ESG Report

of Bank Millennium and

the Bank Millennium

Group for 2021

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Table of Contents

LETTER FROM THE CHAIRMAN OF THE MANAGEMENT BOARD ............................................. 5

1. BANK MILLENNIUM AND THE BANK MILLENNIUM GROUP ............................................. 7

1.1. PROFILE OF THE ORGANIZATION .................................................................... 7

1.1.1. SCALE OF OPERATIONS ............................................................................ 9

1.1.2. SHAREHOLDERS .................................................................................... 10

1.1.3. ECONOMIC PERFORMANCE ....................................................................... 10

1.2. MISSION AND VALUES ................................................................................ 11

1.3. BUSINESS MODEL AND THE VALUE CREATION MODEL ........................................... 13

1.4. ESG IS AN INTEGRAL PART OF THE NEW STRATEGY FOR 2022-2024 .......................... 17

1.5. DESCRIPTION OF SIGNIFICANT TYPES OF RISK IN THE ESG AREA .............................. 19

1.6. SELECTED AWARDS AND DISTINCTIONS ........................................................... 20

1.7. DEFINING THE CONTENT OF THE REPORT – DIALOGUE WITH STAKEHOLDERS ............... 22

2. ENVIRONMENT .............................................................................................. 27

2.1. ENVIRONMENTAL IMPACT MANAGEMENT .......................................................... 27

2.1.1. CLIMATE ISSUES IN THE BANK MILLENNIUM GROUP'S STRATEGY ............................ 28

2.1.2. ENVIRONMENTAL POLICY OF THE BANK MILLENNIUM GROUP ............................... 28

2.1.3. CLIMATE - KEY RISKS AND NEW OPPORTUNITIES .............................................. 29

2.2. REDUCTION OF THE ENVIRONMENTAL IMPACT OF THE BANK’S OPERATIONS ................ 29

2.2.1. REDUCTION OF RESOURCE CONSUMPTION ..................................................... 30

2.2.2. GREENHOUSE GAS EMISSIONS .................................................................... 46

2.2.3. ENVIRONMENTALLY-FRIENDLY PRODUCTS AND RESPONSIBLE FINANCING ................. 55

2.3. EU TAXONOMY ........................................................................................ 56

2.4. FULFILLING THE REPORTING REQUIREMENTS .................................................... 58

2.5. ENVIRONMENTAL EDUCATION ...................................................................... 58

3. SOCIETY ...................................................................................................... 61

BANKING INSPIRED BY PEOPLE

3.1.

INNOVATIVE SERVICES ............................................................................... 61

3.1.1. OFFER DESIGNED TO MEET CLIENTS’ NEEDS ................................................... 67

3.1.2. BANKING WITHOUT BARRIERS ................................................................... 68

3.1.3. SERVICE AND SUPPORT FOR CLIENTS IN THE COVID-19 PANDEMIC SECOND YEAR ........ 71

3.1.4. TOP QUALITY CUSTOMER SERVICE .............................................................. 72

3.1.5. CUSTOMER SERVICE STANDARDS ................................................................ 73

3.1.6. RECOGNIZING CLIENT EXPECTATIONS .......................................................... 73

3.1.7. COMPLAINTS MANAGEMENT ...................................................................... 74

3.1.8. CYBERSECURITY ................................................................................... 77

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

3.1.9. INITIATIVES TO ENHANCE CLIENTS’ FINANCIAL AWARENESS ................................... 78

3.2. RESPONSIBLE ADVERTISING AND SALES ........................................................... 80

3.2.1. RELIABLE MARKETING COMMUNICATION ....................................................... 80

3.2.2. TRANSPARENT INFORMATION ABOUT PRODUCTS AND SERVICES ............................ 81

3.2.3. ETHICAL STANDARDS IN CLIENT SERVICE ....................................................... 84

3.2.4. SETTLEMENTS AND OTHER SOLUTIONS FOR FOREIGN CURRENCY LOAN BORROWERS ... 86

RESPONSIBLE EMPLOYER

3.3.

HEADCOUNT STRUCTURE ........................................................................... 88

3.4. WORKING CONDITIONS .............................................................................. 91

3.4.1. HR POLICY .......................................................................................... 91

3.4.2. COMPENSATION POLICIES ........................................................................ 92

3.4.3. SIGNIFICANT RISKS RELATED TO THE EMPLOYEE AREA ....................................... 93

3.4.4. SUPPORTING DIVERSITY AND COUNTERACTING DISCRIMINATION ........................... 94

3.4.5. FREEDOM OF ASSOCIATION....................................................................... 97

3.4.6. EMPLOYEE APPRAISAL ............................................................................ 98

3.4.7. RECRUITMENT AND PROFESSIONAL DEVELOPMENT ........................................... 98

3.4.8. SOCIAL BENEFITS ................................................................................ 103

3.4.9. FRIENDLY WORKPLACE ......................................................................... 104

3.5. EMPLOYEE HEALTH AND SAFETY ................................................................. 106

3.5.1. MEASURES CONTINUED IN CONNECTION WITH THE COVID-19 PANDEMIC ................ 106

3.5.2. OHS STANDARDS ................................................................................. 106

BANK IN SOCIAL ENVIRONMENT

3.6.

SOCIAL ENVIRONMENT ............................................................................. 108

3.7.

COMMUNICATION WITH STAKEHOLDERS ........................................................ 108

3.8. SOCIALLY BENEFICIAL ACTIVITIES ................................................................ 110

3.8.1. EDUCATION PROGRAMS OF THE BANK MILLENNIUM FOUNDATION ........................ 111

3.8.2. CHARITABLE CAMPAIGNS AND EMPLOYEE VOLUNTEERISM ................................. 111

3.8.3. PATRONAGE OF CULTURE ...................................................................... 113

3.8.4. SUPPORTING EDUCATION ...................................................................... 114

3.8.5. SUPPORTING DIVERSITY ........................................................................ 114

4. GOVERNANCE .............................................................................................. 115

MANAGEMENT

4.1. APPLICATION OF CORPORATE GOVERNANCE PRINCIPLES ..................................... 115

4.2. GOVERNANCE STRUCTURE ........................................................................ 116

4.3. MANAGEMENT APPROACH TO SUSTAINABLE DEVELOPMENT .................................. 117

4.4. RISK MANAGEMENT ................................................................................ 121

4.5. ETHICAL STANDARDS AND HUMAN RIGHTS ..................................................... 121

4.6. THE BANK IN THE MARKET ENVIRONMENT ...................................................... 123

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

4.6.1. RELATIONS WITH THE CAPITAL MARKET ..................................................... 123

4.6.2. COOPERATION WITH TRADE ORGANIZATIONS ............................................... 125

4.6.3. BUSINESS PARTNERS ............................................................................ 125

4.7. TAX POLICY ......................................................................................... 128

CORPORATE SAFETY

4.8.

SAFETY OF CLIENT FUNDS ........................................................................ 128

4.8.1. SAFETY OF INFORMATION AND TRANSACTIONS ............................................. 129

4.8.2. PROTECTION OF PERSONAL DATA ............................................................. 130

4.8.3. FRAUD PREVENTION............................................................................. 131

4.8.4. ANTI-MONEY LAUNDERING AND COUNTERING TERRORISM FINANCING (AML/CTF) ..... 131

4.8.5. PREVENTING CONFLICTS OF INTERESTS ...................................................... 132

4.8.6. ANTI-CORRUPTION .............................................................................. 133

4.9. INTERNAL CONTROL SYSTEM ..................................................................... 134

4.9.1. COMPLIANCE ..................................................................................... 134

4.9.2. INTERNAL AUDIT ................................................................................. 135

5. ABOUT THE REPORT ...................................................................................... 136

5.1. APPROACH TO REPORTING ....................................................................... 136

5.2. ACCOUNTING ACT COMPLIANCE TABLE ......................................................... 137

5.3. GRI STANDARDS CONTENT INDEX ................................................................ 137

5.4. CONTACT DATA .................................................................................... 146

5.5. CERTIFICATION LETTER ........................................................................... 147

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

LETTER FROM THE CHAIRMAN OF THE MANAGEMENT BOARD

[GRI 102-14]

Ladies and Gentlemen,

The year 2021 was another unusual and difficult period in our business. Although the economic outlook

after the end of the first waves of the pandemic was good, and vaccines gave hope for the

normalization of life, the second half of the year brought inflation, economic uncertainties and...

new variants of the coronavirus. However, I close the year with a sense of fulfilment and satisfaction

with the effects we have achieved. This was possible thanks to the commitment and harmonious

cooperation of all employees of the Bank Millennium Group, whom I wholeheartedly thank for this.

In 2021, we achieved good operational and business results, while actively managing and mitigating

the different risks related to the banking activity. It was a year of high growth in retail lending, led

by record sales of new mortgage loans and a rebound in consumer loan sales. As befits a leader in

digital customer experience, the number of active digital customers exceeded 2.3 million (an increase

of 10% y/y) and mobile customers 1.9 million (an increase of 16% y/y). We increased our core revenues

(interest and commission revenues) and decreased operating costs. The quality of the loans portfolio

improved, which allowed a lower cost of credit risk. The financial loss in the amount of PLN 1.332

billion was caused by the creation of provisions for legal risk related to the portfolio of foreign

currency mortgage loans (excluding Euro Bank) in the amount of PLN 2.086 billion, additional costs

incurred with individual amicable settlements with FX mortgage borrowers and with legal costs.

Excluding these provisions and costs, the Group's net profit would amount to PLN 1.097 billion net.

Undoubtedly, this year was important to speed up solving the issue of Swiss franc loans. As a result

of signing settlements with our customers, the number of active FX mortgage loans decreased by

8,449 in 2021 compared to over 57,800 active loan agreements at the end of 2020. The number of

amicable settlements was higher than the influx of new court cases.

The event of the year for the Bank was undoubtedly the announcement of our new Strategy for 2022-

2024 entitled "Inspired by people". The document is the result of the work of many teams and derives

directly from the knowledge and inspiration of employees. The strategy assumes smart growth, solid

business development and further technological progress. We want to maintain high operational

efficiency and strengthen customer acquisition based on the growth engines developed in recent years

– the sales of personal accounts, cash and mortgage loans, and selective growth in corporate. The key

values of our activities remain unchanged. These are customer centricity, offering high quality of

service, continuous innovation, accelerated digitalization, with the mobile app at its core, and a

commitment to society and the environment.

The Bank is a signatory to the partnership for the implementation of the UN Sustainable Development

Goals, which sets the direction for our activities. For 11 years, the Bank has been part of the index

of the Warsaw Stock Exchange, which brings together companies with the highest standards of

sustainable development. Bank Millennium Group does not provide financing for new coal mines and

investments in coal-based energy, with the exception of new investments related to the reduction of

pollution. A few years ago, the Bank decided to significantly reduce the exposures financing the coal

industry. As a result, the portfolio's exposures involved in coal and hydrocarbon mining are close to

zero. For the coming years, we have set ourselves specific climate goals. The Bank’s plans are to

reduce its own greenhouse gas emissions by 50% in 2022 compared to 2020 and to achieve climate

neutrality in terms of its own emissions by 2027. It will also actively support corporate clients in their

decarbonization activities, in developing their investment plans related to the package of the

European funds, especially green finance.

Following a long period of only virtual activity of the Bank Millennium Foundation due to the

pandemic, in 2021 its activity returned to real life. We continued the employee volunteering project

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

#słuchaMYwspieraMY and the educational program "Financial ABCs". We conducted 200 workshops in

kindergartens throughout Poland and over 2 600 people in a difficult life situation received help from

us. After the very popular 18th edition of the Millennium Docs Against Gravity festival, we have

extended our cooperation with its organizer for another three years.

What lies ahead? In accordance with the new strategy for the years 2022-2024, the Bank plans to meet

the growing, post-pandemic expectations of customers and shareholders. By 2024, we intend to

achieve PLN 2 billion of net profit (excluding costs related to the portfolio of foreign currency

mortgage loans) and ROE (without the above-mentioned costs) at the level of approx. 14%. Ambitious

efficiencies and smart business growth will be made possible by further increasing the number of

active customers to over 3 million in 2024 and improving a cost-effective, scalable operating platform

allowing to achieve cost/income ratio of less than 37% in 2024.

We expect that in 2022 the Polish economy will remain on the positive path, although economic

growth will slow down when compared to 2021. The economy will continue to be supported by

household consumption, driven by the expected further decline in the unemployment rate and wage

growth. However, high inflation and interest rate hikes will limit the dynamics of consumer spending.

2022 may also be a year of rebuilding investments, especially if European funds start to flow into

Poland in a wider stream. The pandemic remains a factor of uncertainty, despite the fact that in 2021

the economy largely adapted to operate in its conditions. High inflation remains a risk, which may

force higher than expected interest rate increases, which could imply a stronger slowdown of the

economy.

Looking ahead to the coming year, I am optimistic. Bank Millennium is fully prepared for the

challenges of the future and poised to implement ambitious, strategic goals. I hope that working on

them will be a source of satisfaction for every employee. I cordially invite you to read the report.

Joao Bras Jorge

Chairman of the Management Board of Bank Millennium

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

1.1. PROFILE OF THE ORGANIZATION

[GRI 102-1] Bank Millennium is a modern nationwide bank offering services to its clients in all of the

market segments through its branch network, individual advisors and electronic banking. The Bank

was established in 1989 as one of the first commercial banks in Poland. Today, it is the 7th largest

commercial bank in Poland measured by assets.

