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Independent Statutory Auditor’s Report

on the Audit of Consolidated Annual Financial Statements

of Bank Gospodarstwa Krajowego Group

for the financial year ended

31 December 2024

Forvis Mazars Audyt Sp. z o.o.

ul. Piękna 18

00-549 Warsaw

Forvis Mazars Audyt Sp. z o.o.

Sąd Rejonowy dla m. st. Warszawy, XII Wydział Gospodarczy KRS nr 0000086577, kapitał zakładowy: 1 268 000,00 PLN,

NIP: 5260215409, REGON: 01111097

INDEPENDENT STATUTORY AUDITOR’S REPORT

ON THE AUDIT OF CONSOLIDATED ANNUAL FINANCIAL STATEMENTS

Translation of the document originally issued in Polish

To the Supervisory Board of Bank Gospodarstwa Krajowego

Report on the Audit of Consolidated Annual Financial Statements

Opinion

We have audited the consolidated annual financial statements of the group, the parent undertaking of

which is Bank Gospodarstwa Krajowego (“the Parent Undertaking”) (“Group”), which comprise the

consolidated statement of financial position as at 31 December 2024, the consolidated statement of profit

or loss, the consolidated statement of comprehensive income, the consolidated statement of changes in

equity, the consolidated statement of cash flows for the financial year from 1 January to

31 December 2024 and notes to the consolidated financial statements, comprising a summary of

significant accounting policies and other explanatory notes (“the consolidated financial statements”).

In our opinion, the accompanying consolidated financial statements:

• give a true and fair view of the Group’s property and financial position as at 31 December 2024,

and of its consolidated financial performance and its consolidated cash flows for the financial year

then ended in accordance with the applicable International Financial Reporting Standards as

adopted by the European Union and the adopted accounting principles (policy);

• comply with the legislation applicable to the Group and with the provisions of the Parent

Undertaking’s Articles of Association as to the form and content;

The present opinion is consistent with the additional report to the Audit Committee that we issued

on 11 April 2025.

Forvis Mazars Audyt Sp. z o.o.

Basis for Opinion

We conducted our audit in accordance with National Standards on Auditing as per International Standards

on Auditing adopted by resolution of the National Council of Statutory Auditors no. 3430/52a/2019

of 21 March 2019 regarding national standards on auditing and other documents, as amended (during the

audit, the possibility of early application of the provisions of Resolution No. 105/4/2023 of the National

Council of Statutory Auditors of 18 September 2023 on the establishment of National Auditing Standard

600 (Revised) was exercised) and resolution of the Council of the Polish Agency for Audit Oversight no.

38/I/2022 of 15 November 2022 on national standards on quality control and National Standard on Auditing

220 (Revised) (“NSA”), as well as according to the Act on Statutory Auditors, Audit Firms and Public

Supervision of 11 May 2017 (“the Act on Statutory Auditors” - Journal of Laws of 2024, item 1035 as

amended) and Regulation (EU) No 537/2014 of 16 April 2014 on specific requirements regarding statutory

audit of public-interest entities and repealing Commission Decision 2005/909/EC (“EU Regulation” -

Official Journal of the European Union L 158/77 of 27 May 2014, as amended). Our responsibility under

those standards has been further described in “Statutory Auditor’s Responsibilities for the Audit of the

Consolidated Financial Statements” section of our report.

We are independent of the Group Companies in accordance with the International Code of Ethics for

Professional Accountants (including International Independence Standards) issued by the International

Ethics Standards Board for Accountants (“the IESBA Code”), adopted by resolution of the National Council

of Statutory Auditors No. 3431/52a/2019 of 25 March 2019 on the principles of professional ethics for

statutory auditors, as amended and other ethical requirements which are applicable to the audit of financial

statements in Poland. We have fulfilled our other ethical responsibilities in accordance with these

requirements and the IESBA Code. During the audit the key statutory auditor and the audit firm remained

independent of the Group Companies in accordance with the independence requirements set out in the

Act on Statutory Auditors and in the EU Regulation.

We believe that the audit evidence that we have obtained is sufficient and appropriate to provide a basis

for our audit opinion.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in the

audit of the consolidated financial statements of the current reporting period. These include the most

significant assessed risks of material misstatement, including the assessed risks of material misstatement

due to fraud. These matters were addressed in the context of our audit of the consolidated financial

statements as a whole and in forming our opinion thereon, and we summarized our responses to these

risks, and, where deemed appropriate, presented the most important observations related to these risks.

We do not provide a separate opinion on these matters.

Forvis Mazars Audyt Sp. z o.o.

