e. at 31.12.2024.
As at 31.12.2024, the XTB Group employed:
Among the Group's 1015 employees, as many as 703 were employed at the XTB S.A. Head
Office in Warsaw as of 31.12.2024, representing 69.26% of the Group's workforce.
Table 26. Number of XTB Group employees by gender as of 31.12.2024.
Gender of the employee
Number of employees
As for
31.12.2024
Women
347
Men
668
Others
0
Not disclosed
0
Total
1 015
To calculate the S1-6 disclosure indicators, data was collected on the number of employees
as at 31.12.2024. The exception is the turnover indicator, where the total number of people
who left XTB in 2024 was identified. In relation to the financial statements, where the total
number of employees and associates disclosed is 1,245 people, there is a difference
in connection with the inclusion in the summary for the purposes of sustainable development
reporting of people on maternity leave, parental leave and benefits (leave of absence
exceeding 33 days).
34%
WOMEN
66%
MEN
90%
STAFF EMPLOYED FOR AN
INDEFINITE PERIOD OF TIME
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Table 27. Number of employees of XTB Groups by gender and nature of cooperation
As for
31.12.2024
Gender
Women
Men
Others
Not
disclosed
Total
Number of
employees
347
668
0
0
1 015
Number of staff
employed for
an indefinite
period of time
312
601
0
0
913
Number of fixed-
term employees
35
67
0
0
102
Number of
employees who are
not guaranteed
working hours
0
0
0
0
0
Number
of employees
347
668
0
0
1 015
As of December 31, 2024, the XTB Group was predominantly staffed by men (66%), and 90%
of employees were employed under an employment contract for an indefinite period.
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Table 28. Employee turnover rate*
Reporting period
01.01.2024 – 31.12.2024
Total number of employees who left XTB
Group during the reporting period
134
Employee turnover rate during the reporting
period (%)
13%
*Persons who left and were reinstated in the same reporting period are not included in the indicator.
In 2024, 134 employees left the XTB Group, which constitutes 13% of total employment
in the XTB Group as at 31.12.2024. The indicator does not include people who left and were
reinstated in the same reporting period. In order to calculate the turnover rate, the number
of employees who left was compared to the total number of employees as at 31.12.2024.
S1-7 Other forms of cooperation
As of 31.12.2024, the following forms of cooperation with persons who were not employees
of XTB Group branches and companies have been used:
▪ Self-employment (B2B)
▪ Contract of mandate
▪ Contract for specific work
▪ Appointment
The table below presents the number of persons cooperating with the XTB Group
as at December 31, 2024 (all cooperating persons are listed, except for persons who are
simultaneously employed under an employment contract with XTB Group companies).
Table 29. Characteristics of own workforce – non-employees of XTB Group
Form of cooperation
As of 31.12.2024
Number of persons cooperating
on a self-employed basis (B2B)
193
Number of persons cooperating based on civil
law contracts: (mandate and specific work)
47
Number of persons cooperating
based on an appointment
6
Number of persons cooperating
through an employment agency
6
Total:
252
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3.1.2. Diversity and equality
At XTB, diversity is one of the foundations that allows us to build a global organisation based
on mutual respect, kindness and partnership. Our team is made up of employees with different
nationalities, views, experiences, backgrounds and values, and each employee brings unique
perspectives, allowing us to create innovative investment solutions for over 20 years.
Diversity at XTB not only enriches the organisational culture, but also creates space for
employees to fully identify and realise their potential. Together we aim to build a working
environment based on empathy and mutual support, where every employee has an equal
opportunity to develop their career, achieve success and receive an objective evaluation of
their work.
The XTB Group's recruitment standards aim not only to attract talented candidates but also
to create a working environment where employees will want to stay. The recruitment process
is conducted in a transparent manner, giving equal opportunities to candidates applying for
the same position.
S1-9 The following assumptions were made regarding the diversity indicators:
▪ the top management diversity index included all persons holding director and
managerial positions, regardless of the legal basis of cooperation as of 31.12.2024;
▪ when presenting the age structure of employees, reference was made only
to employees employed under an employment contract in accordance
with the employment status as of 31.12.2024.
Diversity indicators
S1-9
Table 30. Diversity index of top management as of 31.12.2024 (regardless of
the form of cooperation)
Gender of the employee
Number of people
at the top
management level
Percentage of people
at the top management
level (%)
As for
31.12.2024
Women
13
20,63%
Men
50
79,37%
Others
0
0
Not disclosed
0
0
Total
63
100%
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Table 31. Age structure of employees as at 31.12.2024
3.1.3. Working conditions
S1-10 / S1-16
In terms of remuneration, the Group applies market principles, i.e. it makes the level
of employees' remuneration dependent in particular on their knowledge, professional
experience and substantive contribution to the development of the Company.
At XTB, we periodically analyse the evolution of women's and men's salaries in each
department. If discrepancies are identified, the director of the business unit concerned
is consulted and corrective action is taken if necessary. The XTB Group has not set indicators
related to adequate remuneration for the assessment of results and effectiveness in relation
to significant impacts, opportunities and risks.
All XTB Group employees receive appropriate remuneration in accordance with the provisions
of the applicable local law according to the location of the branch and XTB S.A.
Information on equal pay ratios for the XTB Head Office and the XTB Group is presented
below for the first time. The company presents the indicator for XTB Head Office separately,
bearing in mind:
▪ the widest diversity of positions compared to other branches and subsidiaries,
which are dominated by people employed in sales positions and
▪ the highest percentage of Group-wide employment at XTB Head Office
as of 31.12.2024, i.e. 69.26%.
The pay gap and total compensation indicators have not been assessed by an independent
expert, except for the sustainability attestation.
Data for the balance
as of
31.12.2024
Gender
Women
Men
Others
Not
disclosed
Total number
of employees
by age
Number of employees
under 30
130
253
0
0
383
Percentage of
employees under 30
37,46%
37,87%
0
0
37,73%
Number of employees
between 30 and 50
212
400
0
0
612
Percentage of
employees between
30 and 50
61,10%
59,88%
0
0
60,30%
Number of employees
over 50
5
15
0
0
20
Percentage of
employees over 50
1,44%
2,25%
0
0
1,97%
Total number of
employees by gender
347
668
0
0
1 015
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Table 32. The pay gap of XTB S.A. Head Office and XTB S.A. Group.
As for 31.12.2024
XTB S.A. Head Office
XTB Group
Nominal basic wage
24,74%
23,32%
Total remuneration (basic
wage and bonuses)
29,01%
31,56%
Table 33. Wage gap ratio of employees of XTB S.A. Head Office in 2024
Pay gap
excluding IT
employees
Pay gap
including
IT employees
As for 31.12.2024
Indicator
based on
basic salary
Directors and Management
Board
32,46%
31,84%
Employees in leading and
managerial positions
3,47%
7,92%
Employees in other positions
-4,31%*
18,74%
Index based
on basic
salary with
benefits
Directors and Management
Board
44,67%
44,62%
Employees in leading and
managerial positions
13,95%
14,49%
Employees in other positions
3,82%
19,75%
*Women salary higher than men’s salary.
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Methodology for calculating the wage gap indicator
For the purpose of calculating the indicator, the following assumptions were made:
– the wage gap was calculated for contract employees at branches and XTB Group
companies,
– the average hourly rate per employee has been calculated on the basis of the basic salary
declared in the employment contracts as of 31.12. and the basic salary including additional
salary elements paid in the period 01.01.2024 - 31.12.2024,
– the indicator was recalculated in two variants: including the salaries of employees
representing the IT sector and excluding the salaries of the above-mentioned employees.
The wage gap was calculated according to the formula proposed in the ESRS
standards:
The level of the XTB Headquarters pay gap differs both in terms of the type of remuneration
(base salary/base salary and benefits) as well as in terms of including employees representing
the IT industry and excluding them from the calculation. The difference in the size
of the Headquarters indicator based on base salary compared to base salary increased
by additional benefits is mainly related to the greater share of men employed in the Trading
Department and the Sales Department, in which additional benefits (i.e. in particular bonuses
and premiums) are higher than similar benefits in administrative positions.
A factor influencing the wage gap at XTB Head Office is the employment of IT staff
(in particular software developers), which as at 31.12.2024 was approx. 46% of employees
at XTB Head Office for whom the salary level as well as the predominant male gender share
in this category results in a gender pay gap. The high salaries in this professional group
are related to wage pressures in the labour market and the need to attract and retain
high-calibre professionals in this area. However, this dependency is typical of the IT industry
and not exclusive to XTB.
The Group-wide wage gap takes on higher values because we compare the salaries
of employees working in different markets around the world and in different countries, where
the standards of remuneration for the same work are determined by geographically
differentiated market standards. The standards of remuneration for the same work in different
countries are clearly different, which is reflected in the gap presented.
The total remuneration ratio, which expresses the ratio of the highest earning person
in the XTB Group to the median remuneration of all other employees in 2024,
was recalculated in two variants:
▪ for the Head Office of XTB S.A., according to the ESRS standards formula where
it reached 15,41 and
▪ simplified for the XTB Group, (the highest remuneration was compared to the median
selected from among the medians provided by all XTB S.A. entities). The indicator
for the XTB Group was in 2024: 15,53.
Average level of gross hourly wage of male employees
Average level of gross
hourly wage of male
employees
Average level of gross
hourly wage of female
employees
x 100
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In 2024, we have made non-wage benefits available to Head Office employees, i.e.:
▪ private medical care;
▪ funding for the MyBenefit platform and the Multisport package;
▪ "Helping Hand" well-being platform providing psychological support, psycho-
education and prevention (e.g. online sessions with therapists, webinars,
workshops, educational articles);
▪ reimbursement of the cost of corrective glasses;
▪ Christmas vouchers;
▪ holiday surcharges;
▪ an allowance for the use of accrued leave during the calendar year;
▪ group life insurance;
▪ an additional day of paid leave for birthdays;
▪ an additional day of paid leave for care for young parents;
▪ days off for voluntary services;
▪ subsidised meals.
The scope and form of non-wage benefits in the subsidiaries are adapted to local conditions
and standards in the area of employee remuneration and include, for example, additional
medical benefits, group insurance or Christmas gifts. In addition to this, employees receive
annual bonuses in the form of financial gratification according to established rules.
3.1.4. Training and staff development
S1-13 A suitably educated workforce is the foundation of the business, ensuring that duties
are carried out in a professional manner. The XTB Group has a training policy based on an
individual approach, tailoring development programmes to the current needs of employees
and business objectives, and the principles of the training system are determined
by the Procedure for Educational Training and Confirmation of Knowledge and Competence
of Employees. The company offers support for education, including funding for training,
courses, conferences, as well as studies, postgraduate studies and specialisation
examinations such as the broker's licence or CIIA. The principles for granting subsidies
are regulated by the XTB S.A. Training Policy.
An additional element of the training policy is support during the introduction of new
employees. They have access to an internal knowledge base containing presentations and
recordings about the industry and products offered by the company, which helps them start
work quickly and effectively. Financial resources for training are an element of the budgets of
individual XTB departments. In foreign branches, the training budget is set by the branch
director. Employees are delegated to training by their direct superior, according to needs.
The main categories of external training include:
▪ technical training (in the IT area);
▪ specialised training (to enhance professional knowledge, including postgraduate
studies, CFA, ACCA, MBA, ICA, stockbroker licence preparation course, etc.).;
▪ soft skills training;
▪ language training (tuition grants, reimbursement of course fees, access to the eTutor
online language learning platform).