[GRI 102-2] It offers services to individual clients (in

the retail, Prestige and Private Banking segments), micro businesses and small, medium and large

enterprises in the Corporate Banking segment. By blending the most sophisticated technologies and

the best banking traditions Bank Millennium successfully competes in all of the segments of the

financial market. The Bank adds its international practice in finance contributed by Banco Comercial

Português (Millennium bcp) – one of the largest commercial banks in Portugal and Bank Millennium’s

strategic shareholder - to its many years of familiarity with the Polish market. The acquisition of Euro

Bank in 2019 was a landmark decision that increased the magnitude of its operations and contributed

to its growth.

Innovation is one of the most important values in Bank Millennium’s organizational culture. From its

inception the Bank has been a trendsetter in the Polish banking industry, e.g. it was the first bank

listed on the Warsaw Stock Exchange and it issued the first payment card on the Polish market. Today,

it is a market leader in innovation defined as new technology solutions and process-related facilities.

Invariably, one of its top priorities when introducing further innovation is to make clients’ daily lives

easier by offering them convenient and intuitive access to financial and non-financial services. The

key element in all of the changes introduced by the Bank is the care it shows for providing the very

best user experience, grasping the unique needs of various client groups and offering them full access

to financial services.

Bank Millennium and its subsidiaries constitute the Bank Millennium Group – one of the most

sophisticated and growing financial groups in Poland. In addition to the Bank, its most important

1. BANK MILLENNIUM

AND THE BANK

MILLENNIUM GROUP

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

companies in 2021 were Millennium Leasing (leasing activity), Millennium Dom Maklerski (brokerage

activity), Millennium TFI (mutual funds) and Millennium Bank Hipoteczny.

[GRI 102-10] In connection

with the permit to launch operations within the meaning of Article 36 sec. 1 of the Banking Law Act

issued by the Polish Financial Supervision Authority, Millennium Bank Hipoteczny Spółka Akcyjna

commenced operations on 14 June 2021. Its primary goal is to secure long-term financing by issuing

covered bonds whose underlying instruments are the accounts receivable by virtue of the mortgage

loans transferred by Bank Millennium S.A. Covered bonds are one of the safest financial instruments

in the world. Transferring these accounts receivable makes it possible to finance mortgage loans using

long-term covered bonds by successively decreasing the mismatch between the maturities of assets

and liabilities.

On 10 May 2021 the Management Boards of Bank Millennium and Millennium Dom Maklerski made the

decision on the planned demerger of Millennium Dom Maklerski under which the Bank is the acquiring

entity. The transfer of brokerage activity in its entirety to the Bank and the integration of brokerage

services under a single entity is slated to take place in mid-2022. This ownership change will not

require the clients of Dom Maklerski or the clients of Bank Millennium to take any additional actions.

All agreements will remain unchanged.

Millennium Goodie Spółka z o.o. has been operating an innovative smart shopping platform based on

sophisticated technology in collaboration with the Bank since 2016.

These companies’ offering complements the products and services offered by the Bank. The Bank

Millennium Foundation is also part of the Group. For years it has been supporting financial education

and employee volunteerism projects.

[GRI 102-4] The Bank and its Subsidiaries operate in the Republic of Poland. [GRI 102-3] The Bank's Head

Office is located in Warsaw while some of its head office functions are also performed in Gdańsk and

Wrocław.

[GRI 102-5] Organizational chart of the Bank Millennium Group (as at 31 December 2021)

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

1.1.1. SCALE OF OPERATIONS

[GRI 102-6] The Bank operates throughout Poland and has no branches outside of its borders. Total

assets amount to PLN 103.9 billion. The Bank Millennium Group serves 2.7 million active retail clients.

As might be expected of a client experience leader in electronic banking, the number of active digital

clients exceeded 2.3 million (up 10% y/y) and mobile clients 1.9 million (up 16% y/y). At the end of

2021, the Bank had 655 branches, including 440 own branches and 215 outlets in the franchise model,

and 480 ATMs.

Share in key market segments

[GRI 102-7] Scale

of the Bank

Millennium

Group's business

activity

2021 2020 2019 2018 2017

Number of active

retail clients

(thous.)

2,694 2,633 2,571 1,838 1,635

Number of active

corporate clients

(thous.)

8.3 7.8 7.7 7.4 6.9

Number of own

and franchise

branches

655 702 830 361 355

Number of ATMs 480 479 498 487 483

Number of

employees

(persons)

7,079 7,645 8,615 6,270 5,945

Number of Bank’s

suppliers

6,639 6,679 6,352 5,012 5,153

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

1.1.2. SHAREHOLDERS

[GRI 102-5] Bank Millennium is a joint stock company that has been listed on the Warsaw Stock Exchange

since 1992. Presently, the Bank is a member of the WIG, WIG 30, mWIG 40, WIG Banks and the

WIG-ESG indices.

Bank Millennium’s strategic shareholder is Banco Comercial Português, the largest private bank in

Portugal, which holds a 50.1% stake in Bank Millennium. Polish pension funds are significant

shareholders and they include Fundusz Emerytalny Nationale-Nederlanden, Fundusz Emerytalny PZU

Złota Jesień and Fundusz Emerytalny Aviva, which hold more than 5% of the share capital.

[GRI 102-10] Bank Millennium’s shareholder structure*

*as of 31.12.2021 and 31.12.2020

1.1.3. ECONOMIC PERFORMANCE

[GRI 103-1, GRI 103-2, GRI 103-3] The Bank Millennium Group achieves its economic goals striving to

balance the needs of the key Shareholders, in accordance with its growth strategy, taking into account

the principles declared in the Code of Ethics.

[GRI 201-1]

Selected

economic results

(PLN million)

GROUP BANK

2021 2020 2021 2020

Operating income 3,558.1 3,577.8 3,400.7 3,421.5

Operating

expenses*

(1,642.3) (1,752.8) (1,573.7) (1,693.5)

Cost/income

ratio

46.2% 49.0% 46.3% 49.50%

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

[GRI 201-1]

Selected

economic results

(PLN million)

GROUP BANK

2021 2020 2021 2020

Impairment

provisions and

other cost of risk

(299.0) (621.3) (257.2) (541.5)

FX legal risk

related provisions

(2,305.2) (713.6) (2,305.2) (713.6)

Banking tax (312.6) (279.1) (312.6) (279.1)

Corporate income

tax (CIT)

(330.9) (188.1) (309.5) (175.1)

Net loans and

borrowings to

clients

78,603.3 73,639.3 78,237.6 73,052.4

Client deposits 91,447.5 81,510.5 91,672.3 81,832.5

Common Equity

Tier 1 capital

(CET1=T1)

14.0% 16.5% 14.0% 16.2%

Total Capital

Ratio (TCR)

17.1% 19.5% 17.2% 19.2%

Reported net

income

(1,332) 22.8 (1,357.5) 18.6

Adjusted net

income**

1,110.0 768.1 - -

Reported Return

on Equity (ROE)

(16.3%) 0.2% - -

Adjusted Return

on Equity (ROE)**

13.6 7.8 - -

Distribution of

profit

Dividend 0*** 0

Capital 100%*** 100%

* without impairment charges for financial and non-financial assets

** adjusted net income and ROE - excluding extraordinary items

*** proposal of the Bank's Management Board before the Shareholder Meeting

1.2. MISSION AND VALUES

[GRI 102-16] The Bank’s mission is to support its clients in the achievement of financial success now

and in the future. The Bank builds its competitive advantage on values forming the basis for running

its business.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The Bank Millennium Group’s Values

We build relationships based on trust

We can rely on one another, and in the course of developing and pursuing ambitious goals, we keep

ethics and our associates in mind. Responsibility, respect, support and understanding cement our

community and help us strengthen our leadership position among the best banks in Poland. We build

trust in the Bank by serving as its ambassadors.

Quality and innovation are our passion

We set the standards of perfection and create trends in banking. Openness, enthusiasm, searching for

the best solutions and breaking barriers are embedded in our thinking, actions, products, services and

processes as well as in our relations with the outside world and within the organization.

We develop employees and we promote cooperation

In our organizational culture, goals and successes are achieved through mutual inspiration, exchange

of competence and experience. We discover and reward the people who through their actions

motivate others to be their very best.

We always aim higher

When others achieve the peak of their capabilities, we want more. We develop and increase the

employees’ and the teams’ competences through training and certification programs. We carefully

observe our surroundings, we perfect and evolve, and we actively respond to the challenges of the

future.

The Leadership Code devised by a group of managers is in force in the Bank Millennium Group. It

translates values into the behaviour expected of leaders in their day-to-day work. It defines

specifically what a given value entails, what behaviour supports that value and what constitutes a

violation.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

1.3. BUSINESS MODEL AND THE VALUE CREATION MODEL

Business model

Bank Millennium operates according to a business model predicated on five pillars:

• CUSTOMER FOCUS: We are the most customer-focused bank that is constantly developing. We

want to be the most personalized bank operating on a mass scale.

• DIGITALITY AND NEW TECHNOLOGIES: We are the leader in digital banking by offering high

quality services blended with an extensive reach.

• ORGANIC GROWTH CAPACITY: we are one of the fastest growing banks in terms of soliciting

clients for whom we are their primary relationship.

• COST EFFECTIVENESS: We have the leading cost effective business model built using the most

sophisticated technology that is flexible when it comes to changes and the Bank’s growing

size.

• FLEXIBILITY IN RESPONDING TO CHANGES: We have a flexible operating model, an

organizational culture that facilitates rapid response and digital and data analysis

competences.

[GRI 102-16] The firm’s values form the foundation of our business model: building relations based on

trust, a passion for quality and innovation, employee development and promoting collaboration and

the ever constant ambition to aim higher.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Value creation model

The Bank Millennium Group’s capital poises it to grow its business as it simultaneously creates value

for its Stakeholders.

The Bank Millennium Group’s capital...

FINANCIAL CAPITAL

Liabilities

Equity

Assets

PLN 97.2 bn Group total liabilities

PLN 6.7 bn Group total equity

PLN 103.9 bn Group total assets

HUMAN CAPITAL

7,079 – number of Group employees

Friendly workplace, focus on

employee development, attention to

diversity

38.9

average number of training hours

per Group employee per year

Mandatory training on the Code of Ethics

Winners of numerous competitions in the area of service

quality

Modern infrastructure, environmentally friendly

solutions in the headquarters buildings

ORGANIZATIONAL CAPITAL

Focus on growth and innovation, with full

understanding of client needs

Culture of rapidly responding to

change (agility), sophisticated

infrastructure and IT systems,

digitization and optimization of

processes making it possible to

develop innovative products and offer

high quality services, organization’s

cost effectiveness.

Active development of open banking services

46.2% Group cost/income ratio

Reducing resource consumption and the carbon footprint

of buildings

INTELLECTUAL CAPITAL

New business strategy for 2022-2024 - ESG issues are

part of it

Investments in modern technological

solutions and innovations, the bulk of IT

The Millenet internet banking system and the mobile

application have been designed with users in mind and

jointly with them in the spirit of Human-Centred Design

Cooperation with Universities

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

development is in-house, internal start-

up goodie, internal UX Design time

Extensive internal training program

SOCIAL CAPITAL

94% retail clients satisfied with the Bank's services

Quality of relations with the

environment, Bank reputation,

transaction safety, enhancing the

society’s financial awareness.

Nearly PLN 1.6 million provided by Bank Millennium

Group for donations and sponsorships in 2021

Cybersecurity education activities for clients

Financial education programs of the Bank Millennium

Foundation and support of local communities as part

of employee volunteerism

… They support business development through:

Process optimization and

digitization

Marketing products and banking

services making everyday life

easier

Facilitating access to non-

banking services

Designing the goodie smart

shopping platform

Creating a work culture to

facilitate rapid response to

changes

Organic growth and synergies after

the merger with Euro Bank

... and create value for stakeholders:

CLIENTS

Banking for all – no

physical, infrastructural

and digital obstacles

 Constant development of mobile and internet

banking services

 70% of own branches are accessible to

persons with disabilities

 100% of the ATMs are accessible to persons

with disabilities

 “Wrocław Without Barriers” award for Bank

Millennium

 Golden CSR Leaf of the Polityka weekly - an

award for companies with the highest

corporate social responsibility standards

Non-banking digital

functionalities,

e.g. e-administration

 Over 1 million clients with access to

e-administration

 Mobile app as a hub for managing daily

affairs, not just finances

High quality of service

 51 - NPS for retail customers



The Best Bank in Poland for 2021 according to

Global Finance magazine

 In the last edition of the "Newsweek's Friendly

Bank" ranking, Bank Millennium took first

place in the main category “Every One’s

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Bank” and second place in the category

“Remote Banking”.

EMPLOYEES

Employee turnover ratio

 4% – employee turnover ratio

Education and

development

 Millennium Campus - a program to develop

knowledge and skills with the objective of

supporting the growth of innovation across

the organization. The offer to participate in

this program is addressed to all of the Bank’s

employees.

Respect for diversity

 The Bank was included in the "European

Diversity Leaders 2022" ranking. In the latest

Financial Times list, 850 employers were

selected from among 15,000 European

companies as supporters and promoters of

diversity in their organizations.

SUPPLIERS

Ethical cooperation

 83% of all invoices paid within a range up to

30 days

Responsibility in the

supply chain



100% of newly-executed contracts have a

clause obligating suppliers to apply the

principles of the Bank Millennium Group’s

Code of Ethics

SOCIETY

Employee support fund

 PLN 1,000,000 in Special Bank Millennium

Group Employee Support Fund in case of

COVID-19 infection (contribution of the Bank's

funds) - fund established in 2020, the money

from the fund are made available on an

ongoing basis also in 2021

Financial education

 In November and December 2021, as part of

the seventh edition of the “Financial ABCs”

project, the Bank Millennium Foundation

conducted 200 workshops in 54

kindergartens.