Key audit matter

How our audit responded to this matter

Loss allowances for expected credit losses in

the portfolio of loans and advances to

customers

In accordance with International Financial

Reporting Standard 9 Financial instruments

(“IFRS 9”), the Group’s Management Board

should define the value of expected credit losses

that may occur in the period of 12 months or in

the remaining lifetime of a financial asset

depending on the classification of particular

assets to the risk category (“phases”), taking into

consideration the impact of future

macroeconomic conditions on the level of

expected credit losses.

We considered this matter as a key matter

because defining the amount and moment of

recognition of the expected credit losses requires

the exercise of significant judgment and

significant and complex estimates, particularly

with respect to parameters of credit risk in the

expected credit loss calculation models.

In note 21 Loans and advances to customers and

note 45 Credit risk management to the

consolidated financial statements there is

detailed information on the applied methods and

models and the level of loss allowances for

expected credit losses in the portfolio of loans

and advances to customers.

We performed a critical analysis of the design and

implementation of controls within the process of

credit risk assessment and estimation of expected

credit losses and we verified the effectiveness of

these controls.

We reconciled the base of receivables from loans

and advances granted to customers with the

accounting books of the Group in order to confirm

the completeness of the recognition of receivables

from loans and advances to customers being the

base for recognizing loss allowances for the

expected credit losses and the value of these

allowances.

We performed analytical procedures for the

coverage of the loan portfolio with expected credit

losses and their changes, as well as the transfer of

exposures between phases.

We performed the assessment of the Group’s

approach to impairment in terms of compliance

with the requirements of IFRS 9, in particular with

respect to the application of criteria of identification

of a significant increase of credit risk, definition of

failure to perform obligations, adopted credit risk

parameters and consideration of the impact of

future macroeconomic conditions on the level of

expected credit losses.

For the portfolio of loans and advances to

customers assessed using a collective method:

• we verified the calculation of allowances

for expected credit losses for selected

portfolios,

• we verified back-testing of risk parameters

and allowance calculations (so-called

back-testing and model validation reports)

and performed independent testing,

• we analysed the assumptions for the

inclusion of future information in the form

of macro adjustments - we assessed the

adequacy of these assumptions.

Forvis Mazars Audyt Sp. z o.o.

For the portfolio of loans and advances to

customers assessed using the individualised

method:

• we performed the analysis of the process

and methodology of identification of

impairment and classification of exposures

into phases,

• based on a selected sample of significant

credit exposures we got acquainted with

documents concerning the borrower’s

financial situation and checked the

correctness of its allocation to the

appropriate credit phase,

• on a selected sample of impaired loans

and advances to customers (Phase 3), we

tested the assumptions used in calculating

expected credit losses, in particular the

expected scenarios and the probabilities

assigned to them, as well as the timing

and amounts of expected cash flows,

including cash flows from repayments and

collateral realizations.

We also assessed the quality and we checked the

correctness of disclosures concerning allowances

for expected credit losses in the Group’s financial

statements.

Responsibility of the Management Board and Supervisory Board of the Parent Undertaking

for Consolidated Financial Statements

The Parent Undertaking’s Management Board is responsible for preparing the consolidated financial

statements that give a true and fair view of the Group’s property and financial position and its financial

performance in accordance with International Financial Reporting Standards as adopted by the European

Union and adopted accounting principles (policy), as well as with the relevant legislation and with the

provisions of the Parent Undertaking’s Articles of Association. The Parent Undertaking’s Management

Board is also responsible for such internal control as the Management Board determines is necessary to

enable the preparation of consolidated financial statements that are free of material misstatement, whether

due to fraud or error.

When preparing the consolidated financial statements, the Parent Undertaking’s Management Board is

responsible for assessing the Group’s ability to continue as a going concern, as well as for disclosing, if

applicable, matters related to going concern and for adopting the going concern assumption as an

accounting basis, unless the Management Board either intends to liquidate the Group or to cease

operations, or has no realistic alternative but to do so.

Forvis Mazars Audyt Sp. z o.o.

The Parent Company’s Management Board and members of its Supervisory Board are obliged to ensure

that the consolidated financial statements meet the requirements set out in the Accounting Act the of 29

September 1994 (“Accounting Act” - Journal of Laws of 2023, item 120 as amended). Members of the

Parent Undertaking’s Supervisory Board are responsible for supervising the financial reporting process.