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Regular (quarterly or annual) employee evaluations take place at XTB S.A. branches
and companies, which are carried out in order to:
▪ improve the quality and efficiency of the work of XTB employees;
▪ give feedback to the employee and build relationships;
▪ recognise and promote achievements;
▪ increase staff motivation;
▪ identify and analyse possible problems at the earliest possible stage;
▪ support rational staffing decisions and planning for individual employee career
development.
The indicators regarding training and development and regular employee assessments refer
exclusively to employees employed in the XTB Group as at 31.12.2024. Training hours
do not include the time spent by employees on postgraduate studies, MBA and CFA courses
(self-study), where a reliable estimate of training time is impossible. The list does not include
access to e-learning platforms, where access to courses is unlimited in time; studies;
language courses; courses preparing for obtaining a license, if access to the above courses
was unlimited in time. Employees can use co-financing for access to e-learning platforms with
unlimited time access - 5 people used this option in 2024. Additionally, the company supports
the development of language skills by offering co-financing for English language courses
for employees and Polish language courses for foreigners employed at the headquarters - 38
people used this support. In addition, the company provides access to a language learning
platform: English (79 users), German (38 users) and Spanish (30 users). In 2024,
all employees were provided with regular Security Awareness training and practical
anti-phishing training.
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Table 34. Training and skills development indicator by gender
As for 31.12.2024
Average number of training hours per employee
Hierarchical level
Woman
Man
Others
Not disclosed
Senior management
and directors
16,30
9,07
0
0
Executives and managers
10,86
8,96
0
0
Other employees
7,23
6,44
0
0
Average number
of training hour per
employee
7,87
6,93
0
0
The average number of training hours per employee (without distinction based on gender
and salary level) was 7.28 hours per employee across the XTB Group.
Table 35. Indicator on regular employee evaluation by gender
As for 31.12.2024
Scheduled employee evaluations
Hierarchical
level
Woman
Man
Others
Not disclosed
Senior
management
and directors
10
45
0
0
Executives and
managers
42
161
0
0
Other
employees
597
1 169
0
0
Total
649
1 375
0
0
Completed employee evaluations
Senior
management
and directors
11
42
0
0
Executives and
managers
34
155
0
0
Other
employees
584
1 147
0
0
Total
629
1 344
0
0
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In 2024, there was no single, consistent method of employee evaluation in the XTB Group.
Each branch and department had its own methodology, which was communicated to each
employee upon commencement of work and each time during evaluation interviews
as a reminder. In some departments, interviews are held annually, in others on a quarterly
basis. This is dictated by the specifics of the work of a given organizational unit. Some
interviews did not take place in 2024 as a result of their postponement to the next reporting
year.
Table 36. Percentage of XTB Group employees who participated in regular performance
reviews and career development by gender (as of 31.12.2024).
Employee
evaluations
Women
Men
Other
employees
Not
disclosed
Senior
management
and directors
70,00%
60.00%
0
0
Managers,
supervisors
66, 67%
78,31%
0
0
Other employees
74,42%
75.37%
0
0
Total
73.49%
74.70%
0
0
In 2024, a total of 754 out of 1,015 people in the XTB Group were subject to regular evaluation,
which constitutes 74.29%. The percentage of people under regular evaluation by gender was
similar: women 73.49%, men 74.7%.
Table 37. Number of work evaluations completed per employee
(as of 31.12.2024)
Employee
evaluations
Women
Men
Other
employees
Not
disclosed
Number
of
completed
evaluations
per
employee
Senior
management
and directors
1,10
0,93
0
0
0,96
Managers,
supervisors
0,94
1,87
0
0
1,59
Other
employees
1,94
2,12
0
0
2,06
As of December 31, 2024, per employee of the XTB Group employed under
an employment contract, an average of 2.06 employee assessments
(per 1 employee) were completed in the year under review.
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3.1.5. Policies and regulations
S1-1 / S1-2
Employees are key stakeholders in the XTB Group influencing the success of our business.
Each year we survey employee satisfaction levels, and the feedback gathered is translated
into actions aimed at the development of areas marked for improvement. Opinions are also
collected by staff representatives, who then formulate proposals to the Management Board.
In order to adequately manage the area of needs and employee well-being, we have
implemented and monitor the effectiveness of policies, among others:
S1-1 MDR-P Diversity, Equal Treatment and Inclusive Culture
Management Policy
The Diversity, Equal Treatment and Inclusive Culture Management Policy (hereinafter:
Diversity Policy, DEI Policy) was created in response to the identified influences, risks and
opportunities indicating the area of equality and inclusion culture as important for our team
(reference to significant influences, opportunities and risks can be found in chapter 1.6.
Statements). It organizes and indicates the most important directions of activities in the area
of supporting and building a diverse and inclusive organization. The policy was adopted
by a resolution of the Management Board of XTB S.A., and the Human Capital Management
Department of the XTB Headquarters is responsible for its implementation. The document
has been communicated and is known to employees.
As part of the DEI Policy, we commit to respecting all human rights recognized and defined
in internationally recognized documents and to avoiding/minimizing the potential negative
impact of its activities on human rights. We commit to complying with the provisions
of all types of activities:
▪ The 10 principles of the UN Global Compact;
▪ The Universal Declaration of Human Rights;
▪ The UN Guiding Principles on Business and Human Rights;
▪ The OECD Guidelines for Multinational Enterprises;
▪ The principles concerning fundamental rights at work contained in the 8 ILO
Fundamental Conventions set out in the Declaration on Fundamental Principles and
Rights at Work, including: respect for the freedom of association and collective
bargaining; the right not to be subject to forced labour, child labour and discrimination
in respect of employment and occupation.
In addition, we are committed to respecting the human rights of employees in business
relationships and areas where it is justified, to engaging our affected stakeholders as part
of improving or monitoring our approach to human rights. By affected stakeholders we mean
people (e.g. company employees, representatives of local communities, etc.) on whom
the XTB Group exerts or may exert a negative influence.
▪ Work regulations (including health and safety rules)
▪ XTB HR Policy
▪ Anti-mobbing and anti-discrimination policy
▪ XTB S.A.'s Diversity, Equal Treatment and Inclusive Culture Management Policy
▪ Remuneration Policy
▪ Training policy
▪ Human Resources Risk Management Procedure
▪ Recruitment and selection procedure
▪ Data protection security policy
▪ Remote working regulations
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The goals of the DEI Policy are:
▪ Promoting diversity: by ensuring that all people employed at XTB, regardless
of nationality, gender, sexual orientation, religion, age, family status or level
of professional experience, are treated equally and with respect.
▪ Equality in employment: Recruitment processes and career development paths
at XTB are based on professional competences and achievements, not personal
characteristics.
▪ Culture of inclusion: At XTB, we strive to build an open work environment, in which
everyone can freely express their views, experiences and needs.
▪ Combating discrimination: XTB does not tolerate any form of discrimination,
mobbing or harassment based on age, gender, nationality, appearance, property
and family status, degree of physical ability, sexual orientation, political or religious
beliefs and views. Every employee has the right to feel safe and comfortable in the
workplace. In the event of any violations, employees have the opportunity to report
incidents in accordance with established procedures, also anonymously.
In addition, the Policy also defines rules of conduct based on respect and acceptance, equal
pay, education and awareness, and refers to recruitment standards and the possibility
of reporting violations. The Human Capital Management department is responsible
for monitoring the effectiveness of the DEI Policy.
The remaining policies implemented in XTB were created before the double significance test
and are not related to the identified significant impacts, opportunities and risks. They are
related to and consistent with XTB's strategy and are intended to support effective human
resources management through effective selection, support and retention of the team
of employees and, among others:
▪ Employment planning and sourcing of employees with specific skills
and professional potential.
▪ Supporting employees' identification with the organisation's goals and mission.
▪ Shaping attitudes in line with XTB standards.
▪ Ensuring professional stability, countering job turnover and retaining a highly
qualified workforce.
▪ Supporting the development of the specialised skills needed to perform professional
duties.
▪ Creating an incentive system based on attractive employment conditions,
performance appraisal, transparent promotion and bonus rules.
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MDR-T
All entities in the XTB Group are based on the provisions of the XTB S.A. Human Resources
Policy. The Human Resources Management Department of XTB S.A. is responsible
for monitoring and updating the policies. In 2024, in order to implement the goals of the ESG
Strategy for 2024-2027, we implemented the Anti-Mobbing and Anti-Discrimination Policy.
The policies implemented in XTB are aimed at counteracting discrimination (including
harassment), promoting equal opportunities and social inclusion and cover the reasons
for discrimination such as gender, religion, nationality, age, disability, nationality, political
beliefs, ethnic origin, sexual orientation, appearance, etc.
As part of the remedial actions, we commit to taking independent actions or cooperating
in the scope of remedial actions for the benefit of affected stakeholders; cooperating in this
scope with suppliers to remedy negative effects that are directly related to our activities,
products or services; cooperating with judicial or extrajudicial mechanisms to ensure access
to full remedial actions. We expect that suppliers cooperating with the XTB Group act in
a manner that respects human rights and the provisions of the ILO Declaration
on Fundamental Principles and Rights at Work and the areas regulated by this Declaration,
including:
▪ respect for the freedom of association and collective bargaining;
▪ rights not to be subjected to forced labour, child labour and discrimination
in employment and occupation.
These policies have been communicated to employees.
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3.1.6. Work safety and comfort
S1-11 Social protection
XTB Group employees are covered by social protection under public schemes or any benefits offered by XTB against loss of income caused by:
▪ Disease
▪ Unemployment starting while employee is working at XTB
▪ Accident at work and acquired disability
▪ Parental leave
▪ Retirement
The exception is the XTB S.A. Sucursal em Portugal branch, where employees with less than 360 days of employment in the last 24 months are not covered by social protection against
unemployment and are not entitled to unemployment benefits.
The XTB Group has not set indicators related to social protection to assess results and effectiveness in relation to significant impacts, opportunities and risks.
As part of disclosure S1-15, we have assumed that all employees of the XTB Group employed under an employment contract are entitled to exercise the right to the above-mentioned leave.
Table no. 38 presents the percentage of employees who exercised this right in 2024 in accordance with the employment status as of 31.12.2024.
Table 38. Work-life balance indicators for employees
S1-15
Reporting period
01.01.2024 – 31.12.2024
Women
Men
Others
Not
disclosed
Total
Percentage of employees entitled to parental leave
100%
100%
0
0
100,00%
Percentage of eligible employees who have taken parental leave
7,78%
5,24%
0
0
6,11%
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3.1.7. Incidents and complaints related to human rights
S1-2 / S1-3
XTB has an internal "Anonymous Whistleblowing Procedure", which details the procedure for
reporting actual or potential violations of the law, including violations of anti-money laundering
and terrorist financing regulations, internal procedures and ethical standards. The procedure
covers both employees and other persons performing activities for XTB, including XTB's
suppliers. The internal procedure implements the obligations introduced by the Law of 14
June 2024 on the protection of whistleblowers and provides protection against retaliation.
Reporting is made via an electronic form available at: https://www.xtb.com/pl/zawiadomienie.
The entities handling the reports, depending on their subject matter, are: Supervisory
Inspector, MLRO (Money Laundering Reporting Officer), Management Board, Supervisory
Board or members of these bodies.
In addition, employees can report any irregularities through direct contact with their superiors,
to employee representatives or by contacting the Human Capital Management department.
The whistleblowing procedure is reminded to employees via internal mailings from the Legal
and Compliance department. The XTB Group assesses whether the solutions applied during
the explanatory and corrective processes were effective and, in the course of periodic
communications, reminds about the available methods of reporting irregularities.