 Over 5,000 preschoolers aged 3 to 6

participated in these workshops.

Promoting Culture



Bank Millennium has been a sponsor of the

Millennium Docs Against Gravity documentary

film festival for 16 years and has signed an

agreement to extend its cooperation for

2022-2024.

 In September 2021, the 18th edition of the

Millennium Docs Against Gravity festival took

place, for the second time in the hybrid

INVESTORS

Profitability

 13.6 - return on equity (ROE) (adjusted for

significant extraordinary events)

Solid capital base

 17.1% - TCR (Total Capital Ratio)

High standards of ESG

management



Member of the WIG-ESG index at the Warsaw

Stock Exchange, adherence to the Best

Practices for WSE Listed Companies and

Corporate Governance Principles

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

formula. The 2021 hybrid edition of the

festival attracted a total audience of

134,000.

 The Golden Culture Atlas Award for

patronage over the Sacrum Profanum festival

ENVIRONMENT

Minimizing the

environmental impact

 Greenhouse gas reduction targets set out in

the new business strategy

 Reducing resource consumption and the

carbon footprint of occupied buildings

 Since implementing the Mobile

Authorization, clients have effected

approximately 1.6 million transactions,

which made it possible to abandon hardcopy

printouts and save 32,000 reams of paper

 New head office in Wrocław, meeting high

environmental standards

 Model green branch in Gdańsk

1.4. ESG IS AN INTEGRAL PART OF THE NEW STRATEGY FOR

2022-2024

[GRI 102-15] ESG (Environmental, Social, Governance) issues have for years been an integral part of the

Bank Millennium Group’s business strategy. In connection with the pandemic, 2021 has been treated

as a transition year before the new strategy comes into effect; however, the topics of sustainable

development and corporate social responsibility invariably continue to be part of the Group’s business

strategy. The approach to managing sustainable development is discussed extensively in the Corporate

Governance section of this report.

ESG is also included in the Group’s new strategy for 2022-2024, which was announced in December

2021. Of crucial significance for Bank Millennium is not only to attain the goals set in the strategy,

but also to take the proper path towards them, based on our commitment to society and the natural

environment, in line with stringent standards of quality and ethics in the sales process and the services

offered. The new strategy entitled “Bank Millennium. Inspired by people.” highlights the importance

attached to the inspirations provided by employees, clients and the community in which the Bank

functions.

In the new strategy, the Bank has for the first time defined its goals pertaining to climate protection.

The Bank is well positioned to reduce its own greenhouse gas emissions by 50% in 2022 compared to

2020. Climate neutrality in terms of the Bank’s own emissions is planned to be achieved by 2027 while

full climate neutrality is in plans by 2050. The Bank Millennium Group will also actively support clients

as they decarbonise and provide PLN 2 billion of financing for sustainable and transformational

projects for the clients of the Bank and of the Bank’s Group over the next 3 years. For years the Bank

has been involved in environmental activities, also to finance energy savings investments. These

topics are extensively discussed in the “Environment” section of this report.

As an institution inspired by people and their needs, in its new strategy the Bank aims to be an

employer of first choice, ensure that services are available to all its clients and listen to and support

the local community. As a responsible member of society the Bank will continue to offer the Bank

Millennium Foundation’s financial education program targeting children and their parents, cultivating

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

its more than thirty-year-old tradition of being a patron of culture and supporting the social initiatives

pursued by the Bank Millennium Group’s employees to benefit their local environment.

In management processes the Bank incessantly cares about observing high ethical standards as well

as safety and transparency of relations with its clients. The Bank constantly develops its risk

management processes while giving consideration to the rapidly evolving challenges regarding climate

risks. In the Risk Management Strategy for 2022-2024 approved by the Bank’s Supervisory Board, the

Risk Appetite framework was defined for selected ESG risk factors: level of own emissions, diversity

and social initiatives.

The aspiration of the Bank Millennium Group is to continue to achieve ambitious targets in the coming

years

Clients

• Customer centric service focused on superb quality, further simplification of client-facing

processes and communication, best-in-class digital and omnichannel experience

• Banking without barriers and accessible for people with disabilities

Employees

• Improved EVP (Employee Value Proposition), including the development of a hybrid work

model, talent management based on career paths that create new opportunities and top

quality working conditions

• Self-development and training tailored to employees' needs

• Regular employee opinion surveys

Society

• Financial education for children and their parents

• Cultural initiatives as a 30+ year tradition

• Supporting employees' social initiatives for the benefit of their local community

Ethical approach to business

• We regularly revise the Code of Ethics and compliance assessment

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Measures to combat financial crime

• We take measures to increase the transparency and credibility of business relationships with

clients

• We implement robust AML IT system

Consideration of climate and environmental risks

• We introduce sustainability metrics in Risk Appetite Statements

• We incorporate climate risk assessment into risk policy

• We conduct stress tests

The strategy for 2022-24 is available at the following address:

https://www.bankmillennium.pl/en/about-the-bank/investor-relations

1.5. DESCRIPTION OF SIGNIFICANT TYPES OF RISK IN THE ESG AREA

[GRI 102-15] The Bank has described significant risks related to its activity that may exert an

unfavourable impact on social, employee, natural environmental issues and respecting human rights

and combating corruption. In the social area, Bank Millennium manages various types of risk; however,

the overriding risk for the Bank is the risk related to the safety of its clients’ funds. It is a function of

other types of risk, including, among others, the reputation risk considered from the point of view of

the Bank and the Bank Millennium S.A. Group, as well as from the point of view of the entire banking

sector. Additionally, the Bank distinguishes risk resulting from its cooperation with clients (including

credit risk) and contractors.

With regard to the risk related to client relations, the Bank examines the legal aspects of the

agreements it has signed, the risk of incorrectly designing products and services and the risk of making

the optimum selection of products to suit clients’ needs and possibilities. At the same time, the Bank

analyzes new legal regulations, the opinions pronounced by UOKiK (Office of Competition and

Consumer Protection) and other authorities and is focused on delivering the best quality products and

services to its clients, as the Bank’s high ratings in various rankings amply attest.

In terms of the risk related to incorrect employment and work safety practices, the Bank minimizes

the risk of high employee turnover by embracing the pertinent policies (HR, compensation and

diversity, among others) and offering high working standards.

The risk related to the issue of failing to respect human rights and combat corruption refers to the

possibility of instances of human rights violations and corruption occurring in the organization. This

causes risk of legal, administrative, financial liability and loss of reputation. The Bank’s Group

prevents this risk by observing the provisions of the “Diversity Policy” and obligating its employees

and business partners to adhere to the Bank Millennium Group’s Code of Ethics in which these issues

are regulated and by offering the ability to report violations anonymously in these areas.

The risk of impact on the natural environment is associated mainly with the negative impact of the

Group on the environment, both through its own operating activity and through projects and

investments financed by the Bank. The Group prevents this risk by submitting to legal regulations,

monitoring its own environmental impact and implementing environmentally-friendly actions and

observing the “Environmental Policy of the Bank Millennium Group” and project financing rules.

Another critical risk, to which the Bank is exposed, is the risk of financial loss associated with a failure

of the customers to repay liabilities. If the volume of lost loans becomes high, the Bank could suffer

financial losses. In the same case, the consequence and the risk at the customer’s side may be the

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

loss of credit capacity (unfavourable entries in registers such as BIK), loss of financial balance of a

household and the Bank launching a court procedure aimed at enforcing repayment.

A detailed description of the management of the foregoing types of risk has been set forth in the

various sections of the report pertaining to relations with clients, employees, business partners and

communities and to respecting human rights, preventing corruption and managing the natural

environmental impact.

1.6. SELECTED AWARDS AND DISTINCTIONS

Bank Millennium as the Best Bank in Poland for 2021 according to Global Finance magazine

In the Best Bank Awards contest held by the renowned Global Finance Magazine Bank Millennium was

recognized as the Best Bank in Poland for 2021. The winners were selected by the Global Finance

editors after extensive consultations with CFOs, bankers, banking consultants and analysts from across

the world.

Bank Millennium as the best digital bank according to Global Finance magazine

Bank Millennium was also awarded The Best Consumer Digital Bank in Poland for 2021 in the World's

Best Digital Banks competition organized by the renowned Global Finance magazine.

Golden Banker 2021 - Bank Millennium with the best mortgage loan

• 1st place in the Mortgage Loan category,

• 2nd place in the Socially Sensitive Bank category,

• 3rd place in the Best Multichannel Service Quality category.

2nd place among the best employers in banking and financial services in Forbes and Statista

ranking

Poland’s Best Employers 2021 is a list of 300 companies doing business in Poland, whose achievements

in the field of HR have been recognized with the title of the best employer. In the banks and financial

services category Bank Millennium came second. The ranking was prepared and published by Forbes

magazine, with Statista acting as the substantive partner of the project.

Best Bank 2021

Bank Millennium took second place in the "Best Bank 2021" competition in the small and medium-sized

commercial banks category. The competition was organized by Gazeta Bankowa. The best commercial

and cooperative banks were selected based on detailed surveys that included financial, sales and

service ratios, and innovation and security information.

Golden CSR Leaf

As in 2020, the Bank was awarded the Golden CSR Leaf of the Polityka weekly, which is given to

companies whose efforts in the area of corporate social responsibility and sustainable development

are rated the highest. In previous years Bank Millennium won the Silver CSR Leaf as many as five

times.

Celent Model Bank in Open Banking

Bank Millennium won the Celent Model Bank award for its open banking services. The Bank’s solutions

were assessed as an excellent example of good practices in project execution, exerting a significant

impact on its business performance and the whole industry.

Bank Millennium as Innovator 2021 according to Global Finance magazine

In a survey conducted by Global Finance magazine, Bank Millennium was recognized as a 2021

Outstanding Innovator in Retail Banking for "Bank Millennium Open Banking Services" (Special

Honours).

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Bank Millennium as Culture Atlas

The Bank was awarded with the Culture Atlas title already for the 6th time by the Kraków Festival

Office for its patronage over the Sacrum Profanum festival.

Institution of the Year 2021 - Millennium as the best bank in mortgage services and winner in

most other categories

In the Institution of the Year ranking, the Bank was recognized as the best in mortgage servicing. It

was also ranked among the winners in the categories: Best Bank in Poland, Best Service in a Branch,

Best Service via Remote Channels, Best Online Banking, Best Mobile Application and Best Account

Opening Process. 11 branches were included in the list of the best banking institutions in Poland.

Projects executed by the Bank Millennium Foundation were recognized with a distinction in the

Corporate Social Responsibility category.

Contact Centre teams are the winners in Golden Handset and Telemarketer of the Year contests

The competition for the best Customer Care projects in Poland is organized by the Direct Marketing

Association.

Banking Stars - 3rd place in the "Customer Relationship Star" category

The Bank was among the banks distinguished in the "Banking Stars" ranking organized by "Dziennik

Gazeta Prawna" and PwC. In the "Customer Relationship Star" category, judged by bank clients, Bank

Millennium took third place.

Bank Millennium third in TOP 200 Best Polish Brands ranking

In the TOP 200 Best Polish Brands ranking of the Forbes magazine, the Bank was placed on a high,

third position (the highest positioned bank in the ranking). The TOP 200 Best Polish Brands ranking

shows the position and value of brands from the perspective of their strength in the minds of

customers and their role in generating revenue.

Victory in the latest edition of the “Newsweek’s Friendly Bank" ranking

1st place in the "Every One’s Bank" category

2nd place in the "Remote Banking" category

Bank Millennium is the winner of the latest edition of the "Newsweek's Friendly Bank" ranking. The

Bank ranked in the top in all aspects of services, especially in mobile banking. It was this area, highly

scored in both rankings, that determined the winners in the jubilee edition of the competition.

Bank Millennium in the "European Diversity Leaders 2022" ranking

In the latest Financial Times list, 850 employers were selected from among 15 thousand companies

as supporters and promoters of diversity in their organizations. The ranking was based on feedback

from 100 thousand employees and human resources and recruitment experts. The research firm

Statista is a substantive partner of the project.

My Business account is number one for microbusinesses

In Bankier's ranking, out of 11 banks, it was Bank Millennium's business account that came in first. My

Business account is a modern, multifunctional tool for managing the finances in small businesses.

Bank Millennium on the podium in the developers ranking

For the fifteenth time developers associated in the Polish Association of Developers evaluated banks

in terms of cooperation in financing and servicing residential development investments - Bank

Millennium was on the podium, taking third place.

Bank Millennium one of the winners of the Wrocław Without Barriers plebiscite in the Corporate

Social Responsibility category

The certificate was granted for the facilities making it easier to use digital banking and for the

implementation of architectural adjustments for people with disabilities and for conducting personnel

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

training on how to service people with special needs. The organizers also appreciated the Bank’s

efforts to build a socially responsible brand.

1.7. DEFINING THE CONTENT OF THE REPORT – DIALOGUE WITH

STAKEHOLDERS

[GRI 102-40; 102-42; 102-44; 102-46; 102-47] The process of defining the report’s contents preceded the

writing of the report. It consisted of identifying, prioritizing and validating the key aspects of the

operations of the Bank Millennium Group in the following areas: economic, business, environmental,

employee, social and ethical / corporate governance.

39 reported aspects aligned to the Bank Millennium Group’s operations have been identified based on

the topical scope of the GRI Standards and sustainable development practices and trends in the

financial industry. These aspects are listed below.