Statutory Auditor’s Responsibility for Audit of the Consolidated Financial Statements

Our objectives are to obtain reasonable assurance about whether the consolidated financial statements

as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s

report that includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee

that an audit conducted in accordance with the National Standards on Auditing will always detect a material

misstatement when it exists. Misstatements can arise from fraud or error and are considered material if,

individually or in the aggregate, they could reasonably be expected to influence the economic decisions of

users taken on the basis of these consolidated financial statements.

The scope of audit does not include assurance as to the future profitability of the Group and effectiveness

or efficiency of running the Group’s affairs by the Parent Undertaking’s Management Board at present or

in the future.

According to National Standards on Auditing, we exercise professional judgement and maintain

professional skepticism throughout the audit, as well as:

• we identify and assess the risk of material misstatement of the consolidated financial statements,

whether due to fraud or error, we design and perform audit procedures in response to this risk and

we obtain audit evidence which is sufficient and appropriate to provide a basis for our audit opinion.

The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting

from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or

the override of internal control;

• we obtain understanding of internal control applied for the purposes of audit in order to design audit

procedures that are appropriate in the circumstances, but not for the purpose of expressing an

opinion on the effectiveness of the internal control in the Group;

• we evaluate the appropriateness of the accounting principles (policy) used, the reasonableness of

the accounting estimates and related disclosures provided by the Management Board of the Parent

Undertaking;

• we conclude on the appropriateness of the Parent Undertaking’s management’s use of the going

concern principle as a basis of accounting and, based on the audit evidence obtained, whether a

significant uncertainty related to events or conditions exists and if that may cast significant doubt

on the Group’s ability to continue as a going concern. If we come to the conclusion that a material

uncertainty exists, we are required to pay attention in our auditor’s report on related disclosures in

the consolidated financial statements or, if such disclosures are inadequate, to modify our opinion.

Our conclusions are based on the audit evidence obtained up to the date of the auditor’s report.

However, future events or conditions may cause the Group to cease to continue as a going

concern;

• we evaluate the overall presentation, structure and content of the consolidated financial

statements, including the disclosures, and whether the consolidated financial statements represent

the underlying transactions and events in a manner that achieves fair presentation.

Forvis Mazars Audyt Sp. z o.o.

• we obtain sufficient and appropriate audit evidence related to the financial information of entities

and to the economic activities within the Group, in order to express our opinion on the consolidated

financial statements. We are responsible for directing, supervising and conducting the Group’s

audit and we remain exclusively responsible for our audit opinion.

We communicate with the Parent Undertaking’s Audit Committee regarding, among other matters, the

planned scope and timing of the audit and significant audit findings, including any significant deficiencies

in internal control identified by the auditor during the audit.

We also provide the Parent Undertaking’s Audit Committee with a statement that we have complied with

relevant ethical requirements pertaining to independence and that we will communicate to the Audit

Committee all relationships and other matters that could reasonably be considered to pose a threat to our

independence, and, where applicable, the safeguards applied.

From all the matters communicated to the Audit Committee of the Parent Undertaking, we have chosen

those being of most significance in the audit of the consolidated financial statements of the current

reporting period and therefore we judged them to be Key Audit Matters. We describe these matters in our

auditor’s report unless law or regulation precludes their public disclosure or when, in exceptional

circumstances, we determine that a matter should not be communicated in our report because the adverse

consequences of doing so would reasonably be expected to outweigh the public interest benefits of such

communication.

Other Information, including the Management Report

Other Information includes the Management Report of the Group for the financial year ended 31 December

2024 (“the Management Report ").

The Management Report of the Group of Bank Gospodarstwa Krajowego in 2024, which includes

the Management Report of Bank Gospodarstwa Krajowego in 2024, were prepared jointly under Article 55

section 2a of the Accounting Act.

Responsibilities of the Management Board and Supervisory Board of the Parent Undertaking

The Parent Undertaking’s Management Board is responsible for preparing the Management Report

in accordance with the applicable regulations.

Moreover, the Parent Undertaking’s Management Board and members of the Parent Undertaking’s

Supervisory Board are obliged to ensure that the Management Report meets the requirements set out in

the Accounting Act.

Statutory Auditor’s Responsibility

Our opinion on the audit of the consolidated financial statements does not cover the Management Report.

Our responsibility regarding the audit of the consolidated financial statements is to get acquainted with the

Management Report and to consider whether it is not significantly incoherent with the consolidated

financial statements or with our knowledge obtained during the audit or whether it seems to be significantly

misstated in other manner. If, based on the work we have performed, we conclude that there is a material

misstatement in the Management Report, we are required to report that fact in our audit report.