S1-17 The XTB Group monitors the number of reported complaints relating to mobbing
or discrimination and reports each year in its sustainability reporting. In 2024, there were
no incidents of mobbing or harassment and no serious incidents were reported regarding
respect for human rights. In one of the subsidiaries of the XTB Group, in the audited reporting
period, proceedings were pending concerning discrimination, which ended with a settlement
in the first quarter of 2025. As a result of the settlement, XTB was obliged to pay £ 2,000,
which in relation to the consolidated net profit of PLN 856,856,194.46 is a small per mille.
S1-4 / S1-5
The supreme authority for managing HR impacts, opportunities and risks is the Management
Board of XTB S.A. and the directors at the head of the branches, subsidiaries and HR
divisions. In relation to the identified material impacts, opportunities and risks, we have
updated the ESG Strategy and identified objectives i.e.:
▪ updating the remuneration principles at XTB S.A. Head Office as well as measuring
and monitoring the Gender Pay Gap indicator for the entire XTB Group;
▪ creating a safe and inclusive working environment for XTB Group employees;
▪ development of the educational and social activities of the XTB Foundation.
These objectives were based on the results of surveys, in-depth interviews and workshop
meetings with representatives from different areas of XTB's business as part of the Double
materiality assessment. The achievement of targets is overseen by the assigned target
owners and the ESG Team.
Material impacts, opportunities and risks are managed with the help of the activities
of the Human Capital Management team, which examines the needs and moods within the
team, represents the employees to the Management Board and implements the specific
actions of the HR area. In order to counteract significant negative impacts and mitigate risks
in 2024 at XTB S.A.'s Head Office, we have implemented an Anti-Mobbing
and Anti-Discrimination Policy and a Diversity Policy. We have also launched a competency
survey process to support the unification and transparency of remuneration and bonus rules
in the XTB Group. We aim to improve comfort and working conditions to reduce turnover
or employee departures from XTB.
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Scope of social bargaining and social dialogue
S1-8
The XTB Group provides full freedom of association and is open to dialogue with labour
communities. In 2024, the only country with more than 50 employees, which is at least 10%
of the total employment value, was Poland. There were no collective agreements in this
branch - employee participation was 0%. In the case of social dialogue in the EEA area, 100%
of employees of the Headquarters in Poland were represented by employee representatives
(what represents 69% of total employment of XTB Group). In 2024, no agreement
was concluded with employees on representation by the European Works Council (EWC),
the Societas Europaea (SE) Works Council or the Societas Cooperativa Europaea (SCE)
Works Council.
3.2. Consumers and end-users
Among the recipients of XTB's services and products we can indicate:
▪ individual clients who are our consumers and end-users, and
▪ institutional clients, i.e. companies and organisations using XTB solutions.
These are key XTB Group stakeholders with whom we identify mutual impact in our
relationships. It is the recipients of our services and products that inspire our further product
plans and motivate us to take on the challenges of growing the business. On the other hand,
XTB's business influences clients through its strategy, business model and the services
and products offered. We have been managing each other's impact for many years, building
our experience and improving our standards of doing business.
3.2.3. Consumers and clients of XTB Group
XTB is targeting two segments:
▪ Retail: The retail activity of the XTB Group includes offering clients a universal and
comprehensive investment application, thanks to which they can effectively manage
their financial resources and use a variety of investment products.
▪ Institutional: In the institutional segment, we act, among other things, as a liquidity
provider for institutional clients. We also offer technology so that they can offer their
clients the opportunity to trade financial instruments under their own brand.
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All consumers and institutional clients are covered by the disclosures under sustainability
reporting. The XTB Group does not adversely affect the right to privacy, personal data
protection or freedom of expression of its consumers. However, it manages and processes
the data provided by them and in the event of a potential leak could be held liable for causing
a negative impact. XTB consumers subject to significant impacts are dependent on accurate
and accessible information regarding XTB's product or service to avoid potentially harmful
use of the product or service and may be particularly susceptible to the effects of marketing
and sales strategies. Consumers subject to significant impacts are not particularly vulnerable
to health or privacy effects.
SBM-3 XTB's impact on consumers and end-users is related to:
▪ the use of XTB's technological solutions, i.e. the investment application
and the investment platform, through which investors have the opportunity to invest
the funds raised;
▪ advertising and marketing activities based on responsible marketing practices and
▪ ongoing educational activities to help our investors achieve their investment goals.
The identified needs of consumers and end-users, are in line with XTB's business model and
business objectives, which provokes the continuous development of our portfolio of
investment and financial products. We carry out advertising activities with well-known athletes
to help us reach the widest possible audience, make our presence felt on social media and
carry out educational activities to build client investment awareness. As a broker, we offer
access to a variety of financial instruments, including those that carry particularly high
investment risks, of which XTB clients are informed. Since 2016, XTB has organised
a Masterclass Conference, which is attended by several thousand people every year.
As part of the Double materiality assessment carried out in 2024, we identified the impacts,
opportunities and risks of the consumer cooperation area as described in Chapter I of the
Statement.
SBM-2 / S4-2 / S4-4 / S4-5 In order to understand the perspective of our individual
and institutional clients, we invited a selected sample with the highest active use of XTB's
services to participate in a Double materiality assessment in 2024. This gave us an insight
into their needs and complemented the results of the Survey, making it a complete and
valuable source of information for the Company. We based the ESG Strategy 2023-2027,
updated in July 2024, on this and the designated: mission, vision and strategic directions,
with no specific targets set for managing impacts, risks and opportunities. The XTB Group,
as a provider of investment products and services, influences clients through activities
in the areas of: quality of communication, offer and documentation, level and availability
of customer service, availability of communication channels with clients, educational materials
and activities, decisions supported by analyses of client opinions and availability
of information, which minimizes the possibility of negative potential impacts and risks.
We monitor and assess the effectiveness of these activities and initiatives by analyzing
the opinions of our clients available online, the level of interest in XTB services and through
direct contact with our Customer Service department.
Strategic direction
We are committed to social sustainability by creating a safe and inspiring working
environment, building sustainable social relationships, the expectations of our clients.
The XTB Group identifies necessary actions in response to actual or potential negative
impacts on consumers through organized operational and management processes focused
on their needs and preferences. The XTB Group's approach to taking action in relation to
specific significant negative impacts on consumers is described in Chapter 1.6. Statements.
The XTB Group ensures that processes enabling remedial action in the event of significant
negative impacts are available and effective as part of the breach reporting procedure, contact
form and direct contact with customer service. Each report is processed with due diligence by
dedicated persons with appropriate qualifications. In order to mitigate significant risks in this
area resulting from XTB's impact on consumers and its dependence on consumers,
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the organization undertakes and monitors activities aimed at improving technology,
developing transparent information processes and strengthening the security of XTB
products. The Company intends to continue the activities undertaken in subsequent reporting
periods and allocates appropriate human and material resources for this purpose. We are
increasing employment and training additional experts in each area of our activity in order to
ensure not only the appropriate quality of customer service, but also effective operational and
management processes affecting the entire activity of XTB, which allows us to counteract
negative impacts. The XTB Group has not adopted goals in this area.
For years, our Business Strategy, its objectives and business model have been based on the
needs of our clients and the identified needs of societies in different regions of the world.
Contact with XTB Group's clients takes place at every stage of the cooperation: from the
initiation of dialogue with potential clients, through the establishment of the cooperation,
service during the cooperation, education and ending the cooperation. A widely available
source of information and for reporting problems and complaints is, in addition to the form
available on the XTB product website, the XTB helpline and customer service department,
which is available 24 hours a day, five days a week . Among other things, in order to improve
the quality of dialogue with investors in 2023, we have established a strategic partnership with
the Association of Individual Investors, which represents their interests and perspective.
In addition, we analyse and improve our business based on feedback from our clients added
within the evaluation of the xStation application or on websites and discussion forums. The
opinions collected influence business decisions and impact management for XTB clients. The
top structure responsible for managing relationships with clients is the Management Board of
XTB S.A. and the directors responsible for the operational performance of the customer
service teams subordinate to them.
The safety of our clients is our priority and we do not agree to compromise in this area.
We see security in the perspective of:
▪ protection of our clients' personal data,
▪ digital security of our products,
▪ transparent and clear rules of cooperation with XTB,
▪ appropriate quality of customer service by qualified XTB experts,
▪ education to support investors in achieving their investment goals.
To ensure adequate security, we encrypt client data in accordance with proven and accepted
industry standards. We carry out an internal GDPR audit process at least once a year.
We regularly conduct independent security audits in line with the requirements of GDPR and
ISO 27001, using recognised companies specialising in online security. Internal or external
penetration tests are regularly scheduled. XTB has also implemented access management
controls, including approval of access by Legal and Compliance to ensure that only authorised
employees have access to data (in line with Need-to-Know and Least Privilege).
Employees receive cyber security training once a year, culminating in an exam, covering
topics such as information security, data privacy and password security. Our physical
infrastructure is supported by Data Centres providing the best industry standards such
as physical security with secure access, intrusion alarms, CCTV, motion sensors, etc. located
in different geographical regions. XTB also provides centralised monitoring for IT security,
especially for malicious activity, vulnerabilities, incidents. For the security of clients, XTB
always confirms requests to change personal data using multi-factor authentication
mechanisms. We use a variety of contact channels (e-mail, SMS, telephone).
The XTB xStation mobile app allows authentication by password and additionally offers
access security by code or biometrics. The application has multi-component authentication
implemented.
During the reporting year, we did not record any serious human rights issues or incidents
related to the value chain. For more information on impacts, opportunities and risks in the
area of consumer relations, see Chapter 1.6. of the Statement.
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3.2.4. Consumer and end-user policies
S4-1 The overarching documents at XTB are the business and ESG strategies.
The umbrella sets our objectives and courses of action in line with publicly available standards
of conduct such as e.g. UN Guiding Principles on Business and Human Rights, or the OECD
Guidelines for Multinational Enterprises. The policies adopted at the XTB Group can be
viewed from two perspectives: internal and external. In order to responsibly manage
relationships and influence in the consumer area, we have implemented internal standards
that also result from legal regulations imposed on XTB as a financial institution. The highest
authority responsible for implementing the documents is the Management Board of XTB S.A.
These include policies and regulations on, among other things:
▪ improving our services and product management,
▪ data protection security, information security and cyber-security,
▪ risk management and business continuity,
▪ handling complaints and reporting irregularities,
▪ internal control and audit,
▪ ethics, conflicts of interest, anti-corruption and anti-bribery and money
laundering.
We have not implemented a uniform policy addressing all significant sustainable development
issues in the consumer area, but each significant topic is covered by an independent
procedure. Issues related to human rights, which may be significant from the perspective
of customers, constitute the basis of the ESG Strategy for 2024-2027 and the XTB S.A. Code
of Ethics.
As a financial market entity, we are obliged to provide our clients with the necessary
information presenting the principles of cooperation with XTB in a transparent manner.
On our website you will find regulations and documents, the knowledge of which is necessary
when signing an investment account agreement with XTB, among others:
▪ Regulations for the provision of services concerning the execution of orders
for the purchase or sale of property rights and securities, maintenance of securities
and property rights accounts and cash accounts by XTB S.A. (General Terms
and Conditions)
▪ Order Execution Policy (key assumptions in line with the requirements
of the European Union directives on markets in financial instruments, organisational
requirements and operating conditions for investment firms and the terms defined
for the purposes of those directives)
▪ Regulations for the preparation of general recommendations by XTB S.A.