ECONOMIC AREA

• Financial performance (income, costs),

• Incorporating ESG-related issues in the Bank’s business strategy,

• The number of clients in the respective segments,

• The Bank’s asset value,

• Managing taxes and the payment of taxes.

BUSINESS AREA

• Innovation and the development of new technologies,

• Development of electronic banking channels and the mobile application,

• Ensuring IT and technical safety of the banking system / entrusted funds,

• Access to products and services, customizing them to the needs of disabled, older digitally-

excluded persons,

• Environmentally-friendly products and responsible financing,

• Protection of client privacy, measures to prevent data leaks,

• Ethical approach and dialogue with clients,

• Reliable marketing communication, ethical marketing and sales,

• Transparent information about products and services,

• Solutions for holders of mortgage loans,

• Compliance with the law and regulations (including the usage of products and services).

ENVIRONMENTAL AREA

• Raw materials and materials used by the firm and their recycling and re-usage, minimizing

the production of waste,

• Energy consumption, methods of reducing energy consumption,

• Water use and consumption, re-usage of water, information about sewage,

• Impact on biological diversity,

• Greenhouse gas emissions and methods of reducing them,

• Business development risks and opportunities stemming from climate change,

• Compliance with environmental regulations, preventing fraud, violation of the law and

regulations pertaining to environmental protection,

• Vendor assessment related to the fulfilment of environmental criteria,

• Environmental policy in terms of financing,

• Environmental education.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

EMPLOYEE AREA

• Headcount, including the number of new employees, turnover, employee benefits, return to

work after parental leave,

• Creating space for employee development (training and education, supporting development),

• Approach to managing employee health and safety,

• Working conditions,

• Freedom of association and conducting collective disputes.

SOCIAL AREA

• The actions taken by the Bank Millennium Group – and the Bank Millennium Foundation – to

benefit society, and actions to benefit local communities,

• Employee volunteerism,

• Sponsorship activities.

AREA OF ETHICS / CORPORATE GOVERNANCE

• Activities taken to eliminate instances of corruptions,

• Diversity and equal opportunity in access to positions and remuneration,

• Counteracting discrimination,

• Observing human rights, training employees about human rights,

• Vendor assessment related to employee practices, social issues and respecting human rights.

These aspects were prioritized through two complementary processes: review of the internal

perspective and review of the expectations of external stakeholders.

The internal perspective was defined by the male and female representatives of the staff and

management of the Bank Millennium Group by using an anonymous web-based questionnaire. This

research was conducted from 25 October to 5 November 2021. In total, 258 persons took part in this

research.

The research into the expectations of external stakeholders was conducted in the form of a dialogue

meeting held remotely on 17 November 2021 and also in the form of remote interviews conducted in

October and November 2021. When selecting the groups of stakeholders included in this process, the

stakeholder matrix prepared for ESG reporting purposes in 2021 was used as the basis. The design of

the matrix has been described in part 3.6 (“Social environment”) of this report.

The dialogue session was held on the basis of international Standard AA1000SES (AccountAbility).

During this session the male and female representatives of the most important stakeholder groups

had the opportunity to express freely any types of expectations they had in terms of reporting the

Bank Millennium Group’s non-financial issues – this purpose was served by discussion in sub-groups

moderated by an external advisory firm. In turn, through individual work using an anonymous web-

based questionnaire, the male and female meeting participants could assess from their own

perspective the importance of each one of the 39 aspects of the company’s operation as presented,

and put forward additional topics that in their opinion should be incorporated in the report. The male

and female representatives of the following groups of stakeholders took part in the session:

• Vendors / business partners

• Media

• Environment

• Individual clients

• Corporate clients

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

• Cultural institutions

• Institutional investors

• Business organizations

• Public institutions

• Auditors

• Universities / students

• International organizations

• NGOs

• Sectoral organizations

In-depth interviews with selected stakeholders (not participating in the session) were also conducted

by an external advisory firm. They were conducted with the male and female representatives of the

following groups of stakeholders:

• Corporate clients

• Institutional investors

• International organizations

• Non-governmental organizations

• Analysts

• Cultural institutions

• Business organizations

• Auditors

• Vendors / business partners

• Sectoral organizations

In total, 35 people took part in the dialogue meeting and the in-depth interviews.

Male and female employees, the management and external stakeholders advanced the following

additional topics, which they would like to have discussed in this report:

 method of managing ESG and compliance/AML risks

 method of aligning the company to new regulations

 environmental policies based on standards

 goals and directions of ESG activities taken by vendors and other business partners

 education of the market and partners in the supply chain in terms of ESG and non-financial

reporting

 allocation of funds in the Group to actions related to work organization in the head office and

in centres / field branches

 incorporation of social factors and factors related to ethics / corporate governance in lending

policy

 communication and dialogue with employees, including issues related to sustainable

development

 actions taken by the Bank to facilitate and/or mould environmentally-friendly behaviour

among male and female employees

 climate-related goals

 whistleblowing on suspected or observed irregularities

 extra judicial dispute adjudication, e.g. through arbitration

Moreover, during the dialogue session many expectations were put forward in respect of the conduct

of the Bank Millennium Group in the environmental, social and corporate governance areas as well as

on the Group’s non-financial reporting process and its communication. The firm responded in writing

to these expectations – in individual e-mail correspondence and it also strove to react to these issues

in this report.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Material reporting topics

The material reporting topics presented below were selected by taking into consideration the results

of all the processes described. Additionally, non-financial reporting trends, TCFD guidelines on

reporting climate-related issues and regulations of the accounting act were taken into consideration.

Following an analysis of relevant topics, the Bank decided to describe some aspects in greater detail

in the report (presenting both the management approach and performance data), despite the lower

rating given by stakeholders in the survey. This includes, among other things, managing taxes,

materials and raw materials used, water consumption and greenhouse gas emissions.

Map of material topics

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and the Bank Millennium Group for 2021

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

2.1. ENVIRONMENTAL IMPACT MANAGEMENT

[GRI 103-1, 103-2, 103-3] Bank Millennium is guided by the United Nations Sustainable Development

Goals, among which climate protection is one of the key issues. Environmental and climate protection

initiatives have for years been part of Bank Millennium Group’s business strategy and are in line with

the approach of the parent company - Bank Millennium bcp.

The Bank is of the opinion that environmental and climate protection issues concern many areas of

the Bank's operations and are an integral part of its business. Due to the importance of these issues,

the development of ESG strategies and policies is under the direct supervision of the Chairman of the

Management Board.

Bearing in mind the growing significance of sustainable development for the Bank Millennium Group’s

business, including climate-related issues, in December 2021 the Bank established within its structures

the Sustainable Development Committee and the Sustainable Development Department. These units

are described in "Management Approach to Sustainable Development” section.

Due to the nature of its activities, the risk of the Bank's direct impact on the environment has been

assessed as immaterial. However, in order to fully understand the wide range of interrelationships

between the Bank's activities and environmental risks, the Bank has chosen to incorporate various

environmental aspects into the assessment of other risks directly related to the Bank's operations as

separate risk factors. Currently, the environmental aspect is taken into account in the annual

assessment of the materiality of individual risks in the context of credit risk, market risk, operational

risk and reputation risk. The risk management process in the Bank and the Bank Millennium Group is

uniform to a high degree and it may be treated as a common system applicable to the overall Group.

2. ENVIRONMENT

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

2.1.1. CLIMATE ISSUES IN THE BANK MILLENNIUM GROUP'S STRATEGY

In the past years, the Bank's pro-environmental and pro-climate activities focused on reducing the

Bank's own environmental impact, imposing high standards of operations in this area and requiring

the same from suppliers and partners. In addition, for several years the Bank has been involved in

special energy transition financing programs.

The Bank has advanced and established skills in applying sustainability principles, also as regards

climate, and continues activities aiming to support the Bank on its path to climate neutrality.

For more than a decade, the Bank has monitored, reduced and reported its own Scope 1 and 2

greenhouse gas emissions. In its latest business strategy for 2022-2024, the Bank has pledged to reduce

these emissions by 50% in 2022 relative to 2020. The Bank also pledged to strive for climate neutrality

by 2027 in Scope 1 and 2 and by 2050 in Scope 3. The pledge means the continuation of the efforts

limiting own emissions and responsible development of a long-term credit policy taking into account

the energy transformation processes.

The Bank will actively support corporate clients in their decarbonisation efforts, in developing their

investment plans related to the European funds package, especially green finance. The Bank plans to

implement products that support sustainable development of enterprises (energy efficiency and

circular economy projects) and to further limit financing of activities that do not comply with

sustainable development principles and to provide PLN 2 billion of financing for sustainable and

transformational projects for the clients of the Bank and of the Bank’s Group over the next 3 years.

2.1.2. ENVIRONMENTAL POLICY OF THE BANK MILLENNIUM GROUP

A few years ago, the Bank decided to significantly reduce its exposures to the coal industry. As a

result, today the portfolio of exposures to coal and hydrocarbon mining is close to zero and industries

directly related to mining is insignificant (at the end of Q4 2021, the Bank Millennium Group’s

exposure was 0.96% of the corporate portfolio and 0.27% of the Group’s entire portfolio).

In 2019, the Bank decided to formalize its approach to climate issues and developed the

“Environmental Policy of the Bank Millennium Group", which defines 3 main areas of its

environmental activity:

- The Bank’s own environmental activities

The Bank Millennium Group minimizes its environmental footprint through rational management of

materials and waste, monitoring the use of water, energy and fuels, introducing environmentally-

friendly solutions in its operations, by encouraging employees, customers and business partners to

participate in environmental campaigns.

- Environmentally-friendly products and responsible financing

The Group supports the implementation of environmental goals by introducing profiled products to

its offer. Bank Millennium Group does not finance new coal mines and coal-fired power generation

projects, except for new projects related to reduction of pollution. New financing in the energy sector

is only possible if it serves the commitment to carbon-free energy sources and the energy transition

to carbon-free energy sources.

At the same time, the Group has for many years supported the financing of environmentally friendly

and energy-saving investments, including those related to the replacement of coal-fired power

generation with low-emission energy sources and modern energy infrastructure, concerning

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

renewable energy sources, reducing pollutant emissions and supporting energy efficiency, especially

in energy-intensive and high-emission industries, in the field of low-emission motor vehicles.

The Bank’s clients are obligated not to use funds from the loan in any way linked to the activities

mentioned on the EBRD Environmental Exclusion List. They are also obliged to obtain and maintain

all the necessary permits relating to protection of the environment in connection with their business

activity and conduct their business activity in compliance with any environmental regulations any

relevant laws, standards and other regulatory requirements at the nation-wide and local level with

respect to protecting the environment, health and safety as well as rules of social conduct.

- Environmental education

Employees, clients and business partners receive communication increasing environmental awareness.

Where justified, environmental clauses are used in agreements with product suppliers.

2.1.3. CLIMATE - KEY RISKS AND NEW OPPORTUNITIES

[GRI 102-15] Key risks in this area associated with managing the Group's environmental and climate

impacts through its own operations, banking products and services offered, including project finance,

and managing climate, transformation and physical risks to the Group.

[GRI 102-11] The Group prevents

this risk by submitting to legal regulations, monitoring its own environmental impact and

implementing environmentally-friendly actions and observing the “Environmental Policy of the Bank

Millennium Group” and project financing rules.

Under the Bank's existing industry policy regarding financing, the Bank distinguishes high-risk

industries. One of the criteria for a given sector to be classified in this category is a negative outlook

related, among others, with environmental threats. This classification reflects the financing principles

set out in the “Environmental Policy of the Bank Millennium Group". The Bank has exposure limits for

clients in individual categories, with the most restrictive limits set for high-risk industries. For entities

in industries with particularly negative environmental impacts, the Bank does not offer new financing

unless the funds are used for transformation and adaptation to new environmental and climate change

challenges.

Bank Millennium has also introduced provisions in the lending rules and regulations for Corporate

Banking clients, concerning compliance of all clients with environmental protection regulations and

respect for work rules. As a result, all projects financed by the Bank and all loan products were also

subject to these requirements.

[GRI 102-15] The Bank sees new climate-related opportunities in various sectors of economy, in the

development of new financial products and services. In addition, analyses of client feedback and

market research indicate that Polish society is increasingly aware of environmental and climate

challenges, which may in the long term bring changes in the behaviour and expectations of retail and

corporate clients towards products and services, also in the banking sector.

2.2. REDUCTION OF THE ENVIRONMENTAL IMPACT OF THE BANK’S

OPERATIONS

Bank Millennium Group views its responsibility for the climate as an external as well as internal

commitment. In addition to the activities described above and the adopted environmental policy, the

Bank actively implements green and innovative solutions in its premises and reduces consumption of

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and the Bank Millennium Group for 2021

resources. [GRI 304-1] The Bank Millennium Group does not own or lease any real estate in protected

areas or occupy any property, which is subject to special protection.

The Bank attaches great importance to reducing the level of emissions from the buildings it occupies

for the conduct of its business. In 2021, the Bank changed its headquarters in Wrocław to a building

meeting high environmental standards and opened a model environmentally-friendly branch in

Gdańsk. These and other environmentally-friendly measures are described in detail later in this

chapter.

2.2.1. REDUCTION OF RESOURCE CONSUMPTION

Reduction of material consumption [GRI 103-1, 103-2, 103-3, 306-1, 306-2]

In Bank Millennium Group the process of purchasing and supplying the Group’s organizational units

with materials necessary for the day-to-day operations is centralized. Maintaining purchasing

discipline is possible through the use of an IT tool, REZA+, through which each ordered item is verified

for legitimacy of purchase. This significantly reduces material consumption. Permanent monitoring of

budget execution and defining limits to reduce purchases to the level of current consumption also

makes a significant contribution to reducing material consumption. The process of ordering office

supplies and equipment is governed by internal instructions and then reviewed for legitimacy of

purchase and the Bank's equipment standards. Purchases of equipment such as counters, shredders,

refrigerators, microwave ovens and furniture (swivel chairs, desks, chairs and cabinets) are preceded

each time by a review of existing resources in terms of their reuse. This reduces the purchase of new

appliances and furniture.