In accordance with the Act on Statutory Auditors, our responsibility is also to give an opinion whether the

Management Report, to the extent not relevant to sustainability reporting, has been prepared in

accordance with applicable regulations and whether it complies with the information contained in the

consolidated financial statements. In addition, in accordance with requirements of Article 111a (3) of the

Forvis Mazars Audyt Sp. z o.o.

Act of 29 August 1997 Banking Law (“Banking Law” - Journal of Laws of 2024, item 1646 as amended),

our responsibility is to audit information specified in Article 111a (2) of the Banking Law contained in the

Management Report.

Opinion on the Group Management Report

Based on the work performed during the audit, in our opinion, the Group Management Report:

• has been prepared in accordance with Article 49 of the Accounting Act and Article 111a (2) of the

Banking Law,

• is in line with information contained in the consolidated financial statements.

Moreover, according to our knowledge of the Group and its environment obtained during the audit, we

declare that we have not identified any material misstatement in the Management Report.

Report on Other Legal and Regulatory Requirements

Opinion on the Compliance of the Marking up of the Consolidated Financial Statements

Prepared in the Single Electronic Reporting Format with the Requirements of the

Regulation on Technical Standards on the Specification of a Single Electronic Reporting

Format

In connection with the audit of the consolidated financial statements we have been engaged to perform an

assurance engagement to obtain reasonable assurance in order to express an opinion on whether the

consolidated financial statements of the Group as at 31 December 2024 prepared in the single electronic

reporting format (“consolidated financial statements in ESEF format”) were marked up in accordance with

the requirements specified in the Commission Delegated Regulation (EU) 2019/815 of 17 December 2018

supplementing Directive 2004/109/EC of the European Parliament and of the Council with regard to

regulatory technical standards on the specification of a single electronic format (the “ESEF Regulation”).

Identification of Criteria and Description of the Subject of the Engagement

The consolidated financial statements in ESEF format were prepared by the Parent Undertaking’s

Management Board in order to fulfil the criteria regarding the marking up and technical requirements

concerning the specification of single electronic reporting formal which are specified in the ESEF

Regulation. The subject matter of our assurance engagement is the compliance of marking up of the

consolidated financial statements in ESEF format with the requirements of the ESEF Regulation, and the

requirements specified in these regulations form, in our opinion, adequate criteria to express our opinion.

Responsibilities of the Management Board and Supervisory Board of the Parent Undertaking

The Management Board is responsible for the preparation of the consolidated financial statements in

ESEF format in accordance with the requirements regarding the marking up and technical requirements

concerning the specification of single electronic reporting formal which are specified in the ESEF

Regulation. Such responsibility includes the selection and application of appropriate XBRL markups using

the taxonomy specified in these regulations. The responsibility of the Management Board also includes

the design, implementation, and maintenance of such internal control as determined to be necessary to

enable the preparation of the consolidated financial statements in ESEF format that are free from any

Forvis Mazars Audyt Sp. z o.o.

material incompliance with the ESEF Regulation. Members of the Parent Undertaking’s Supervisory Board

are responsible for supervising the financial reporting process, also including the preparation of the

financial statements according to the format prescribed by applicable laws.

Statutory Auditor’s Responsibility

Our objective was to express an opinion, based on the performed assurance engagement providing

reasonable assurance that the consolidated financial statements in ESEF format were marked up in

accordance with the requirements of the ESEF Regulation. We have performed our engagement in

accordance with the National Standard on Assurance Engagements for the audit of financial statements

prepared in a single electronic format 3001PL (“NSAE 3001PL”), and where applicable, National Standard

on Assurance Engagements Other than Audit and Review 3000 (Revised) in the form of the International

Standard on Assurance Engagements 3000 (revised) – ‘Assurance Engagements Other than Audits or

Reviews of Historical Financial Information (“NSAE 3000 (R)”). This standard imposes an obligation on the

auditor to plan and execute procedures in order to obtain reasonable assurance that the consolidated

financial statements in ESEF format were prepared in accordance with specified criteria. Reasonable

assurance is a high level of assurance but is not a guarantee that an engagement conducted in accordance

with the NSAE 3001PL, and where applicable NSAE 3000(R), will always detect a material misstatement

when it exists.

The procedures selected depend on the auditor’s judgment, including the assessment of the risk of

material misstatements due to fraud or error. When performing risk assessment and in order to design

procedures to be performed the auditor takes into consideration the internal controls related to the

preparation of the consolidated financial statements in ESEF format, which can provide the auditor with

sufficient and appropriate evidence. The assessment of the internal controls was not performed for the

purpose of expressing an opinion on the effectiveness of the internal control.