(Recommendation Regulations)
▪ Agreement for the Provision of Services by XTB S.A. together with annexes
▪ IKE agreement
▪ Declaration of Risk Awareness
▪ MiFID questionnaire
▪ Basic information about XTB S.A.
▪ Other (including applications and powers of attorney)
In addition, XTB clients have access to documents, i.e.:
▪ XTB S.A.'s Complaints Management Strategy
▪ Instructions for filing complaints
During the reporting period under review, there were no instances of non-compliance
with the UN Guiding Principles on Business and Human Rights, the ILO Declaration
on Fundamental Principles and Rights at Work or the OECD Guiding Principles
for Multinational Enterprises that concern consumers or end-users.
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3.2.5. Notification channels and remedial action
S4-1 / S4-3 XTB has implemented a comprehensive complaints management
process, which is designed to facilitate the reporting of complaints, the rapid analysis of claims
and the effective remediation of any negative impact on consumers and end-users.
The main principles of this process are:
▪ Transparency: clients are provided with precise information on how to raise
a complaint, information on the stage of the process and on the decision,
with justification.
▪ Promptness: complaints are received and dealt promptly, in accordance with
established time standards, in order to compensate clients for any loss
or inconvenience as quickly as possible.
▪ Efficiency: the complaints process is designed to be efficient and to take into account
not only the effects but also the causes of the problems, what allows to prevent them
from recurring in the future.
▪ Consumer cooperation, based on proactive collaboration with the client
to understand reported problems, expectations and remediation also of individual
cases.
The XTB's complaints process is characterised by transparency; already at the contract
conclusion stage, our clients can familiarise themselves with the provisions
of the Brokerage Services Provision Regulations, which clearly describe the channels through
which a complaint can be lodged, what a complaint should contain and the maximum time
limit within which a response can be expected.
We have also included on our website:
▪ "Instructions on Filing a Complaint".
▪ "Complaints Management Strategy".
These documents comprehensively describe the complaints process, including the client's
rights and obligations. Information on how to make a complaint is also available
in the Education section of XTB's website. XTB clients have a choice of several channels
through which they can make a complaint. These include:
▪ in person, at the premises – in writing and orally,
▪ by telephone via our helpline,
▪ by post – to the address of XTB's registered office,
▪ via an electronic form, available in the Investor Room.
One of the most flexible communication channels is electronic communication, available
regardless of location and continuously monitored by XTB employees.
All complaints reported by clients are recorded in the CRM system and are given their unique
identifier and status, which facilitates the monitoring of the report. The status is also visible
in the Investor Room so that the client can keep track of their application. We do not tolerate
or allow any form of discrimination or unequal treatment towards our customers who have
filed a complaint, grievance or appeal.
The complaints process is a valuable resource for XTB, so the handling of a complaint is not
the end of the process. In systematic cycles, reports and analyses are produced
on the requests received from clients. This enables the company to determine the causes
of the reports and to identify and implement appropriate remedial actions.
By sharing knowledge as to the reasons for the reports, the company is able to implement
remedial measures in a timely and efficient manner. Once these are implemented,
an assessment of effectiveness is made, the complaints process is monitored to ensure that
the problem has been completely resolved and similar situations will not occur again.
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XTB's clients can report by means of complaints any irregularities they have noticed or their
concerns. In 2024, we received a total of 6816 complaints from consumers and end-users
of the XTB Group, representing 0.5% of the total client volume of 1,361,564 as at 31.12.2024.
Due to the nature of the services provided, the most common complaints in 2024 were related
to including technical problems related to using the application or orders placed by our
customers.
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4. Governance
4.1 XTB Group characteristics
4.2 Administrative, management and supervisory
bodies
4.2.1 XTB S.A.'s Management Board and
corporate bodies
4.2.2 Supervisory Board of XTB S.A.
4.3 Corporate culture and ethics
4.4 Risk management and internal control
4.5 Supplier relationship management
4.6 Due diligence statement
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4. Governance
4.1. XTB Group characteristics
XTB Group is an international provider of financial instruments trading products, services and
technology solutions, and XTB S.A., which stands at its head, is one of the largest listed
brokers building experience in the investment industry for over 20 years.
We specialise providing our clients with a universal investment application that allows them
to effectively manage their financial resources and gives them access to a variety
of investment products. In line with the emerging Mission and Vision, our business ambition
is to offer a universal investment application providing the opportunity to invest online
in anything, at any time and in any way. We build solutions to support investors in achieving
their investment goals and provide factual assistance in the form of free materials and market
analysis.
In 2016, we made our debut on the regulated market of the Stock Exchange and, due to our
global brokerage business, our activities are subject to financial supervision in international
financial markets, including, among others: KNF, FCA, DFSA, CySEC, Bappebti Indonesia
and SCA.
XTB S.A. Capital Group is subject to supervision by specific regulatory supervision authorities
and public administration bodies in the jurisdictions in which it operates. In Poland, conducting
brokerage activities requires a permit from the Polish Financial Supervision Authority and is
subject to many regulatory requirements. The Company is a brokerage house operating
on the basis of a permit to conduct brokerage activities and is subject to regulatory supervision
by the Polish Financial Supervision Authority.
Thanks to the principle of a single European passport resulting from the MiFID II Directive,
the Company operates in the form of a branch on the basis and within the framework
of the permit granted by the Polish Financial Supervision Authority in the following EU Member
States: the Czech Republic, Spain, Slovakia, Romania, Germany, France and Portugal.
Material impacts, opportunities and risks of the management and corporate governance area
identified in the 2024 Double Materiality Assessment can be found in Chapter 1.6.
of the Statement.
4.2. Administrative, management and
supervisory bodies
As of 31.12.2024, the XTB S.A. Capital Group consisted of the parent company XTB S.A.
and its seven foreign branches, as well as the Group's 13 subsidiaries.
XTB S.A.'s activities are regulated by documents such as:
▪ Articles of Association of XTB S.A.
▪ Regulations of the Management Board
▪ Rules of Procedure of the Supervisory Board
▪ Rules of Procedure of the General Assembly
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All of the aforementioned documents comprising the Company's governance are publicly
available on the investor relations sub-page under the Governance tab at: https:// ir.xtb.com/
4.2.1. XTB S.A.'s Management Board
and corporate bodies
GOV-1 Role of administrative, management and supervisory bodies
Management structure
The members of the Management Board are appointed and dismissed by the Supervisory
Board for a joint term of three years. The number of members of the Management Board shall
be determined by the Supervisory Board in the resolution appointing the members
of the Management Board. A member of the Management Board may also be dismissed
or suspended by a resolution of the General Assembly. The powers of the Management Board
include the representation and management of the Company's affairs and all matters not
reserved by law or the Company's Articles of Association to the competence of the General
Assembly or the Supervisory Board. The Management Board makes decisions with the best
interests of the Company in mind, drafts development strategies and defines its main business
objectives.
Full professional biographies of the Management Board members, a description of their
competences and information on the principles of operation of the Management Board of XTB
S.A. can be found in the Corporate Governance section in the Management Board Report
of the XTB Group, Corporate Governance, chapter Statutory Bodies of XTB.
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The Management Board of XTB S.A.
As of 31.12.2024 and at the date of publication of this Statement, the Management Board of
the Company remained 100% independent with unchanged composition:
Table 39. Composition of the Management Board of XTB S.A. as of 31.12.2024 and as
of the date of publication of the Statement.
NAME
FUNCTION
OPENING DATE
OF THE FIRST
TERM OF OFFICE
DATE OF EXPIRY
OF THE CURRENT
TERM OF OFFICE
Omar Arnaout
President of the
Management Board
10.01.2017
01.07.2025
Filip Kaczmarzyk
Member of the
Management Board
10.01.2017
01.07.2025
Paweł Szejko
Member of the
Management Board
28.01.2015
01.07.2025
Jakub Kubacki
Member of the
Management Board
10.07.2018
01.07.2025
Andrzej Przybylski
Member of the
Management Board
01.05.2019
01.07.2025
The current composition of XTB S.A.'s Management Board was appointed on 2 June 2022
by a resolution of the Company's Supervisory Board on the appointment of the existing
five-member composition of XTB S.A.'s Management Board for a new joint three-year term
of office (from 1 July 2022 until the end of 1 July 2025).
During the reporting period under review, men made up 100%
of XTB S.A.'s Management Board.
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4.2.2. Supervisory Board of XTB S.A.
As of the day of publication, the composition of the Company's Supervisory Board
was as follows:
Table 40. Composition of the Supervisory Board as at the date of publication
of the Statement.
FULL NAME
FUNCTION
BEGINNING DATE
OF THE CURRENT
TERM OF OFFICE
DATE OF EXPIRY
OF THE CURRENT
TERM OF OFFICE
Aleksander
Chłopecki
Chairman of the
Supervisory Board
16.01.2025
20.11.2027
Ewa Stefaniak
Member of the
Supervisory Board
20.11.2024
20.11.2027
Katarzyna
Dąbrowska
Member of the
Supervisory Board
20.11.2024
20.11.2027
Bartosz Zabłocki
Member of the
Supervisory Board
20.11.2024
20.11.2027
Grzegorz
Grabowicz
Member of the
Supervisory Board
20.11.2024
20.11.2027
During the ongoing term of the Supervisory Board of XTB S.A., men made up 60%
and women made up 40% of the Company's body.
Men
60%
Women
40%
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Changes in the composition of the Body in the reporting period, professional biographies
and description of competences of the Supervisory Board members, information on their
independence and information on the principles of operation of the Body can be found
in the Corporate Governance section of the Management Board’s Report, in chapter Statutory
Bodies of XTB.
Committees of the Supervisory Board
The following committees function within the Supervisory Board:
▪ Audit Committee;
▪ Remuneration Committee;
▪ Committee for Risk Management.
The Supervisory Board performs the tasks of the Remuneration Committee
and the Remuneration Committee for Risk Management by means of a resolution adopted
by it collectively. 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 the appointment and operation of committees are set out in the Rules
of Procedure of the Supervisory Board, available on XTB's website at: https://ir.xtb.com/ under
Governance, Regulations. Detailed info regarding the composition of the aforementioned
committees can be found in the Management Report of the XTB S.A. Capital Group.
4.3. Corporate culture and business ethics
G1-1 XTB is a globally recognised brand. This brings a responsibility that calls for specific
organisational and communication actions, affecting the relationship with our stakeholders
and employees from all over the world. As an investment company, we operate in a highly
regulated environment and it is fundamental for us to be compliant in the markets of our
presence. This influences the shape, quality and standards of our diverse corporate culture.
The Management Board of XTB S.A. manages the elements of organisational culture
in accordance with the division of competences of the Members of the Management Board
in cooperation with the owners of XTB's operational areas. We are building an international
and diverse organisational culture that requires appropriate communication activities.
Accordingly, we have implemented an internal Intranet platform and communicate bilingually.
The interests of the workforce are represented by employee representatives, who can present
their findings and recommendations at regular meetings with the Management Board.
Corporate culture topics are discussed at Board meetings. In 2024, the following were
discussed:
▪ the results of the XTB Group's Double Materiality Assessment,
▪ the adoption of the ESG Strategy 2024-2027,
▪ the adoption of an Anti-Mobbing and Anti-Discrimination Policy,
▪ the adoption of the Anti-Corruption Policy,
▪ the adoption of a Diversity & Inclusion (DEI) Policy.