Proper organization of the centralized procurement process and consistent discipline in purchasing

have helped to reduce consumption. The Bank takes measures on an ongoing basis to reduce the

consumption of purchased materials, thereby reducing the negative impact on the environment.

Collection and regeneration of used toners from multifunction devices used in the Bank is provided

by a third-party company. Waste paper and documents from the Bank’s archives whose retention

period has expired in a given year are transferred to companies specializing in the process of

destroying documentation. 100% of the documentation destroyed in industrial equipment is

recycled.

All types of electronic waste (ICT equipment, electrical equipment, data carriers), metal, plastic,

wood, glass non-hazardous waste (other than municipal waste) are collected by a specialized

company that has a permit for transport, collection and recovery of all types of waste. The contractor

collecting ICT equipment, electrical equipment and data carriers acts in accordance with the

provisions of the Waste Electrical and Electronic Equipment Act. This means that 100% of electronic

waste is sent to recycling.

In its operations, the Bank complies with environmental protection regulations, i.e. the Waste Act of

14 December 2012, as amended, Journal of Laws 2020, Item 797, consolidated version of 04 May 2020.

Following amendments to the Waste Act, in 2020 the Bank was listed on the Waste Database

In 2021, the consumption of paper and envelopes dropped significantly, which was supported by

further optimization of the Bank's processes. The Bank is consistently working towards further

digitization and top quality of online services to encourage clients to go paperless. A marketing

campaign conducted in 2021 to encourage customers to switch to electronic statements and less ad

hoc correspondence to clients resulted in a significant decrease in paper and envelope usage for mass

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

mailing. In addition, Mobile Authorization being implemented in more clients service processes

contributed to a reduction of paper consumption, despite the steady growth of the Bank's clients.

Millennium Leasing also supports the paperless idea by actively promoting the e-invoice service

available to clients in the eBOK portal in place of sending hardcopy invoices. Currently over 76% of

Millennium Leasing’s clients use electronic invoices, thanks to which over 65% of all invoices are sent

in electronic form in an easy and fast way from the client's perspective.

The provision of water purifiers for head office employees and water dispensers in the branches has

further reduced plastic consumption. For a few years now, for meetings in Bank Millennium’s Head

Office, catering is served in reusable dishes and cold drinks only in glass bottles. As part of educational

campaigns, the use of reusable cups is being promoted in the Bank Millennium Head Office cafeteria.

Moreover, on the occasion of relocation to the new Head Office in Wrocław, all employees of the

Wrocław office were equipped with porcelain mugs. In the Bank branches, in turn, in order to reduce

plastic consumption, disposable plastic water cups for clients have been fully replaced with

environmentally friendly BIO paper cups in 2021. These cups contain no plastic, are 100%

biodegradable and compostable according to European standard EN13432. Cups can be refilled twice.

In Bank branches, all plastic coffee stirrers have been replaced with wooden ones. Plastic consumption

levels are impacted by the ongoing COVID-19 pandemic that started in early 2020, as plastic is found

in hand sanitizer containers and diffusers, among other things. However, in the face of a real threat

to health, the Bank's priority is to continue to prevent the spread of the coronavirus and ensure the

safety of employees and clients. A small number of field units are still supplied with water in plastic

bottles, however these are ECO RPET bottles.

[GRI 301-1]

Material

consumption

(kg)

Bank

2021

Bank

2020

Bank

2019*

Bank

2021/2020

Reasons for change

Paper and

paper rolls

for

operational

needs

250,141 354,994 327,930 -29.54%

1. Decrease in mass mailing

due to a significant portion of

clients switching to

electronic bank statements.

2. Development of Mobile

Authorization.

Envelopes 75,055 116,064 77,655 -35.33%

1. Decrease in mass mailing

due to a significant portion of

clients switching to

electronic bank statements.

2. Decrease in additional

mailings by 50%.

Plastics 16,073 40,911** 12,948 -28.54%

1. Plastic stirrers and

disposable cups have been

withdrawn. They have been

replaced with biodegradable

paper cups and wooden

stirrers.

2. Decrease in purchase of

secure envelopes - decrease

in the number of branches

requiring additional security

of cash in secure envelopes

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

* without data from former Euro Bank

** purchase of plexiglass dividers for all branches as a result of the Covid-19 pandemic

* without data from former Euro Bank

** purchase of plexiglass dividers for all branches as a result of the Covid-19 pandemic

Municipal waste management

The Bank segregates, depending on local regulations, waste into 3 to 5 groups: plastic, paper, glass,

bio and mixed. In addition, containers for collection of batteries and small electrical waste have been

set up in the offices of the Bank's Head Office in Warsaw. A campaign to collect large size electronic

waste takes place once a year. Mixed municipal garbage is collected by the City using a pre-declared

monthly number of containers. Recycling waste bins are available at all Bank locations, both branches

and office buildings. In addition, in 2021, 453 new waste segregation kits were delivered to 436

locations, bringing the total number of bins to 1,359. All bins are properly labelled with educational

signs with detailed waste segregation instructions to help employees segregate waste.

The annual campaign to collect electro-waste was organized in the Bank Millennium Head Office and

enabled employees to give away unwanted equipment. The Administration and Infrastructure

Department encouraged employees to do their annual cleanup by allowing a convenient way to hand

over electro-waste. The campaign also involved private equipment and batteries. In addition, bottle

and container caps are collected at the head offices and branches and then donated to a charitable

cause. The caps collected in 2021 by Bank Millennium Group employees were donated to the Dom

Rodzina Człowiek (Home, Family, Human) Association, which will sell them as recyclable material and

(no multi-safe permanently

attached to the floor).

3. Reduction of the purchase

of water in plastic bottles by

more than 11%.

Consumable

materials for

printing

devices

0 1 418 -100%

Purchase of supplies for

multifunctional devices is the

responsibility of a third-party

company.

Batteries 794 760 556 +4.6%

Batteries required, among

others, for:

- automatic hand sanitizer

dispensers,

- remote controls for alarms,

electronic locks

- for A/C remote controls.

[GRI 301-1] Material

consumption (kg)

Group

2021

Group

2020

Group

2019*

Group 2021/2020

(% change)

Paper and paper rolls for

operational needs

259,608 364,592 343,277 -28.79%

Envelopes 76,014 117,541 79,031 -35.33%

Plastics 16,532 41,371** 14,252 -60.04%

Consumable materials for

printing devices

0 1 418 -100%

Batteries 806 785 610 +2.65%

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

donate the money for: material assistance for the poor and disabled, financing the purchase of

prostheses, meals for poor families, financing tutoring for children from poor families or financing

Christmas presents for poor families.

Similarly to previous years, managers of the buildings of the Head Offices in Gdańsk and Warsaw kept

a register of waste in the following categories - metal and plastic, paper and glass, bio and mixed.

[GRI 306-3] Municipal waste (kg)*

Paper 10,861

Metal and plastic 15,434

Glass 15,600

BIO 4,212

Mixed 65,220

* Data from Bank Millennium’s Head Office Building Managers Register

- no information on recycling rate available

Waste collections

from employees

(kg)

Group

2021

Group

2020

Group

2019*

Group 2021/2020

(% change)

Reasons for change

Electrical waste 200 250 150 -20%

Due to the wide

availability of collection

sites, and lower building

occupancy caused by the

pandemic.

Collection of

batteries

150 300 150 -50%

Due to the wide

availability of collection

sites, and lower building

occupancy caused by the

pandemic.

Collection of plastic

caps

230 n/a n/a -

In 2021, we began

collecting data on the

number of caps donated.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Recycling - reuse

In 2021, the Bank allocated 452 items of assets (equipment and furniture) for reuse in the Bank's

branches).

In 2021, the Bank changed its headquarters in Wrocław. The furniture from the previous location did

not fit into the arrangement of the new Head Office facility and was not used in the Bank’s other

facilities, it was slated for liquidation. In order to minimize as much as possible the amount of waste

resulting from the liquidation of unnecessary furniture, the Bank organized, through a specialized

company, the sale of chairs, cabinets, desks, containers, tables, chests of drawers, armchairs and

bookcases. 3,269 items were put up on the sale platform. The exercise was preceded by messages in

the Bank's internal channels. As a result of the sale, as much as 65% of the furniture received a

second life. Bank employees purchased 30% of the items, the remaining 35% was purchased in the

next stage by companies specializing in resale, and only 35% of the equipment, due to the fact that

the furniture was heavily worn-out and damaged, was sent for disposal. The project of changing the

seat of the Bank's Head Office in Wrocław is described in detail later in this report.

Generated waste sent for reuse and recycling

[GRI 306-3]

Waste

generated (kg)

Bank

2021

Bank

2020

Bank

2019*

Bank

2018

Bank

2021/2020

Reasons for change

ICT equipment

and devices

52,358 53,084 23,185 17,654 -1.4%

Systematic replacement

of the slowest ICT

equipment in the head

office and branch

network no longer fit for

use.

Paper** 258,754 272,316 243,782 298,428 -4.9%

The amount of waste

paper destroyed depends

on the number of cartons

in the External Archives

for which the retention

period has expired in a

given calendar year.

Metal waste and

cable

1,884 9,998 21,986 13,217 -81.2%

The decrease in waste is

due to the transfer of

responsibility for

managing waste

generated during office

remodelling to service

providers.

The 2020 data includes

elements from the

building managers'

waste).

Plastics 51 4,715 1,667 936 -98.9%

The 2020 data includes

elements from the

building managers'

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

waste).

Glass 0 828 637 3,176 -100%

The 2020 data includes

elements from the

building managers'

waste).

Furniture 5,494 7,160 49,028 22,711 -23.2%

The effect of the sale of

furniture to the Bank's

employees.

Lead batteries 336 6,928 14 0 -95.2%

The decrease results from

the liquidation of the UPS

from decommissioned HQ

Wrocław Computer

Centre in 2020.

Waste printing

toner

586 614 295 438 -4.7%

The decrease in waste is

due to the transfer of

responsibility for

managing waste

generated during office

remodelling to service

providers.

Mixed concrete

and brick

rubble waste,

waste from

construction

sites and

renovations

0 0 3,520 5,310 n/a

Responsibility for waste

management related to

facility conversions

delegated to service

providers who report

directly to the BDO.

Total 319,643 355,643 344,114 361,870 -10.17%

[GRI 306-4]

Recycled

waste (%)***

82% 88% 84% 82%

* no data for Bank Millennium Group; no data from Euro Bank

** waste paper is 100% recycled

*** percentage of waste shown in the table, excluding paper, that is further recycled at processing

facilities

[GRI 306-3] Waste generated (kg) Bank 2021 Bank 2020 Bank 2019*

Municipal waste 111,327

Generated waste sent for reuse and recycling 319,463 355,643 344,114

Total waste 430,790

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Monitoring energy, water and fuel consumption

[GRI 103-1, 103-2, 103-3]

After an analysis of the consumption of water, energy and fuels, measures are implemented to reduce

consumption of these resources, inter alia through:

 Use of energy-efficient lighting in the head office and branches and automatic systems to

reduce energy and water consumption in the head office building in Warsaw, which has been

awarded the BREEAM certificate (Very Good level), and LEED Gold in Wrocław. Additionally,

in Wrocław, Dali system (Digital Addressable Lightning Interface) is installed, which reduces

operating costs and increases the comfort of work. Used both daylight supply sensors and

occupancy sensors throughout the space, which contributes significantly to energy efficiency.

 In order to reduce fuel consumption, Bank Millennium Group successively replaces cars in its

fleet with hybrid models. For business travel, low-emission means of transport (rail) are

preferred and limits associated with the use of airplane transport are applied.

[GRI 302-1]

Energy

consumption

Group

2021

Bank

2021

Group

2020

Bank

2020

Group

2021/

2020

Bank

2021/

2020

Reasons for change

Electricity

purchased

(GJ)

87,265 76,979 94,936 83,621 -8.08% -7.94%

Optimization of the

number of branches,

reduction of the

number of head

office buildings in

Wrocław (1 out of 4

buildings remains),

introduction of

technical equipment

optimization, as well

as the impact of

pandemic and lower

occupancy of office

buildings.

Electricity

with RES

Guarantees of

Origin*

68% 68%

Heating

energy

purchased

(GJ)

92,029 85,913 115,969 102,763 -20.64% -16.40%

The decrease is due

to a reduction in the

number of branches,

as well as the closure

of three head office

buildings in Wrocław.

Consumption in 2020

was very high due to

the long heating

season, resulting in a

significant reduction

in heating

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

*A description of the calculation methodology can be found on page 48

Fuel

consumption

[GRI 302-1]

Bank

2021

Bank

2020

Bank

2021/2020

Fuel Gasoline Diesel LPG Gasoline Diesel LPG Gasoline Diesel LPG

Fuel

consumption

(litres)

487,974 209,588 151,133 422,327 271,300 131,415 +15.5% -22.7% +15%

consumption year-

on-year.

Natural gas

(GJ)

6,921 6,435 7,897 6,821 -12.35% -5.66%

Similarly as for

heating energy.

Heating oil

(GJ)

423 334 291 240 +45.40% +39.32%

The increase is due

to the purchase of

heating oil as

replenishment of the

stocks.