Summary of the Work Performed

Procedures planned and performed by us included:

• obtaining an understanding of the process of preparation of the consolidated financial statements

in ESEF format, including the process of selection and application of XBRL markups by

the Group and ensuring compliance with the ESEF Regulation, in which the understanding of

internal controls related to this process;

• evaluating the compliance with technical standards concerning the specification of single electronic

format, evaluating the completeness of marking up information in the consolidated financial

statements in ESEF format using XBRL markups;

• evaluating the appropriateness of the use of XBRL markups from the taxonomy specified in the

ESEF Regulation and the creation of extension markups where no suitable element in the core

taxonomy specified in the ESEF Regulation has been identified;

• evaluating the appropriateness of anchoring of the applied taxonomy extensions to the core

taxonomy specified by the ESEF Regulation;

• testing the correctness of the mathematical calculations for particular items marked up using XBRL

markups;

• reconciling of the marked-up information included in the consolidated financial statements in ESEF

format to the audited consolidated financial statements;

• evaluating the completeness of marking up information in the consolidated financial statements in

Forvis Mazars Audyt Sp. z o.o.

ESEF format using XBRL markups

We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our

opinion on the compliance of the marking up with requirements of the ESEF Regulation

Ethical Requirements, Including Independence

While performing the engagement, the statutory auditor and the audit firm complied with the independence

requirements and other ethical requirements as specified by the IESBA Code. The IESBA Code is based

on the fundamental principles related to integrity, objectivity, professional competence and due care,

confidentiality, and professional behavior. We have also complied with other independence and ethical

requirements which are applicable to such assurance engagement in Poland.

Quality Control Requirements

The audit firm applies national standards on quality control introduced by the resolution of the Council of

the Polish Agency for Audit Oversight No. 38/I/2022 of 15 November 2022. National Standard on Quality

Control 1 as per International Standard on Quality Management (PL) 1 requires the audit firm to design,

implement and operate a system of quality management, including policies or procedures relating to

compliance with ethical requirements, professional standards and applicable legal and regulatory

requirements.

Opinion on Compliance with ESEF Regulation Requirements

The matters described above constitute the basis for the auditor’s opinion which is why the opinion should

be read in conjunction with these matters. In our opinion, the consolidated financial statements in ESEF

format were marked up in all material respects in accordance with the requirements of the ESEF

Regulation.

Information on Observing Applicable Prudential Regulations

The Parent Undertaking’s Management Board is responsible for ensuring the compliance of the Group’s

operations with prudential regulations, in which for the correct determination of capital ratios.

Our responsibility is to communicate in the auditor’s report whether the Group complies with applicable

prudential regulations, defined in separate provisions, and in particular whether the Group correctly

determined the capital ratios presented in note 50 Capital adequacy and leverage risk.

The purpose of the audit of the consolidated financial statements was not to express an opinion on the

Group’s compliance with applicable prudential regulations and therefore we do not express such an

opinion.

Based on our audit of the consolidated financial statements we would like to inform you that we have not

identified any breaches of applicable prudential regulations by the Group in the period from 1 January

2024 to 31 December 2024, defined by separate provisions, in particular with respect to the correctness

of the determination of capital ratios as at 31 December 2024 by the Group, which could have a significant

impact on the consolidated financial statements.

Statement about Provision of Non-Audit Services

According to our best knowledge and belief we declare that non-audit services that we have provided to

the Group comply with laws and regulations applicable in Poland and that we have not provided any non-

audit services that are prohibited pursuant to Article 5 (1) of the EU Regulation and Article 136 of the Act

Forvis Mazars Audyt Sp. z o.o.

on Statutory Auditors. Non-audit services that we provided to the Group during the audited period were

specified in note 52 Information on the entity authorised to audit the financial statements to the

consolidated financial statements.

Appointment of an Audit Firm

We were appointed to conduct the audit of the Group’s consolidated financial statements based on the

resolution of the Parent Undertaking’s Supervisory Board of 31 July 2020 and again based on the

resolution 9 December 2022. We have been auditing the consolidated financial statements of the Group

continuously, starting from the financial year ended 31 December 2020, i.e. for 5 consecutive years.

The key statutory auditor responsible for the audit that was the base of the present independent statutory

auditor’s report is Małgorzata Pek.

Acting on behalf of Forvis Mazars Audyt Sp. z o.o. with its registered office in Warsaw, ul. Piękna 18,

entered on the list of audit firms under the no. 186, on behalf of which the key statutory auditor audited the

consolidated financial statements.

Małgorzata Pek

Electronically signed on the Polish original

Key Statutory Auditor

No 13070

Warsaw, 11 April 2025