We support the development of our corporate culture through:
▪ competitive and flexible terms and conditions of employment,
▪ values, strategy, procedures and policies,
▪ bilingual communication based on an internal intranet and mailings,
▪ company-wide and departmental team-building events,
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▪ organising and subsidising employee training,
▪ communication activities under the Natural Investment Programme,
▪ promoting prevention and health-oriented habits through regular Health Day
celebrations or ad hoc actions;
▪ year-round "Inner Power" workshops to encourage sharing of passions among
employees,
▪ annual employee satisfaction survey;
▪ promotion of volunteering;
▪ support for diversity and the introduction of a Diversity Policy (DEI).
MDR-P Our activities in the area of corporate culture and ethics are supported by internal
documents which include, among others:
▪ Articles of Association of XTB S.A.
▪ Regulations of the Management Board of XTB S.A.
▪ Code of Ethics,
▪ Diversity Policy (DEI)
▪ Anti-mobbing and anti-discrimination policy
▪ Training policy
▪ Anti-Corruption Policy
▪ Work Regulations
▪ HR Policy
▪ Remuneration Regulations of the Management Board of XTB S.A.
We build an organisational culture based on values:
We assess our organisational culture through an annual employee satisfaction survey
conducted by the Human Capital Management Department
Tackling corruption and bribery
G1-3 / G1-4 To prevent, detect and respond to allegations and incidents of corruption
and bribery:
▪ there is an Anti-Money Laundering team within the Legal and Compliance
department and XTB Group employees receive training in the area of anti-money
laundering and terrorist financing,
▪ XTB S.A.'s Anti-Corruption Policy was implemented,
▪ there are rules on accepting gifts and souvenirs;
▪ in accordance with the provisions of applicable law, conversations conducted
with XTB clients are recorded.
In 2024, no cases of corruption were identified in the XTB Group, and there were
no proceedings against XTB Group companies in this area.
TECHNOLOGY
TRUST
SUPPORT
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G1-1 / MDR-P / MDR-A / MDR-P Responding to the identified material impacts
and risks in anti-corruption area and in line with the 2024-2027 ESG Strategy objective,
the XTB S.A. Anti-Corruption Policy was developed and recommended for implementation
across the XTB Group. The document is based, inter alia, on the United Nations Convention
Against Corruption and addresses the issues comprehensively, and the whistleblowing
system has been linked with the system implemented by the internal Whistleblowing
Procedure to ensure efficient, independent and objective investigation of incidents.
The highest level responsible for implementing the Policy is the Management Board of XTB
S.A. The Policy does not implement any objectives; it is educational, informative and
preventive in nature. It does not require taking action in the absence of violations, although
it is subject to standard periodic review.
The Policy identifies areas particularly vulnerable to the risk of corruption:
▪ XTB customer service;
▪ IT area;
▪ selection of suppliers and business partners;
▪ the conclusion of commercial agreements;
▪ sponsorship and charitable activities;
▪ employment, remuneration and bonuses of employees;
▪ information processing, including confidential and business secret information;
▪ judicial and administrative decisions.
In Q4, XTB S.A. Head Office implemented anti-corruption and bribery training for newly hired
employees and decided to send cyclical alerts to employees identified as vulnerable. These
activities complement the AML (Anti-Money Laundering) training provided to date. Those
identified as being at particular risk of corruption and bribery and members of management
and supervisory bodies will be covered. The area of identification of vulnerable functions and
training is a new area undertaken operationally by XTB and, as a result, many branches did
not carry out training exclusively dedicated to corruption, but only included elements of this
topic as part of other, often mandatory training, e.g. in the area of AML.
Table 41. Training on anti-corruption and bribery
Management
Board and
Supervisory
Board)
Directors
and
managers
Other
employees
Other persons
cooperating on
the basis of B2B
contracts,
contracts
of mandate, etc.
Total number of people
at risk of corruption
11
153
218
7
Number of people at
risk and trained
1
25
42
3
Number of persons
eligible for training
11
153
218
7
Percentage of people
performing a function
exposed to a risk of
corruption covered by
training programmes
(%)*
9%
16%
19%
43%
Training time per 1
participant
1,55
0,84
0,32
2,43
*To calculate the percentage of people performing a function exposed to a risk of corruption covered by training
programmes, the numerator, i.e. the number of people at risk and trained in this area, was divided by the denominator,
i.e. the total number of people at risk of corruption.
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In 2024, training conducted in the area of corruption had a form of mixed training: onsite,
online and using online platforms.
To prevent, detect and respond to allegations and incidents of corruption and bribery:
▪ there is an Anti-Money Laundering team within the Legal and Compliance
department and XTB Group employees receive training in the area of anti-money
laundering and terrorist financing,
▪ XTB S.A.'s Anti-Corruption Policy was implemented,
▪ there are rules on accepting gifts and souvenirs;
▪ In accordance with the provisions of applicable law, conversations conducted with
XTB clients are recorded,
▪ training including anti-corruption issues has been implemented into the training
process of newly recruited employees from Q4 2024,
▪ a decision was taken to send cyclical alerts to both those identified as being at high
risk of corruption and all employees.
In 2024, no cases of corruption were identified in the XTB Group, and there were no
proceedings against XTB Group companies in this area.
Whistleblower mechanism
XTB has an internal "Anonymous Whistleblowing Procedure", which sets out the procedure
for reporting actual or potential violations of the law, including violations of anti-money
laundering and terrorist financing regulations, internal procedures and ethical standards.
The procedure covers both employees and other persons performing activities for XTB,
including XTB's suppliers. The internal procedure provides protection for whistleblowers
against retaliation and implements the obligations introduced by the Law of 14 June 2024 on
the protection of whistleblowers. Any employee who witnesses or has knowledge of a breach
is obliged to make a report.
Applications are made via an electronic form available at
https://www.xtb.com/pl/zawiadomienie. The entities handling the reports, depending on their
subject matter, are: Supervisory Inspector, MLRO (Money Laundering Reporting Officer),
Management Board, Supervisory Board or members of these bodies. Pursuant to the adopted
Whistleblower Procedure at XTB S.A. of 24.09.2024 it is assured that the investigators are to
be separate from the chain of management structures involved in the case. Upon receipt
of a notification, the competent entity shall initiate an investigation, which should take no
longer than 2 months.
All reports from outside the internal structures concerning suspicions of corrupt activities of
XTB should be submitted via the electronic form available at
https://www.xtb.com/pl/zawiadomienie, or by correspondence to the registered office of XTB
S.A. in Warsaw.
The report should contain at least the following information:
▪ date, place and circumstances of the incident;
▪ nature of the incident;
▪ evidence of a breach, such as documents, e-mails or other.
All submissions are treated as confidential and are stored in a dedicated submission register.
An acknowledgement of receipt of the notification shall be given to the notifying person who
provided contact details as part of the notification, within 14 working days from the date of
notification, If the proceedings initiated as a result of the notification are terminated, the
notifying person will also be informed of the termination and outcome of the proceedings,
within one month from the date of termination. The people handling the report are separate
from the management structures involved in the case.
Reporting the results of the investigation to the management and supervisory bodies under
the Whistleblowing Procedure is the responsibility of the Member of the Management Board
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for Legal Affairs who periodically reports to the Supervisory Board on the notifications
received.
4.4. Risk management and internal control
GOV-5 In 2024, we undertook to organise our ESG management processes, identify
material impacts, opportunities and risks, set strategic action steps for the coming years,
analyse XTB S.A. Group's data capture process and align reporting with the requirements of
the EU CSRD and ESRS standards.
The highest management authority with regard to risks of the ESG area is the Management
Board of XTB S.A.. The ESG risks identified as part of the Double Materiality Assessment
process in line with the 2024-2027 strategic objective have been aligned with the internal risk
management system and will be incorporated into it. Experts representing various areas of
XTB Group's operations and providing the necessary data for the reporting process are
responsible for its completeness, reliability and accuracy. The organisational unit that
coordinates the XTB Group's sustainability reporting process is the ESG Team, which collects,
consolidates, analyses and presents the information gathered in the report. Each person
required to support the reporting process by providing data is supported by the ESG Team,
which remains at their disposal throughout the process. Data collection is based on universal
and publicly available tools familiar to every XTB Group employee.
Supervision of the correctness of the reporting process is exercised personally by the Member
of the Management Board for Finance and members of XTB S.A.'s Management Board. Also
from 2025, the Internal Auditor representing XTB S.A.'s internal audit function will periodically
review the published sustainability statements and audit the ESG area at least once every
two years. The Internal Auditor reports organisationally to the President of the Management
Board and functionally to the Chairman of the Audit Committee in accordance with the rules
provided for in the Internal Audit Regulations. The tasks of the Internal Audit Department
include examining and assessing the correctness and effectiveness of internal processes,
rules and procedures at XTB. The Internal Auditor also has an advisory role to other
organisational units, including the unit responsible for risk management, ESG and reporting.
Within the structure of XTB S.A., there is also a Risk Control Department managed
by the Member of the Management Board for Risk Management. Legal and compliance
issues, on the other hand, are overseen by a legal team managed by the Board Member
for Legal Affairs. The purpose of the XTB Risk Management System is to ensure informed
and controlled risk-taking within the XTB Group. Risk management policies are developed
to identify and measure the risks taken, as well as to mitigate them and set appropriate limits
to reduce the scale of exposure to these risks.
Within the Supervisory Board, there is a Committee for Risk Management. The Company has
also established an Audit Committee, which functions as a separate committee.
4.5. Supplier relationship management
G1-2 / G1-5 / G1-6 We aim to build long-term and stable relationships with our
suppliers through communication and responsible payment practices. Despite analysis we
have not found the key opportunities and risks of this area, which is caused by, among other
things, the non-productive nature of our business and the business characteristics of the
partners we work with (regulated institutions, partners from the European Union area). When
selecting suppliers, we are guided by their good reputation in the market and assess our
relationships on the basis of ongoing cooperation and contact; as of the date of publication of
the Statement, we have not included environmental and social criteria in our assessment
when selecting suppliers.
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Supply chain risks and sustainability impacts are minimised, as we are not in a situation where
we are dependent on one supplier or threatened by supply chain disruptions. Among
suppliers, we mainly identify suppliers of IT infrastructure, office supplies and services
(e.g. marketing and advertising).
The XTB Group has not adopted a policy regulating the rules of payment for suppliers,
nor do we adjust payment terms depending on the type of supplier, and in the reporting period
we did not take any significant actions or set any goals in this area. Payment terms are
determined each time during individual negotiations of contractual provisions between XTB
and suppliers. Despite the lack of procedures in the area of payments, also towards our SME
sector partners, we adhere to the principle of the most effective settlement of liabilities,
and in 2024, 78% of payments made on the scale of the XTB Group were made in accordance
with the adopted payment standards.
G1-6 MDR-P The XTB Group has not adopted a policy governing payment terms
for suppliers, nor do we adjust payment terms according to supplier type as payment terms
are determined during individual negotiations of contractual provisions between XTB
and suppliers. Despite the lack of procedures in the area of payments, we adhere
to the principle of paying our business partners as efficiently as possible, and as many
as 78% of payments made at Group level were made in accordance with accepted payment
standards.
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/ Sustainability Statement for 2024
Investor Relations
Table 42. Standard payment rules at XTB Group in 2024
Reporting period
01.01.2024 – 31.12.2024
Average number of days needed to pay
an invoice from the start of the contractual
or statutory payment period
15
Number of pending legal proceedings for late
payment
0
Standard payment terms (average number
of days)
14
Number of payments made according
to standard conditions
21 971
Total number of payments made
28 280
% of payments compliant with the standard
payment conditions
78%
4.6. Due diligence statement
GOV-4 Pursuing sustainable business is a complex process that requires thoughtful
actions spread over time across the XTB Group. Due diligence, as we understand it,
is a series of continuous activities aimed at monitoring, improving and verifying the
effectiveness of implemented solutions. The process is intended to accompany the business
throughout its operations, supporting its growth by improving strategic and operational
processes.