Total energy

consumption

(GJ)

186,639 169,660 219,092 193,444 -14.81% -12.30%

[GRI 303-5]

Water

consumption

Group

2021

Bank

2021

Group

2020

Bank

2020

Group

2021/

2020

Bank

2021/

2020

Reasons for change

Water (m³) 70,739 66,146 101,898 93,391

30.58% -29.17%

Water consumption

is closely related to

the number of

employees in the

offices, so this

significant decrease

was driven by the

pandemic and

remote work,

temporary shutdowns

of branches for

service, and a

decrease in the

number of branches

and office buildings.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The decrease in diesel fuel consumption is due to the termination, in 2021, of approximately 100

diesel car contracts acquired as a result of the merger with Euro Bank. The increase in gasoline and

LPG consumption levels is, in turn, due to a recovery in 2021 in business car use, which dropped

significantly in 2020 due to the pandemic.

Rationalization of business travel is driven by the constraints of Bank-imposed modes of transportation

and the approval path when a higher standard of transportation is used. Employees may use second

class rail transport (PKP), and coach and bus transport (PKS and BUS). Only a limited group of

employees (based on position or function) may use first class rail transport. With regard to the process

of ordering train and airline tickets, the Bank uses the support of an external company with which it

has an agreement to handle business travel. For airplane and private car travel, a Management Board

Member approval is required. Additionally, as part of the modernisation of the Bank's Head Offices in

Warsaw, Wrocław and Gdańsk, multimedia devices and Internet applications (e-learning training

platform, MSTeams, Skype) are used to organise meetings and trainings, which translates into less

business travel.

Business

travel -

Bank (km)*

2021 2020 2019 2018 2017 2021/2020

Air** 302,402 393,922 624,505 566,782 212,425 -23.23%

Taxi 991 1,943 8,784 3,562 3,155 -48.9%

Railway** 725,916 1,105,957 3,183,766 2,739,829 2,227,450 -34.36%

Bus 8,649 208,455 561,841 483,499 247,495 -95.8%

Private car 53,248 48,963 +8.75%

* Data for Bank Millennium; the Companies do not maintain a register of km travelled

** The 2020 data have been updated according to the new methodology applied - see pages 51-52

for a description.

The number of business trips in 2021 was greatly reduced by the coronavirus pandemic. Business travel

was primarily conducted in 1H2021 when government restrictions were lifted. Training away from the

office, which is mostly done through an e-learning platform, continued to be significantly limited.

Companies handle their business travel on their own.

Fuel

consum

ption

Group

2021

Group

2020

Group

2021/2020

Fuel Gasoline Diesel LPG Gasoline Diesel LPG Gasoline Diesel LPG

Fuel

consum

ption

(litres)

574,344 231,267

151,415

540,896 282,251 131,415 +6.2% -18% +15.2%

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Environmental activities

The Bank Millennium Group conducts a number of activities aimed at optimizing the use of energy,

water, fuel and purchased materials.

Plastic

Measure Description

Limiting plastic

consumption

 Popularity of payments using a virtual card and BLIK in a mobile app

reduces the need to reduce the number of issued plastic cards;

 Introduction of an option to temporarily block your card so you don't

have to get a new one made;

 There are water treatment purifiers at the Bank’s Head Office - no need

to purchase bottled water;

 Based on the average number of shipments sent out, a limit for secure

plastic envelope orders was set for each of the Bank's organizational

units.

Efficient

management of

available resources

 Reuse of resources allows the Bank to reduce the purchased quantities of

furnishings (desk chairs), own devices (shredders and bill counters) and

consumable materials (e.g. toners, hangers, inking ribbons);

 Appliances and equipment from closed down or remodelled branches are

handed over for use in other outlets.

Zero Waste - the

second life of

furniture

 The Bank organized, through a specialized company, a sale of equipment

slated for disposal (chairs, cabinets, desks, containers, tables, chests of

drawers, armchairs, bookcases, etc.). 3,269 items were put up on the

sale platform. The exercise was preceded by messages in the Bank's

internal and external channels. As a result of the sale, as much as 65%

of the furniture received a second life.

IT Tools

 The IT system supports verification of each purchase order for materials

and office equipment in terms of the justification for the purchase and

the defined limit, thereby contributing to reduced consumption of

resources;

 In 2021, the Bank continued to use approximately 2,500 VDI (Virtual

Desktop Infrastructure) workstations. This solution reduces, among other

things, the consumption of raw materials (in particular plastic and metals

used for the production of new personal computers) and electricity (e.g.

"traditional" workstation consumes on average about 200W, while VDI in

the Bank model - less than 5W). Despite the additional energy

consumption by the central server room, by sharing a single physical

server across hundreds of virtual machines, VDI technology can

significantly reduce the carbon footprint in the environment.

Recycling -

donating operable

computers to those

in need

 Bank Millennium and Millennium Leasing once again responded to the

needs of a local community by donating computer equipment to the

beneficiaries of the Forani Foundation.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Paper

Action Description

Restrictions on

printing of

documents

 In branches, postings of internal transactions are recorded in the

system - there is no need to print them out;

 The quantity of paper ordered to print cash and treasury

transactions is controlled on an ongoing basis, based on monthly

cash transaction reports;

 Through automation of the ATM settlement process, the related

documents no longer have to be printed;

 Print volume monitoring - reports are sent to the units generating

the highest print volumes so that reduction measures can be taken;

 Printing on company printers is possible only after the employee

logs in to a specific device, which prevents accidental printing.

Opening an account

online using a selfie

or open banking

 The Bank provides the option to open an account online with a

selfie or with proof of identity by logging into an account at

another bank. Both processes are fully remote and require no

printing of any documents.

Buying cinema

tickets on the

mobile app

 When you purchase cinema tickets directly from the app, you don't

need to print them either - you can show them on your phone's

screen at the cinema or you can send them to your friends directly

from the app.

Electronic expert

appraisal in the

mortgage loan

application process

 The Bank has made available the ability to obtain an e-appraisal,

which is one of the documents needed in the mortgage loan

application process. The appraisal, i.e. the property valuation

process, is ordered by the Bank's system and made available to the

Bank for analysis also electronically. This eliminates the need for

the client to provide a paper document. In addition to paper, it

also saves the electricity needed to scan documents and uses less

toner cartridges that ultimately have to be disposed of.

Confirmation of

some transaction at

in branches using

Mobile

Authorization

 In 2020, the Bank made it possible for branches to confirm some

transactions using Mobile Authorization, which is another important

step in the Bank's digitalisation and reduction of paper

documentation. Until then, all transactions made at a branch were

confirmed with a signature on the transaction confirmation printed

by a Bank employee. A client with active Mobile Authorization will

approve some of the transactions ordered at the branch by phone.

In 2021, the service was expanded to include more instructions;

 Since implementing this solution, clients have effected

approximately 1.6 million transactions, which made it possible to

abandon hardcopy printouts and save 32,000 reams of paper.

Opening and

administering

investment

products in remote

channels

 Bank Millennium clients can invest their savings from a computer,

tablet or phone - in 2021 the Bank expanded the offering of

investment products available online, mainly in the mobile

application. Clients can also complete the MiFID questionnaire

online. Access to investment products in the Millenet system and

via the mobile application reduces the number of documents

printed in Bank branches. Clients may conveniently confirm some

instructions regarding funds submitted in a branch in the mobile

application without having to sign any hardcopy documents.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Action Description

Electronic

circulation of

internal documents

 By introducing IT systems for processing internal documents, the

circulation of most paper documents has been eliminated in the

Bank;

 Processing client documentation (e.g. loan applications) is based

on electronic copies of documents.

Fewer printouts for

clients

 Electronic document circulation through Millenet for Corporates -

the solution enables transferring and receiving digital documents

and concluding agreements with the use of an electronic signature

with a qualified certificate. This allows you to dispense with

printing documents for signature;

 Some documents are posted on the Bank's website and in internet

banking. Through internet banking, for example, the client is

informed of changes to the terms of service (durable medium);

 Consolidation of documents (several instructions in one document,

several agreements in one template);

 Shortening documents (tables and verbless sentences instead of

descriptions), reducing the number of printed pages;

 Access to e-government - submitting official applications is

possible through electronic banking, which reduces the use of

paper (applications from programs: Family 500+, Good Start 300+,

RKO, logging in to the PUE ZUS platform, setting up the Trusted

Profile);

 Possibility to pay motorway tolls and buy public transportation and

parking tickets through the mobile application;

 Electronic bank statements - electronic statements are the default

option for every new client concluding an agreement for bank

products and services. It is possible to opt out of this option at a

client’s request;

 The Bank actively conducts campaigns promoting the use of

electronic statements;

 Electronic application process for products: opening another bank

account, cash withdrawals, loan application, setting up a deposit,

etc.;

 Contactless phone payments with the possibility to virtualize

plastic cards, BLIK contactless payments, and promoting cashless

payments;

 Purchase of insurance products also in remote channels, where you

can conveniently and intuitively purchase insurance fully online

without the use of hardcopy documentation;

 When applying for a mortgage loan, scans of documents can be

directly uploaded to the Bank's system or they can be retrieved by

an employee from public records and client’s checking and savings

account statements generated online;

 Clients with a mortgage loan can attach scans or photos of their

insurance policy through remote channels, without having to

provide paper documents;

 The goodie smart-shopping platform launched by Bank Millennium

makes it possible to browse stores’ online offers and electronic

newspapers instead of their hard copy counterparts.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Action Description



Online trade finance module – solution for corporate clients

facilitating electronic orders and remote correspondence with the

Bank;

 E-guarantee for business clients - is a bank guarantee issued in

electronic form (PDF file) using a qualified electronic signature of

two of the Bank's attorneys-in-fact;

 In Millennium TFI, transaction confirmations can be sent to the

client electronically. The client has the option of specifying an e-

mail address for receiving electronic transaction confirmations;

 The distributors with whom TFI has signed distribution agreements

offer the possibility of purchasing fund units online (the purchase

form for the client is electronic);

 Millennium Leasing provides access to the Electronic Client Service

Office on the Millenet platform, where clients can use electronic

invoices (in 2021 the share of clients using this solution increased

from 54% to 76%) and the setting of SMS notifications informing

about a new invoice issued, upcoming payment date and overdue

payment;

 One of the key initiatives of Millennium Leasing is the

popularization of e-signature, introduced in 2020, as a form of

signing leasing contracts (in 2021, the company signed 2,315

contracts this way, which accounted for 11% of the total number of

contracts concluded and 33% of the contracts for which such a

possibility was provided).

Product sales via

remote channels

Retail clients may apply for credit, savings and insurance products

using remote channels where paper documentation does not exist

at all. In this process, an agreement is approved by the SMS

P@ssword and its wording is available in the system, so it does not

need to be printed out;

 Corporate clients can apply for a payment card or open another

account through the internet banking system. Clients applying for a

loan can submit the required documentation electronically.

Product digitization continued in 2021 and, in the wake of the COVID-19 pandemic, consumer habits

have changed significantly, with consumers more willing to use online solutions for both banking

products and ancillary services. There was a record increase in the number of online transactions and

e-commerce payments, especially in BLIK payments, where one can see a +72% y/y change in e-

commerce transactions and as much as +125% y/y in the number of P2P transfers.

Share of electronic channels in the sales volume of key products

Personal accounts* Cash loans Term deposits

28% 69% 92%

*process initiated through the electronic channel

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Increase in the number of clients using online services

2021 2020 difference

All clients with access to

electronic banking

3,489,972 3,230,769 +8%

Active electronic banking

users

2,263,233 2,052,806 +10%

Clients who actively use

mobile banking

1,920,883 1,658,554 +16%

Clients using Mobile

Authorization

1,995,707 1,394,169 +43%

Clients using open banking

(Finanse 360º)

53,149 36,300 +46%

Clients – users of online

statements

2,807,904 2,643,960 +6%

Clients with access to

e-administration

1,058,813 664,695 +59%

Electricity and water

Action Description

Energy efficient

buildings of the

Bank’s Head

Office in Warsaw

and Wrocław

 Savings in energy consumption are driven by, among other things, the

use of modern LED lighting in staircases and headquarters offices.

 In 2020 the Bank replaced the lighting in the Head Office offices

with modern LED lighting. The decision was based on improving

energy efficiency - reducing CO

emissions and analyzing the running

costs of electricity consumption compared to modern solutions and

their impact on environmental protection.

 A total of approx. 12,000 fixtures in the old fluorescent

technology were replaced with modern LED lighting, thereby

reducing lighting energy consumption by 54% and thus reducing CO

emissions by 500 tons per annum. 2021 is the first year to see the full

impact of this project on energy consumption levels.

 In the new head office in Wrocław, LED lighting was used in the DALI

system with motion sensors and light intensity sensors taking into

account the supply of daylight. As a result of the relocation, the old

fluorescent lights were replaced with a state-of-the-art system -

approximately 850 LED fixtures were installed. Improving the quality

of lighting in offices has had a tremendous impact on employee

health, well-being and productivity.

Reduction of the

operating time of

technical

equipment

 In 2021, further optimization of the operating time of the

installations in the buildings progressed. To this effect, the settings

and technical parameters of various devices were changed, for

example, operating time of office lighting, operating time of

ventilation and air conditioning and temperature settings in

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Action Description

individual areas. These optimizations have helped minimize

electricity consumption at the Bank's Head Offices.

Energy savings in

branches

 Advertising banners with traditional light sources were replaced with

energy-efficient LEDs in all branches.

 Time control of advertising banner lighting using astronomical clocks.

 We have consistently increased the number of branches with LED

lighting. At the end of 2021, 153 branches used LED lighting. LED

lighting is standard in all modernized Corporate Centres and was

installed in 4 office locations in 2021.