In all of its operations, the XTB Group is guided by the principles set out in the international
United Nations (UN) Guiding Principles on Business and Human Rights and the OECD
Guidelines for International Enterprises. As an entity listed on the Warsaw Stock Exchange
and regulated on the largest financial markets, we operate in accordance with the
recommendations of the Polish Financial Supervision Authority and regulators on local
markets. Therefore, we exercise due diligence in all processes, including the area
of sustainable development.
Table 43. Basic elements of due dilligence proccess
Basic element of due
dilligence
Area
Reference in the Sustainability Statement
Integrating Due
Diligence
into Corporate
Governance, Strategy
and Business Model
E, S, G
Chapter 1.3. Sustainability management
Chapter 1.6. Material impacts, opportunities and
risks
Chapter 3.1. Our employees
Chapter 3.2. Consumers and end-users
Collaboration
with stakeholders
that the entity
influences
E, S, G
Chapter 1.3. Sustainability management
Chapter 1.5. Key stakeholers
Chapter 3.2. Consumers and end-users
Chapter 1.6. Material impacts, opportunities and
risks
Chapter 2.1.1. The XTB’s Group’s climate policy
Chapter 4.3. Corporate culture and ethics
Chapter 4.5. Supplier relationship management
Identification and
assessment of negative
impacts on people
and the environment
Chapter 1.6. Material impacts, opportunities and
risks
Chapter 3.1. Our employees
Chapter 3.2. Consumers and end-users
Taking action to reduce
identified negative
impacts on people
and the environment
E, S, G
Chapter 2.1.1. The XTB’s Group’s climate policy
Monitoring the
effectiveness of these
efforts and providing
relevant information
in this regard
E, S, G
Chapter 2.1.2. Fuel and energy consumption
Chapter 2.1.3. Greenhouse gas emissions
Chapter 3.1.5. Regulatory policies
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At the XTB Group, we have been implementing due diligence processes for years
with the help of the Legal and Compliance department, which is partly driven by the nature
of XTB's business as a financial institution listed on the Stock Exchange since 2016, but also
by the need to develop the business as well as to build a responsible corporate culture
and competitive advantage. We have been reporting non-financially since 2022, gradually
building our awareness, getting our processes in order and achieving further milestones.
The analyses and reports, the business and ESG strategy, the policies, codes and procedures
implemented and the actions taken have helped us to carry out a Double materiality
assessment at the beginning of 2024 and identify the key ESG impacts, opportunities
and risks. We have reviewed the policies, identified areas for further improvement
and the negative impacts we intend to manage and mitigate. In the next reporting periods,
our will is to further improve the due diligence.
As part of our due diligence, our business is determined by:
▪ XTB Group's Business Strategy and ESG Strategy: the Business Strategy, together
with the Sustainability Strategy, are key documents that are complementary to each
other and determine XTB Group's activities. The objectives set complement each
other, and support the embodiment of ESG criteria to even greater benefit
of our Stakeholders.
▪ XTB Code of Ethics, Anti-Mobbing and Anti-Discrimination Policy, Diversity Policy,
AML CFT Policy and Anti-Corruption Policy: these are the core umbrella documents
of our business, which not only set out XTB operating principles, but also represent
our commitment to uphold and support business ethics, improvement
and the stigmatisation of fraudulent practices. We do not approve of any human
rights violations, unethical behaviour and corruption or bribery.
▪ Internal and external whistleblowing procedure: We give our Stakeholders
the opportunity to report any identified violations and irregularities putting at their
disposal publicly available communication channels that also ensure full anonymity
of the reporter. The whistleblower is placed under the statutory protection
of a whistleblower, against whom any retaliation is prohibited.
▪ Other procedures, policies and instructions.
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In line with the due diligence process, all corporate documents are subject to review
and update and are publicly known and available among the XTB Group employees.
Consideration of due diligence in governance,
strategy and business model through the
legislative environment in which we operate
and XTB's implemented corporate documents,
i.e. Code of Ethics, Anti-Mobbing and Anti-
Discrimination Policy, AML CFT Policy, DEI
Policy and Anti-Corruption Policy.
1
Collaboration with affected stakeholders at all
key stages of the due diligence process and a
double materiality assessment involving
surveys and in-depth interviews with the
stakeholders, which key opportunities, risks
and impacts for XTB Group have been
identified.
2
Identification and assessment of the adverse
impacts, taking action to mitigate identified
adverse impacts by managing impacts,
opportunities and risks with the involvement
of the relevant business units and with
the assistance of the internal audit, risk
management, ESG and compliance units.
3
Monitoring of the effectiveness of these efforts
and provision of relevant information in this
regard: updates and monitoring of processes,
volumes of requests and internal and external
request channels made available.
4
Remedial actions: an agreed catalogue
of remedial actions, whereby we commit to
taking concrete action for those affected and
supporting the fair clarification of reports.
5
325
Annex 1. Scoreboards –Taxonomy
Table 44. Turnover rate.
2024
Year
Criteria for significant contribution
Criteria for the DNSH
("Do No Serious Harm") principle (h)
Economic activity (1)
Code or codes (a)
(2)
Turnover (in PLN
thousands) (3)
Part of turnover,
2024 (4)
Climate change
mitigation (5)
Adaptation to climate
change (6)
Water and marine
resources (7)
Pollution (8)
Circular economy (9)
Biodiversity (10)
Mitigating climate
change (11)
Adaptation to climate
change (12)
Water and marine
resources (13)
Pollution (14)
Circular economy
(15)
Biodiversity (16)
Minimum guarantees
(17)
Percentage of
systematically
compliant turnover,
2023 (18)
Category Support
activities (19)
Category Transition
activities (20)
Text
Currency
%
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
%
E
Y
A. ACTIVITIES ELIGIBLE FOR SYSTEMATISATION
A.1. Types of environmentally sustainable activities (consistent with the systematics)
Computer
programming, IT
consultancy and
related activities
CCA
62
5 060,99
0,27%
N
Y
N
N
N
N
Y
Y
Y
Y
Y
Y
0,50%
326
Turnover from
environmentally
sustainable
activities
(compatible
with the
systematics)
(A.1)
5 060,99
0,27%
0,27%
Including supporting
Including for the
transition
A.2 Activities eligible for systematics but environmentally unsustainable (activities not aligned with systematics)
EL;
N/EL
EL;
N/EL
EL;
N/EL
EL;
N/EL
EL;
N/EL
EL;
N/EL
Data
processing;
website
management
(hosting) and
related
activities
63.11
1 265,25
0,07%
N/EL
EL
N/EL
N/EL
N/EL
N/EL
Turnover from
activities eligible
for the
systematics but
not
environmentally
sustainable
(activities not
aligned with the
systematics)
(A.2)
1 265,25
0,07%
0,07%
327
A. Turnover from
activities eligible
for the
systematics
(A.1+A.2)
6 326,24
0,34%
0,34%
B. ACTIVITIES NON-ELIGIBLE FOR THE
SYSTEMATICS
Turnover from
the activities
non-eligible for
systematics
1 867
110,24
99,66%
TOTAL
1 873
436,48
100,00%
328
Table 45. Capital expenditure ratio.
2024
Year
Criteria for significant contribution
Criteria for the DNSH ("Do No Serious
Harm") principle (h)
Economic activity (1)
Code or codes (a) (2)
Capital expenditure (in
PLN thousands) (3)
Percentage of capital
expenditure, 2024 (4)
Climate change
mitigation (5)
Adaptation to climate
change (6)
Water and marine
resources (7)
Pollution (8)
Circular economy (9)
Biodiversity (10)
Mitigating climate
change (11)
Adaptation to climate
change (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum guarantees
(17)
Share of activities
aligned with the
systematics (A.1.) or
qualifying for
systematics (A.2.)
Capital expenditure,
year 2023 (18)
Category Support
activities (19)
Category Transition
activities (20)
Text
Curren
cy
%
Y;
N;
N/E
L
Y;
N;
N/E
L
Y;
N;
N/E
L
Y; N;
N/EL
Y; N;
N/EL
Y;
N;
N/
E
L
Y/N
Y/
N
Y/N
Y/N
Y/N
Y/N
Y/N
%
E
Y
A. ACTIVITIES ELIGIBLE FOR SYSTEMATISATION
A.1. Types of environmentally sustainable activities (according to the systematics)
Computer
programming, IT
consultancy and
related activities
C
C
A
62
4,82
0,02
%
N
Y
N
N
N
N
Y
Y
Y
Y
Y
Y
0.11%
329
Capital
expenditures
for
environmentall
y sustainable
activities
(consistent
with the
systematics)
(A.1)
4,82
0,02
%
0,0
2%
Including supporting
Including for the
transition
A.2 Activities eligible for systematics but environmentally unsustainable (activities not aligned with systematics) (g)
EL;
N/E
L
EL;
N/E
L
EL;
N/E
L
EL;
N/EL
EL;
N/EL
E
L;
N/
E
L
Data
processing;
website
management
(hosting) and
related
activities
63
.1
1
1,20
0,01
%
N/E
L
EL
N/E
L
N/EL
N/EL
N/
E
L
330
Capital
expenditures for
activities eligible
for the
systematics but
not
environmentally
sustainable
(activities not
aligned with the
systematics)
(A.2)
1,20
0,01
%
0,0
1%
A. Capital
expenditure
from eligible
activities to
systematics
(A.1+A.2)
6,02
0,03
%
0,0
3%
B. ACTIVITIES NON-ELIGIBLE FOR
THE SYSTEMATICS
Capital
expenditure for
non-systematic
activities
20
654,87
99,97
%
TOTAL
20
660,89
100,0
0%
331
Table 46. Operating expenditure ratio.
2024
Year
Criteria for significant contribution
Criteria for the DNSH ("Do No Serious
Harm") principle (h)
Economic activity
(1)
Code or codes (a) (2)
Operating expenditure
(in PLN thousands) (3)
Percentage of
operating expenditure,
year 2024 (4)
Climate change
mitigation (5)
Adaptation to climate
change (6)
Water and marine
resources (7)
Pollution (8)
Circular economy (9)
Biodiversity (10)
Mitigating climate
change (11)
Adaptation to climate
change (12)
Water and marine
resources (13)
Pollution (14)
Circular economy (15)
Biodiversity (16)
Minimum guarantees
(17)
Share of activities
aligned with the
systematics (A.1.) or
qualifying for
systematics (A.2.)
Operating expenditure,
year 2023 (18)
Category Support
activities (19)
Category Transition
activities (20)
Text
Currency
%
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
%
E
Y
A. ACTIVITIES ELIGIBLE FOR SYSTEMATISATION
A.1. Types of environmentally sustainable activities (according to the systematics)
Computer programming, IT
consultancy and related activities
CCA
62
4 907,36
0,55%
N
Y
N
N
N
N
Y
Y
Y
Y
Y
Y
1,13%
Operating expenditure
for environmentally sustainable
activities (aligned with the
systematics) (A.1)
4 907,36
0,55%
0,55%
Including supporting
Including for the transition
A.2 Activities eligible for systematics but environmentally unsustainable (activities not aligned with systematics) (g)
332
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL
(f)
EL;
N/EL
EL;
N/EL
EL;
N/EL
Data processing; website
management (hosting) and
related activities
63.11
1 226,84
0,14%
N/EL
EL
N/EL
N/EL
N/EL
N/EL
Operational expenditure for
activities eligible for systematics,
but not environmentally
sustainable (activities not aligned
with the systematics) (A.2)
1 226,84
0,14%
0,14%
A. Operating expenditure on
activities eligible to systematics
(A.1+A.2)
6 134,21
0,69%
0,69%
B. ACTIVITIES NON-ELIGIBLE FOR THE SYSTEMATICS
Operational expenditure for non-
eligible activities for systematics
880
566,54
99,31%
TOTAL
886
700,75
100.00%
333
Table 47. Summary of key performance indicators to be disclosed by investment firms.
Total environmentally
sustainable assets -
turnover ratio
Total
environmentally
sustainable assets
– capital
expenditure
(CAPEX)
KPI – turnover rate
KPI – capital
expenditure (CAPEX)
% coverage (in total
assets)
Key performance
indicator (for the
purposes of
proprietary trading)
Green asset indicator
0
0
0%
0%
0%
Revenue from total
environmentally
sustainable activities
and services - turnover
ratio
Revenue from total
environmentally
sustainable
activities and
services – capital
expenditure
(CAPEX)
KPI – turnover rate
KPI – capital
expenditure (CAPEX)
% coverage (in total
revenue)
Key performance
indicator (for services
and activities of
others)
Key performance
indicator on revenue
0
0
0%
0%
0%
334
Table 48a. Key performance indicators for investment companies: services of trading for company's own account (revenues).
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
w
x
y
z
Total
(PLN
million)
Of which
covered by
key
performance
indicators
(PLN million)
Climate Change Mitigation (CCM)
Adapting to climate
change
Water and marine
resources (WMR)
Circular economy (CE)
Pollution (PPC)
Biodiversity and
ecosystems (BIO)
TOTAL
(CCM+CCA+WTR+CE+PPC+BIO)
Of which EU systematics assets (%)
(eligible for systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics assets (%)
(eligible for systematics)
Of which activities aligned with
systematics (%) EU (%)
(aligned with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities aligned with
systematics (%) EU (%)
(aligned with systematics)
Of which
for
transition
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
for
transition
(%)
Of which
supporting
(%)
1.
Total assets
invested as part
of the business
of investment
companies
making
transactions on
their own
account*
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2.
of which: on
their own
account
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
3.
of which: on
clients' account
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
* excluding government bonds
335
Table 48b. Key performance indicators for investment companies: services of trading for company's own account (CAPEX).
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
w
x
y
z
Total
(PLN
million)
Of which
covered by
key
performance
indicators
(PLN million)
Climate Change Mitigation (CCM)
Adapting to climate
change
Water and marine
resources (WMR)
Circular economy (CE)
Pollution (PPC)
Biodiversity and
ecosystems (BIO)
TOTAL
(CCM+CCA+WTR+CE+PPC+BIO)
Of which EU systematics assets (%)
(eligible for systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics
assets (%) (eligible for
systematics)
Of which EU systematics assets (%)
(eligible for systematics)
Of which activities aligned with
systematics (%) EU (%)
(aligned with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities
aligned with
systematics (%)
EU (%) (aligned
with systematics)
Of which activities aligned with
systematics (%) EU (%)
(aligned with systematics)
Of which
for
transition
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
for
transition
(%)
Of which
supporting
(%)
1.
Total assets
invested as part
of the business
of investment
companies
making
transactions on
their own
account*
694
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2.
of which: on
their own
account
694
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
3.
of which: on
clients' account
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
* excluding government bonds
336
Table 49. Scoreboard – key performance indicators of investment firms – other services.
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
w
x
y
z
Total
(PLN
million)
Of which
covered by
key
performance
indicators
(PLN
million)
Climate Change Mitigation (CCM)
Adapting to climate
change
Water and marine
resources (WMR)
Circular economy (CE)
Pollution (PPC)
Biodiversity and
ecosystems (BIO)
TOTAL
(CCM+CCA+WTR+CE+PPC+BIO)
Including revenues (fees,
commissions and other monetary
benefits) from services and
activities to the sectors covered by
the EU systematics (%) (eligible for
systematics)
Including revenues
(fees, commissions
and other monetary
benefits) from
services and activities
to the sectors covered
by the EU systematics
(%) (eligible for
systematics)
Including revenues
(fees, commissions
and other monetary
benefits) from
services and activities
to the sectors covered
by the EU systematics
(%) (eligible for
systematics)
Including revenues (fees,
commissions and other
monetary benefits) from
services and activities to
the sectors covered by
the EU systematics (%)
(eligible for systematics)
Of which EU
systematics assets
(%) (eligible for
systematics)
Of which EU
systematics assets
(%) (eligible for
systematics)
Including revenues (fees, commissions
and other monetary benefits) from
services and activities to the sectors
covered by the EU systematics (%)
(eligible for systematics)
Of which for activities and
services related to the
activities aligned with the
systematics (%)
Of which
activities
aligned with
systematics (%)
EU (%) (aligned
with
systematics)
Of which
activities
aligned with
systematics (%)
EU (%) (aligned
with
systematics)
Of which activities
aligned with
systematics (%) EU
(%) (aligned with
systematics)
Of which
activities
aligned with
systematics (%)
EU (%) (aligned
with
systematics)
Of which
activities
aligned with
systematics (%)
EU (%) (aligned
with
systematics)
Of which activities aligned with
systematics (%) EU (%) (aligned with
systematics)
Of which
for
transition
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
supporting
(%)
Of which
for
transition
(%)
Of which
supporting
(%)
1.
Income (i.e. fees,
commissions, and
other monetary
benefits) from
investments and
activities and services
other than
transactions on
company's own
account
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2.
Acceptance and
transmission of
orders in connection
with one or more
financial instruments
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
3.
Execution of orders
on behalf of the client
15,74
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
4.
Portfolio management
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
5.
Investment consulting
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
6.
Underwriting of
financial instruments
or underwriting of
financial instruments
with a guarantee of
assumption of issue
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
337
7.
Underwriting of
financial instruments
without guarantee of
assumption of issue
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
8.
Operation of
multilateral trading
facilities
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
9.
Operation of
organised trading
facilities
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
Commission income relates to: recurring fees from institutional partners, regulatory commissions (i.e. for withdrawals below a threshold amount, the issuing of PITs, etc.), inactivity fees, for the transfer of client securities from/to another brokerage, custody fees for client securities.
338
The tables below refer to the ratio of total assets invested in the proprietary trading activities of investment firms and the ratio of revenues related
to the execution of orders on behalf of clients.
Table 50. Activity related to nuclear energy and natural gas – scope of activities.
Activity related to nuclear energy
1.
The company conducts, finances or has exposure to the research, development, demonstration and deployment of innovative power generation facilities
that produce energy through nuclear processes with minimal fuel cycle waste.
no
2.
The company constructs, finances or has exposure to the construction and safe operation of new nuclear facilities for the generation of electricity
or process heat, including for district heating or industrial processes such as hydrogen production, as well as their safety upgrades using the best
available technology.
no
3.
The company conducts, finances or has exposure to the safe operation of existing nuclear facilities for the generation of electricity or process heat,
including for district heating or industrial processes such as hydrogen production, as well as their safety upgrades using the best available technology.
no
Activities related to natural gas
4.
The company constructs, operates, finances or has exposure to the facilities for the generation of electricity using gaseous fossil fuels.
no
5.
The company constructs, modernises, operates, finances or has exposure to combined heat/cooling and electricity generation facilities
using gaseous fossil fuels.
no
6.
The company constructs, modernises, operates, finances or has exposure to heat/cooling generation facilities using gaseous fossil fuels.
no
339
Table 51a. Nuclear and natural gas activities – economic activities in line with the systematics – revenues.
Row
Types of economic activity
Amount and share (information to be provided in monetary
amounts and percentages)
CCM + CCA
Climate Change Mitigation
(CCM)
Climate Change
Adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.26 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
2.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.27 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
3.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.28 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
4.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.29 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
5.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.30 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
340
6.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.31 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
7.
Amount and share of other economic activities consistent with the taxonomy
not included in rows 1–6 above in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
8.
Overall applicable key performance indicator.
0
0%
0
0%
0
0%
Table 51b. Nuclear and natural gas related activities - economic activity in line with the systematics - by capital expenditure (CAPEX).
Row
Types of economic activity
Amount and share (information to be provided in monetary
amounts and percentages)
CCM + CCA
Climate Change Mitigation
(CCM)
Climate Change
Adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.26 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
2.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.27 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
3.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.28 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
341
4.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.29 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
5.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.30 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
0
0%
0
0%
0
0%
6.
Amount and share of economic activities in line with the taxonomy referred
to in Section 4.31 of Annexes I and II to Delegated Regulation (EU) 2021/2139
in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
7.
Amount and share of other economic activities consistent with the taxonomy
not included in rows 1–6 above in the denominator of the applicable KPI.
0
0%
0
0%
0
0%
8.
Overall applicable key performance indicator.
0
0%
0
0%
0
0%
342
Table 52a. Nuclear and natural gas activities – economic activities in line with the systematics (numerator) – revenues.
Row
Types of economic activity
Amount and share (information to be provided in monetary
amounts and percentages)
CCM + CCA
Climate Change
Mitigation (CCM)
Climate Change
Adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and share of economic activity following the systematics referred to
in Section 4.26 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the numerator of the applicable key performance indicator.
0
0%
0
0%
0
0%
2.
Amount and share of economic activity following the systematics referred to
in Section 4.27 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the numerator of the applicable key performance indicator.
0
0%
0
0%
0
0%
3.
Amount and share of economic activity following the systematics referred to
in Section 4.28 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the numerator of the applicable key performance indicator.
0
0%
0
0%
0
0%
4.
Amount and share of economic activity following the systematics referred to
in Section 4.29 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the numerator of the applicable key performance indicator.
0
0%
0
0%
0
0%
5.
Amount and share of economic activity following the systematics referred to
in Section 4.30 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the numerator of the applicable key performance indicator.
0
0%
0
0%
0
0%
6.
Amount and share of economic activity following the systematics referred to
in Section 4.31 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
7.
Amount and share of other economic activities aligned with the systematics
and not listed in rows 1-6 above in the numerator of the applicable key
performance indicator.
0
0%
0
0%
0
0%
343
8.
Total amount and total share of types of economic activity consistent with
the taxonomy in the numerator of the applicable key performance indicator.
0
0%
0
0%
0
0%
Table 52b. Nuclear and natural gas activities – economic activities aligned with the systematics (numerator) – CAPEX.
Row
Types of economic activity
Amount and share (information to be provided in monetary amounts
and percentages)
CCM + CCA
Climate Change Mitigation
(CCM)
Climate Change
Adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and share of systematic economic activity, referred to in Section
4.26 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
2.
Amount and share of economic activity aligned with the systematics referred
to in Section 4.27 of Annexes I and II of Delegated Regulation (EU)
2021/2139 in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
3.
Amount and share of economic activity aligned with the systematics referred
to in Section 4.28 of Annexes I and II of Delegated Regulation (EU)
2021/2139 in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
4.
Amount and share of economic activity aligned with the systematics referred
to in Section 4.29 of Annexes I and II of Delegated Regulation (EU)
2021/2139 in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
5.