 All facilities have restricted air conditioning operation by installing

timers to regulate the running time of air conditioning units.

 As a result of the changed opening hours of the outlets due to the

pandemic, the operating hours of equipment and lighting in the

outlets and own buildings have been reduced.

Rational

management of

energy

consumption

 In the Bank’s Head Offices, the air conditioning is set at 21 degrees

Celsius and ceases to operate after working hours;

 During visits of Experts in the Bank's branches, a campaign promoting

conscious use of air conditioning in the context of electricity

consumption and environmental protection is conducted.

 Virtualization of servers has made it possible to reduce the number of

physical hardware in the computer centre, which drove down energy

consumption for power supply and air conditioning;

 In 2021, additional floors at the Bank’s Head Office in Warsaw were

redeveloped. Occupancy sensors have been installed in all toilets and

small kitchens - the lights turn off automatically if there are no

people present. In 2020 and 2021, nearly 8,000 sqm of office space

has been redeveloped using occupancy sensors in selected social

areas.

 In the new head office in Wrocław, in the entire lease area, i.e.

almost 4,000 sqm, a modern lighting system with occupancy sensors

and light intensity sensors has been installed in the open space

sections, using daylight supply. The system is designed to significantly

reduce utility consumption compared to old-style lighting.

Utility

consumption

control

 It is done on an ongoing basis. Based on the financial data, a

consumption ranking of energy recipients is prepared. Branches with

the highest energy consumption rates are controlled and

recommendations for building administrator companies are

implemented. Similarly, in the event of high utility bills it is verified

whether the consumption is correct and whether or not any devices

or installations have broken down.

Reducing the

working time of

cleaning

companies

 In previous years, the companies worked in an 8 p.m. to 4 a.m.

system. This required lights to be turned on during these hours,

resulting in higher electricity usage. In 2020, the companies work

from 5 p.m. to 10 p.m. Lighting is turned off after 10 p.m.

Optimization of

water

consumption

(branches and

head office)

 In 2020, the Bank installed 173 state-of-the-art perlators, special

tap attachments that visually increase the flow of water through

aeration, in 14 of its buildings. Perlators allow to save water

consumption in the range from 15% to 25%.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Action Description



At the Bank’s Head Office in Warsaw, some of the perlators were

already installed in 2018, generating water consumption savings of

15%.

 Hot and cold water dispensers are installed in the Head Offices,

which encourages office workers to use dispensers instead of buying

bottled water. This has the effect of reducing waste - including

plastic.

[GRI 302-4] Energy savings in

the Bank's locations

2021 2020 2019** 2018 2017

RETAIL OUTLETS (excluding Millennium Mini outlets)

Branches with LED lighting

banners

417

(100%)

456

(100%)

357

(100%)

361

(100%)

355

(100%)

Locations with panels turned

off at midnight

409

(98%)

409

(90%)

310

(86%)*

305

(84%)*

307

(86%)*

Energy-saving light sources

in branches (LED lighting)

153

(36.5%)

117

(26%)

113

(32%)

100

(28%)

(22%)

CORPORATE BANKING OUTLETS**

Branches with LED lighting

banners

8 7 7 7 7

100%

100% 100% 100% 100%

Locations with panels turned

off at midnight

8 7 7 7 7

100%

100% 100% 100% 100%

Energy-saving light

sources in locations (LED

lighting)

4 1 0 0 0

50% 14% 0% 0% 0%

BANK MILLENNIUM’S HEAD OFFICES***

Branches with LED lighting

banners

3 3 3 2 2

100% 100% 100% 100% 100%

Energy-saving light sources in

locations (LED lighting)

2 1 0 0 0

66% 33% 0% 0% 0%

*The remaining panels are lit up for the entire opening time of the shopping malls in which they

are located.

**Corporate banking outlets, excluding locations at the same address as the Head Offices or retail

outlets.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

***Bank Millennium Head Offices understood in terms of city location rather than individual

buildings due to dispersed structure.

Fuels

Action Description

Hybrid vehicles

Cars in the Bank's fleet are gradually being replaced with hybrid models. At

the turn of 2022 and 2023, the Bank plans to replace its remaining cars with

new hybrid vehicles, which will translate into even greater reductions in

exhaust emissions into the environment.

Limiting the

amount of

business travel

In order to minimize business travel, limits are used for respective types of

transportation and remote communication methods are used, such as: e-

learning courses, teleconferencing and videoconferencing.

Chargers for

electric cars and

scooters

The Bank actively supports a green lifestyle in its infrastructure investments

- in 2021, charging stations for electric cars as well as bicycles and scooters

were launched at the Bank’s Head Office in Warsaw.

2.2.2. GREENHOUSE GAS EMISSIONS

For over a decade, the Bank has been monitoring and publishing data on the level of greenhouse gases

emissions. In its latest business strategy the Bank has pledged to reduce emission of greenhouse gases

in Scope 1 and 2 by 50% in 2022 relative to 2020 and also to strive for climate neutrality by 2027 in

Scope 1 and 2 and by 2050 in Scope 3. Below we present information on the emissions in 2021

(compared to 2020) and information on the methodology of the calculations made.

Carbon footprint

[GRI 305-1, 305-2, 305-3, 305-4]

Scope 1, 2 and 3 GHG emissions in tonnes CO

e for Bank Millennium

Scope of GHG

emissions

Emission category

Emissions 2021

[Mg CO

Emissions 2020

[Mg

difference

Scope 1

Combustion in mobile

sources

1,832

1,840

-0.4%

Combustion in stationary

sources

390

405

-3.8%

Total: Scope 1

2,222

2,246

-1.0%

Scope 2

Purchase of heat

8,291

9,917

-16.4%

Purchase of electricity

(location-based)

14,496

16,820

-13.8%

Purchase of electricity

4,677

11,517

-59.4%

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

(market-based)

Total: Scope 2 location-based

22,786

26,737

-14.8%

Total: Scope 2 market-based

12,968

21,434

-39.5%

Scope 3

Cat. 3 energy and fuel-

related emissions (not

included in scope 1 and 2)

(location-based)

4,376

3,120

+40.2%

Cat. 3 energy and fuel-

related emissions (not

included in scope 1 and 2)

(market-based)

1,902

3,120

-39.0%

Cat. 6. Business travel

127

-28.4%

Total: Scope 3 location-based

4,467

3,247

+37.6%

Total: Scope 3 market-based

1,993

3,247

-38.6%

Total: Scope 1, 2 (location-based), 3

29,476

32,230

-8.5%

Total: Scope 1, 2 (market-based), 3

17,183

26,927

-36.2%

Total (market-based) emissions generated by Bank Millennium in 2021 were 17,183 Mg CO

e, 36.2%

lower than in 2020. In 2021, Scope 1 direct emissions accounted for only approx. 12.9% of Bank

Millennium's total emissions, where 10.7% came from mobile source combustion and 2.3% came from

stationary source combustion. In 2021, 77.3% of Bank Millennium's total emissions came from indirect

Scope 2 (location-based) emissions, where 49.2% of Scope 2 emissions were emitted through the

consumption of purchased electricity and 28.1% came from the consumption of purchased heating

energy. In 2021, indirect Scope 2 (market-based) emissions accounted for 75.5% of Bank Millennium's

total emissions, of which 27.2% of Scope 2 emissions were emitted through the consumption of

purchased electricity and 48.2% came from the consumption of purchased heat. In 2021, the share of

indirect Scope 3 (market-based) emissions was 11.6%, where 11.1% were energy and fuel-related

emissions (not included in Scope 1 and 2, such as electricity and heating generation, transmission

losses, or emissions from the fuel generation process), and 0.5% were business travel. Emissions

reductions occurred in all categories with the exception of energy and fuels emissions not included in

Scope 1 and 2 (location-based). The published DEFRA emission factor for 2021 for this category was

doubled, therefore emission level is increased, despite the decrease in electricity consumption.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Scope 1, 2 and 3 GHG emissions in tonnes CO

e for the Bank Millennium Group

Scope of GHG

emissions

Emission category

Emissions 2021

[Mg CO2e]

Emissions 2020

[Mg

CO2e]

difference

Scope 1

Combustion in mobile

sources

2,076

2,130

-2.5%

Combustion in stationary

sources

424

471

-9.9%

Total: Scope 1

2,500

2,601

-3.9%

Scope 2

Purchase of heat

8,881

11,191

-20.6%

Purchase of electricity

(location-based)

16,433

19,096

-13.9%

Purchase of electricity

(market-based)

5,302

12,985

-59.2%

Total: Scope 2 location-based

25,313

30,287

-16.4%

Total: Scope 2 market-based

Scope 3

Cat. 3 energy and fuel-

related emissions (not

included in scope 1 and 2)

(location-based)

4,966

3,565

+39.3%

Cat. 3 energy and fuel-

related emissions (not

included in scope 1 and 2)

(market-based)

2,082

3,565

-41.6%

Cat. 6. Business travel

127

-28.4%

Total: Scope 3 location-based

5,057

3,691

+37.0%

Total: Scope 3 market-based

2,173

3,691

-41.1%

Total: Scope 1, 2 (location-based), 3

32,871

36,580

-10.1%

Total: Scope 1, 2 (market-based), 3

18,856

30,469

-38.1%

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Total (market-based) emissions generated by the Bank Millennium Group in 2021 amounted to 18,856

Mg CO

e, 38.1% lower than in 2020. In 2021, 77% of Bank Millennium Group's total emissions came

from indirect Scope 2 (location-based) emissions, where 50% of Scope 2 emissions were emitted

through the consumption of purchased electricity and 27.02% came from the consumption of

purchased heating energy. In 2021, indirect Scope 2 (market-based) emissions accounted for 75.22%

of Bank Millennium Group's total emissions, of which 28.12% of Scope 2 emissions were emitted

through the consumption of purchased electricity and 47.1% came from the consumption of purchased

heat. In 2021, Scope 1 direct emissions accounted for about 13.3% of Bank Millennium Group's total

emissions, where 11.05% came from mobile source combustion and 2.25% came from stationary source

combustion. In 2021, the share of indirect (market-based) Scope 3 emissions was 11.5%, where 11%

was energy and fuel-related emissions (not included in Scope 1 and 2), 0.5% was business travel.

Emissions reductions occurred in all categories with the exception of energy and fuels emissions not

included in Scope 1 and 2 (location-based). The published DEFRA emission factor for 2021 for this

category was doubled, therefore emission level is increased, despite the decrease in electricity

consumption.

Due to the fact that for electricity purchased directly by the Bank, Guarantees of Energy Origin were

purchased in amount of 16,418,875 kWh, emissions related to purchase of electricity in Bank

Millennium were reduced by 68% [9,819 t CO

e] and in Bank Millennium Group by 68% [11,131 t CO

e],

comparing calculation according to the location-based method (where average indicator for Poland is

used) to the market-based method (where the energy seller is known, the seller-specific emission

factor is used).

Scope 1, 2 and 3 GHG emissions in tonnes CO

e per mPLN of revenue for Bank Millennium

Scope of GHG

emissions

Emission volume/mPLN

of revenue 2021

[Mg CO

e/mPLN]

Emissions volume/mPLN

of revenue 2020

[Mg CO

e /mPLN]

difference

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Scope 1, 2 (market-

based)

4.18

5.95

-30%

Scope 1, 2 (market-

based), 3

4.73

6.77

-30%

Scope 1, 2 and 3 GHG emissions in tonnes CO

e per employee for Bank Millennium

Scope of GHG

emissions

Emissions

volume/employee

[Mg CO

e/employee]

Emissions

volume/employee

[Mg CO

e/employee]

difference

Scope 1, 2 (market-

based)

2.29

3.31

-31%

Scope 1, 2 (market-

based), 3

2.60

3.76

-31%

Scope 1, 2 and 3 GHG emissions in tonnes CO

e per mPLN of revenue for the Bank Millennium

Group

Scope of GHG

emissions

Emission volume/mPLN

of revenue 2021 [Mg

e/mPLN]

Emission volume/mPLN

of revenue 2020

[Mg CO

e/mPLN]

difference

Scope 1, 2 (market-

based)

4.36

6.37

-32%

Scope 1, 2 (market-

based), 3

4.92

7.25

-32%

Scope 1, 2 and 3 GHG emissions in tonnes CO

e per employee for the Bank Millennium Group

Scope of GHG

emissions

Emissions

volume/employee

[Mg CO

e/employee]

Emissions

volume/employee

[Mg CO

e/employee]

difference

Scope 1, 2 (market-

based)

2.36

3.57

-34%

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Scope 1, 2 (market-

based), 3

2.66

4.07

-34%

Calculation methodology used

The greenhouse gas report was prepared in accordance with the Greenhouse Gas Protocol (GHG

Protocol), according to the revised version of: 'A Corporate Accounting and Reporting Standard revised

edition, GHG Protocol Scope 2 Guidance Amendment to the GHG Protocol Corporate Standard' and

'Corporate Value Chain (Scope 3) Accounting and Reporting Standard, Supplement to the GHG Protocol

Corporate Accounting and Reporting Standard'.

GHG emissions were calculated separately for Bank Millennium (BM) and Bank Millennium Group

(GBM), which includes all the other companies (Millennium Leasing sp. z o. o., Millennium Dom

Maklerski, Millennium TFI S.A., Millennium Goodie sp. z o. o, Millennium Bank Hipoteczny S.A.,

Millennium Service sp. z o.o., Millennium Telecommunication Services sp. z o.o. and Piast Expert sp.

z o.o. in liquidation, Lubuskie Fabryki Mebli S.A. in liquidation, which do not generate emissions). The

operational control criterion was used as organizational boundaries. Bank Millennium has 100%

operational control in the listed companies generating GHG emissions.