Amount and share of economic activity aligned with the systematics referred
to in Section 4.30 of Annexes I and II of Delegated Regulation (EU)
2021/2139 in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
6.
Amount and share of economic activity aligned with the systematics referred
to in Section 4.31 of Annexes I and II of Delegated Regulation (EU)
2021/2139 in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
344
7.
Amount and share of other systematic economic activities not listed in rows
1-6 above in the numerator of the applicable key performance indicator
0
0%
0
0%
0
0%
8.
Total amount and total share of economic activities aligned with the
systematics in the numerator of the applicable key performance indicator.
0
0%
0
0%
0
0%
345
Table 53a. Nuclear and natural gas activities – economic activities that are eligible for the systematics but do not comply with the systematics – revenues.
Row
Types of economic activity
Amount and share (information to be provided in monetary amounts
and percentages)
CCM + CCA
Climate Change Mitigation
(CCM)
Climate Change Adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.26 of Annexes I and II
to Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
2.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.27 of Annexes I and II
to Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
3.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.28 of Annexes I and II
of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
4.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.29 of Annexes I and II
to Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
5.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.30 of Annexes I and II
of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
6.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.31 of Annexes I and II
of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
0
0%
0
0%
0
0%
7.
Amount and share of other economic activities eligible for the systematics,
but not aligned with the systematics, not listed in rows 1-6 above
in the denominator of the applicable key performance indicator
0
0%
0
0%
0
0%
8.
Total amount and total share of economic activities eligible for the
systematics, but not aligned with the systematics in the denominator
of the applicable key performance indicator
0
0%
0
0%
0
0%
Table 53b. Nuclear and natural gas activities – economic activities that are eligible for the systematics but do not comply with the systematics - CAPEX
346
Row
Types of economic activity
Amount and share (information to be provided in monetary amounts
and percentages)
CCM + CCA
Climate Change Mitigation
(CCM)
Climate Change Adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.26 of Annexes I and II
to Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
2.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.27 of Annexes I and II
to Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
3.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.28 of Annexes I and II
of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
4.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.29 of Annexes I and II
to Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator.
0
0%
0
0%
0
0%
5.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.30 of Annexes I and II
of Delegated Regulation (EU) 2021/2139 in the denominator of the
applicable key performance indicator.
0
0%
0
0%
0
0%
6.
Amount and share of economic activities eligible for the systematics, but not
aligned with the systematics referred to in Section 4.31 of Annexes I and II
of Delegated Regulation (EU) 2021/2139 in the denominator of the
applicable key performance indicator
0
0%
0
0%
0
0%
7.
Amount and share of other economic activities eligible for the systematics,
but not aligned with the systematics, not listed in rows 1-6 above
in the denominator of the applicable key performance indicator
0
0%
0
0%
0
0%
8.
Total amount and total share of economic activities eligible for the
systematics, but not aligned with the systematics in the denominator
of the applicable key performance indicator
0
0%
0
0%
0
0%
347
Table 54a. Non-systematic business activities – data for the indicator of total assets invested in the trading activities of investment firms on their own account – revenues.
Row
Types of economic activity
Amount
(PLN million)
%
1.
Amount and share of the economic activity referred to in row 1 of template 1 which is an economic activity that is not eligible
for the systematics according to section 4.26 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
0
0%
2.
Amount and share of the economic activity referred to in row 2 of template 1 which is an economic activity that that is not eligible
for the systematics according to section 4.27 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
0
0%
3.
Amount and share of the economic activity referred to in row 3 of template 1 which is an economic activity that that is not eligible
for the systematics according to Section 4.28 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
0
0%
4.
Amount and share of the economic activity referred to in row 4 of template 1 which is an economic activity that is not eligible
for the systematics according to Section 4.29 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
0
0%
5.
Amount and share of the economic activity referred to in line 5 of template 1 which is an economic activity that is not eligible
for the systematics according to Section 4.30 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
0
0%
6.
Amount and share of the economic activity referred to in line 6 of template 1 which is an economic activity that is not eligible
for the systematics according to Section 4.31 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
0
0%
7.
Amount and share of other economic activities not eligible for the systematics that have not been listed in rows 1-6 above
in the denominator of the applicable key performance indicator
0
0%
8.
Total amount and total share of economic activities is not eligible for the systematics in the denominator of the applicable key
performance indicator
0
0%
348
Table 54b. Non-systematic business activities – data for the indicator of total assets invested in the trading activities of investment firms on their own account. - CAPEX
Row
Types of economic activity
Amount
(PLN million)
%
1.
Amount and share of the economic activity referred to in row 1 of template 1 which is an economic activity that is not eligible
for the systematics according to section 4.26 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
694,27
100%
2.
Amount and share of the economic activity referred to in row 2 of template 1 which is an economic activity that that is not eligible
for the systematics according to section 4.27 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
694,27
100%
3.
Amount and share of the economic activity referred to in row 3 of template 1 which is an economic activity that that is not eligible
for the systematics according to Section 4.28 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
694,27
100%
4.
Amount and share of the economic activity referred to in row 4 of template 1 which is an economic activity that is not eligible
for the systematics according to Section 4.29 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
694,27
100%
5.
Amount and share of the economic activity referred to in line 5 of template 1 which is an economic activity that is not eligible
for the systematics according to Section 4.30 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
694,27
100%
6.
Amount and share of the economic activity referred to in line 6 of template 1 which is an economic activity that is not eligible
for the systematics according to Section 4.31 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the denominator
of the applicable key performance indicator
694,27
100%
7.
Amount and share of other economic activities not eligible for the systematics that have not been listed in rows 1-6 above
in the denominator of the applicable key performance indicator
694,27
100%
8.
Total amount and total share of economic activities is not eligible for the systematics in the denominator of the applicable key
performance indicator
694,27
100%
349
Table 55a. Business activities not eligible for the systematics data for the Investment Firms Performance Indicator – other services. Commissions and fees related to the execution
of orders on behalf of the client – revenues.
Row
Types of economic activity
Amount
(PLN million)
%
1.
Amount and share of economic activity referred to in row 1 of template 1, which is an economic activity not eligible
for the systematisation according to section 4.26 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
15,74
100%
2.
Amount and share of economic activity referred to in row 2 of template 1, which is an economic activity that is not eligible
for the systematics according to section 4.27 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
15,74
100%
3.
Amount and share of economic activity referred to in row 3 of template 1, which is an economic activity not eligible
for the systematisation according to section 4.28 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
15,74
100%
4.
Amount and share of economic activity referred to in row 4 of template 1, which is an economic activity not eligible
for the systematisation according to section 4.29 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
15,74
100%
5.
Amount and share of economic activity referred to in row 5 of template 1, which is an economic activity not eligible
for the systematics according to section 4.30 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
15,74
100%
6.
Amount and share of economic activity referred to in row 6 of template 1, which is an economic activity not eligible
for the systematics according to section 4.31 of Annexes I and II of Delegated Regulation (EU) 2021/2139
in the denominator of the applicable key performance indicator.
15,74
100%
7.
Amount and share of other economic activities not eligible for systematics that have not been listed in rows 1-6 above
in the denominator of the applicable key performance indicator.
15,74
100%
8.
Total amount and total share of economic activities not eligible for systematics in the denominator of the applicable key
performance indicator.
15,74
100%
350
Table 55b. Business activities not eligible for the systematics data for the Investment Firms Performance Indicator – other services. Commissions and fees related to the execution
of orders on behalf of the client - CAPEX
Row
Types of economic activity
Amount
(PLN million)
%
1.
Amount and share of economic activity referred to in row 1 of template 1, which is an economic activity not eligible
for the systematisation according to section 4.26 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the
denominator of the applicable key performance indicator.
0
0%
2.
Amount and share of economic activity referred to in row 2 of template 1, which is an economic activity that is not eligible
for the systematics according to section 4.27 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the
denominator of the applicable key performance indicator.
0
0%
3.
Amount and share of economic activity referred to in row 3 of template 1, which is an economic activity not eligible
for the systematisation according to section 4.28 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the
denominator of the applicable key performance indicator.
0
0%
4.
Amount and share of economic activity referred to in row 4 of template 1, which is an economic activity not eligible
for the systematisation according to section 4.29 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the
denominator of the applicable key performance indicator.
0
0%
5.
Amount and share of economic activity referred to in row 5 of template 1, which is an economic activity not eligible
for the systematics according to section 4.30 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the
denominator of the applicable key performance indicator.
0
0%
6.
Amount and share of economic activity referred to in row 6 of template 1, which is an economic activity not eligible
for the systematics according to section 4.31 of Annexes I and II of Delegated Regulation (EU) 2021/2139 in the
denominator of the applicable key performance indicator.
0
0%
7.
Amount and share of other economic activities not eligible for systematics that have not been listed in rows 1-6 above
in the denominator of the applicable key performance indicator.
0
0%
8.
Total amount and total share of economic activities not eligible for systematics in the denominator of the applicable key
performance indicator.
0
0%
351
Management Report of XTB Group and XTB S.A. in 2024
/ Sustainability Statement of the XTB S.A. Capital Group
Statement of the
Management Board
MANAGEMENT REPORT OF XTB GROUP AND XTB S.A. IN 2024
352
Management Report of XTB Group and XTB S.A. in 2024
/ Sustainability Statement of the XTB S.A. Capital Group
Statement and information of the Management Board
Statement of the Management Board of XTB S.A. on the reliability of preparation
of the consolidated and separate financial statements
The Management Board of XTB S.A. declares that, to the best of its knowledge,
the consolidated and separate financial statements for 2024 and the comparative data have
been prepared in accordance with the applicable accounting principles and reflect in a true,
fair and clear manner the assets, financial position and financial result of the Group
and the Company, respectively. In addition, the Management Board declares that the report
on the activities gives a true picture of the development, achievements and position
of the Group and the Company, respectively, including a description of the principal risks
and threats
Information of the Management Board of XTB S.A. on the selection of an audit
company to audit the financial statements
The Management Board of XTB S.A. hereby announces that, on the basis of the statement
of the Supervisory Board, the audit company authorized to audit the financial statements
performing the audit of the annual unconsolidated and consolidated financial statements for
the year 2023 was selected in accordance with the regulations, including those concerning
the selection and procedure for selecting the audit company. At the same time, the
Management Board of XTB S.A. informs that the company and the members of the team
performing the audit of these statements fulfilled the conditions for the preparation of an
impartial and independent report on the audit of the annual consolidated and separate
financial statements, in accordance with the applicable regulations, professional standards
and principles of professional ethics, and that the applicable regulations related to the
rotation of the audit company and the key statutory auditor and mandatory grace periods
are observed. In addition, the Management Board of XTB S.A. announces that the Issuer
has a policy on the selection of the audit company and a policy on the provision of additional
non-audit services to the Issuer by the audit company, an affiliate of the audit company or a
member of its network, including conditionally exempt services provided by the audit
company.
353
Management Report of XTB Group and XTB S.A. in 2024
/ Sustainability Statement of the XTB S.A. Capital Group
Signatures of all required individuals
Date
Name
Function
Signature
20.03.2025
Omar Arnaout
President of the Management Board
The original Polish document is signed with
a qualified electronic signature
20.03.2025
Filip Kaczmarzyk
Board Member
The original Polish document is signed with
a qualified electronic signature
20.03.2025
Paweł Szejko
Board Member
The original Polish document is signed with
a qualified electronic signature
20.03.2025
Jakub Kubacki
Board Member
The original Polish document is signed with
a qualified electronic signature
20.03.2025
Andrzej Przybylski
Board Member
The original Polish document is signed with
a qualified electronic signature