The scope of emissions reporting includes Scope 1 direct emissions (according to the GHG Protocol)

from combustion of fuels in own or controlled energy sources: combustion in stationary sources -

natural gas and fuel oil heating boilers and combustion in mobile sources - company vehicles (LPG,

gasoline, diesel), scope 2 indirect emissions from the generation of purchased electricity and heating

energy consumed, and other scope 3 indirect emissions related to energy and fuels (not included in

scopes 1 and 2) and emissions generated during business travel in modes of transportation not owned

or controlled by the company.

In order to increase the quality of the carbon footprint calculations, changes were made to the

methodology for 2020 and 2021 by systematising the emission factors used, performing calculations

for electricity according to the location-based (using the average emission factor for Poland) and

market-based (using emission factors specific to energy sellers) methods, and changing the calculation

method for business trips (changing the data source from estimates of the distance travelled for air

and rail trips to the distance between the city of the start and end of the trip). Additionally, the data

for calculations was updated based on actual values from invoices, including invoice corrections for

electricity) (available after the date of the previous report), which related to electricity consumption

and district heating. There were no biogenic emissions in the organization. Total CO

emissions

(market-based) for Bank Millennium were (in tonnes) 17,167, CH4: 0.16 and N2O: 0.04, and for Bank

Millennium Group respectively: 18,838, 0.18 and 0.05. 2020 was selected as the base year due to the

application of the updated calculation methodology for that year, and because it was the first full

year after the acquisition of Euro Bank.

Data used for calculation and measurement of emissions

Fuel and energy consumptions are shown in the tables for Indicator 302-1. Business travel data is

shown in the table on p. 38.

Input data source

Combustion in mobile sources:

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Diesel, gasoline, LPG - Fuel consumption data comes from a compilation of fuel card reports. Fuel

consumption in Millennium Bank Hipoteczny S.A. was estimated on the basis of fuel costs.

Combustion in stationary sources:

Natural gas - Gas consumption figures for Bank Millennium and Bank Millennium Group were estimated

on a cost basis.

Fuel Oil - Consumption data comes from invoices.

Purchased energy:

Electricity - Consumption data comes from invoices and was partially estimated based on energy costs.

In 2020, invoice data represented 68% of the estimated total energy consumption in Bank Millennium

and 69% in Bank Millennium Group. In 2021, 65% and 68%, respectively.

Heating (district) - Consumption data comes from invoices and was partially estimated based on

actual costs. In 2020, invoice data represents 7.7% of the estimated total cost of heat consumption in

Bank Millennium and 8.2% in Bank Millennium Group. In 2021, invoice data represents 9.5% of the

estimated total cost of heat consumption in Bank Millennium and 11% in Bank Millennium Group.

Business travel:

Air travel - emissions were calculated based on reports received from travel agents (distance

travelled). In 2021, the travel agent arranged 98% of the flights (by flight cost), so the emissions

calculated by the travel agent were approximated to 100% of the emissions in 2020 and 2021.

Rail transportation - For Bank Millennium, data on distance travelled was obtained from reports

prepared by the travel agency. In 2021, the travel agent arranged 75% of the travel by train (based

on travel costs), so the distance calculated by the travel agent was approximated to 100%. Few train

trips by employees of other Group companies were also included.

Road transport (bus, taxi, private cars) - For Bank Millennium the distance travelled was estimated

based on actual costs. The distance covered by private cars was calculated on the basis of costs

including a flat rate per kilometre (so-called kilometre allowance).

Emission factors

Fuels (combustion in mobile and stationary sources), WTT indicators, business travel - DEFRA 2020,

version 1.3 (published 31.07.2020), DEFRA 2021, version 1, CH4 and N2O emissions converted from

AR4 to AR5 (CH4 25 to 28; N2O 298 to 265).

Electricity location-based - 2019 electricity benchmarks published in December 2020 (benchmark for

2020 data), 2020 electricity benchmarks published in December 2021 (benchmark for 2021 data). Link:

https://www.kobize.pl/pl/fileCategory/id/28/wskazniki-emisyjnosci

Electricity market-based -

https://www.orlenpaliwa.com.pl/PL/NaszaOferta/Documents/Struktura%20Paliw%202019%20ORLEN

%20Paliwa.pdf (benchmark for 2020 data)

https://www.orlenpaliwa.com.pl/PL/NaszaOferta/Documents/Struktura%20Paliw%202020%20ORLEN

%20Paliwa.pdf (benchmark for 2021 data)

The above data, in accordance with the regulations, are published after the end of the year by the

end of March of the following year, which is after the time the Bank prepares the report. Therefore,

the most current available indicators at the date of the calculation are used in the calculations.

Heat - URE (Energy Regulatory Office); Report “Heating power industry in numbers - 2019” - the latest

available document used in the emissions calculations.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Reducing the carbon footprint of buildings

Bank Millennium attaches great importance to reviewing and reducing the level of emissions from

the properties that it occupies in connection with its activities. In 2022, all electricity purchased by

the Bank will be covered by certificates of origin from renewable energy sources. The Bank

introduces environmentally friendly solutions in its three head offices (in Warsaw, Wrocław and

Gdańsk). In 2021, the Bank conducted an energy audit of its premises.

New head office in Wrocław

[GRI 305-5]

The head office relocation project in Wrocław started in Q4 2020 and was divided into two stages.

Stage one involved the consolidation of four office buildings into one existing location - this optimized

the office space, reducing it by 3,200 m2, resulting in reduced utility consumption and lower

electricity demand. This ultimately translated into a reduction in carbon footprint expressed in

tonnes of CO

equivalent equal to 959 tC02e/year, representing a 30% reduction in carbon dioxide

emissions. The effect of the reductions presented is evident in the data presented in this report.

Stage two of the project involved relocation to the new head office, to which employees moved in

mid-November 2021. It is located in a building with a LEED GOLD certificate confirming its energy

efficiency and sustainability. The Bank approached the project comprehensively, and environmental

solutions were implemented at every stage of the interior design and furnishing project, starting

with the introduction of led lighting with motion sensors and a system using daylight supply in the

office, which significantly improves the comfort of employees. The wall cladding and part of the

ceilings were made of wood wool, improving acoustics, but most importantly coming from sustainable

sources, as confirmed by the international Blue Angel certification. The Bank's main objective was

to use solutions that have a high recycling rate - for example, the selected carpet is made from 59%

recycled materials and some of the upholstery is 100% recycled. For the rest of the equipment,

wooden materials were chosen, raw natural plywood/mdf from certified cultivation, in natural

colours, thus reducing the use of artificial varnishes and paints. All purchased equipment has an

extended warranty period, so that it will serve employees for many years. When selecting products,

preference was given to those manufactured in Poland and locally, e.g. decorative lamps made of

cardboard were manufactured in Wrocław. The project was accompanied by biophilic concept, which

means that there is a lot of plants in the new office space, improving both employee well-being and

air quality. The equipment from the previous headquarters, in turn, was auctioned off to

employees in keeping with the "Zero Waste" concept, giving it a second life. We estimate that

this phase will further reduce the carbon footprint by 2,016t CO

e, representing 92% of the absolute

reductions achieved both through the purchase of renewable electricity certificates of origin, but

also through the green solutions described above. The full results of this phase will be reflected in

the 2022 Bank Millennium Group ESG report.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The above shows the project summary according to the GHG Protocol standard. A Corporate and Reporting

Standard, revised edition, March 2004. World Resources Institute and World Business Council for Sustainable

Development. (Revisions and Amendments: Required gases and GWP values, February 2013), Scope 2 emissions

calculation methodology: market-based approach (applying purchased electricity emissions rate by energy

supplier rate) according to the GHG Protocol. Scope 2 Calculation Guidance. An amendment to the GHG

Protocol Corporate Standard, 2015. World Resources Institute.

Total absolute reduction of the carbon footprint of Bank Millennium’s Head Office in Wrocław

amounted to 2,976.25 t CO

e/year, which is a reduction of total emissions from utility consumption

by 94.5%. Reductions in emissions from the consumption of: electricity were 99.5%, heat energy -

76%, water - 79% and wastewater production - 81%. The total reduction in emissions of 2,976 tons of

e/year is equivalent to the emissions of a passenger car circling the earth 362 times, a train

journey of one person from Wrocław to Warsaw travelling 269,250 times or the annual electricity

supply for 4,789 people.

Model green branch in Gdańsk

Another example of investing in environmentally-friendly solutions is a model ecological Bank

Millennium branch, which opened in Gdańsk in 2021. The branch was moved from an old building to

a new one that meets strict environmental standards. The project considered the low emission

ambitions already at an early planning stage. This was reflected both in purchasing decisions and in

hiring an independent partner to calculate emission reductions in accordance with the Greenhouse

Gas Protocol standard (Greenhouse Gas Protocol, A Corporate Accounting and Reporting Standard,

revised edition, March 2004). The conscious choice of innovative, environmentally-friendly solutions

in the new branch, combined with reduced consumption of energy and other utilities and the

purchase of green energy (which is produced by wind power in a renewable energy source, as

confirmed by guarantees of origin), has allowed us to reduce emissions by more than 70% compared

to the previous location. For a single Bank branch, this means a reduction of nearly 39 tons of carbon

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

dioxide equivalent per year, which is equivalent to supplying 62 Poles with electricity for the entire

year. This is also how much 26 people would save by switching from cars to bicycles for a year.

The emissions data presented in the “Greenhouse gas emissions" section were calculated by

independent third-party companies.

2.2.3. ENVIRONMENTALLY-FRIENDLY PRODUCTS AND RESPONSIBLE

FINANCING

Environmental activities cover the entire product portfolio of the Bank Millennium Group. Active

measures are taken to reduce the use of paper in communication with our clients in all lines of

business. Clients may confirm some of the transactions ordered in branches using Mobile

Authorization, which has significantly reduced the quantity of paper used for document print-outs.

Individual customers

The WWF Millennium Mastercard credit card (APR of 14.77%) is offered as part of the Bank’s long-

term cooperation with the WWF Poland Foundation. The card is made with recycled plastic.

Thanks to its virtual form, the goodie eCard is a convenient and environmentally-friendly way of

giving a gift. The card can be set up in just a few moments in the goodie mobile app. In addition, the

goodie app affords access to the electronic versions of the store flyers of many shopping networks

thereby reducing paper consumption.

Bank Millennium has investment funds pursuing social and environmental goals in its offering for

affluent clients. Moreover, the Bank is regularly working on extending the investment offering it has

available to clients in electronic banking channels. Presently, all investment products are made

available to clients through remote channels, thereby reducing the number of documents printed in

the Bank’s branches, reducing paper consumption and contributing to environmental protection.

Furthermore, the option to authorize client instructions using a mobile phone was introduced in the

Bank’s outlets in 2021 in processes related to investment products, which eliminates the usage of

paper in these processes. In 2022, a similar solution was extended to include savings products (term

deposits and savings accounts).

The Bank offers mortgage loans for renovation or modernization of properties, under which the Bank's

clients often use the funds to modernize e.g. a roof covered with eternit, replace the central heating

system/furnace, etc.

Corporate customers

The Bank Millennium Group does not finance new coal mines and coal-fired power generation projects,

except for new projects related to reduction of pollution. These issues are described in detail in

"Environmental Policy of the Bank Millennium Group" section.

In line with the strategy for 2022-24, the Bank Millennium Group will actively support clients as they

decarbonise, and will provide PLN 2 billion of financing for sustainable and transformational projects

for the clients of the Bank and of the Bank’s Group over the next 3 years.

The Bank offers the Biznesmax Guarantee Program in cooperation with Bank Gospodarstwa

Krajowego. The guarantee is used to secure loans granted to finance innovative projects in the SME

sector, including environmentally effective companies. Clients benefiting from the “environmental

path” in the Biznesmax Guarantee Program may execute an investment project with at least one

environmental category, e.g.: electromobility, renewable energy sources spanning PV installations,

technologies to reduce energy consumption, technologies to produce alternative fuels, circular

economy, installations to recover raw materials in production processes, etc.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The Bank actively expands the knowledge of its employees on financing environmentally-friendly

projects. In June advisors and credit analysts in corporate banking took part in a webinar run by a

law firm specializing in the renewable energy sector. The meeting was devoted to discussing the

specifics of a financing transaction in the PV sector considering the industry’s legal and regulatory

environment.

Millennium Leasing is consistently involved in the financing of energy savings investment projects in

compliance with the Environmental Policy of the Bank Millennium Group and industrial policy. For this

purpose, it uses and intends to use programs organized by EBRD (European Bank for Reconstruction

and Development) under which it refunds clients for a portion of financing costs for machinery and

equipment on the LEME list. This list contains machinery and equipment vetted by engineers that

support the reduction of CO

emissions and energy efficiency by achieving energy savings of at least

20%. Millennium Leasing also advocates the financing of equipment to generate energy from

renewable sources. Since 2019 Millennium Leasing is particularly active in developing the MilleSun

program dedicated to financing PV investments. Leasing of panels is a solution targeting entrepreneurs

focused on reducing the costs of electricity consumption combined with a change in social awareness

in the field of environmental protection and keen on building their environmentally-friendly image on

a par with the economic efficiency of investments. In the leasing of PV panels Millennium Leasing

cooperates with leading reliable suppliers of these types of installations; it offers safe financing on

preferential terms and conditions and a greatly simplified process to lease environmentally-friendly

investment projects.

In 2022 Millennium Leasing intends to participate in the Mój Elektryk Priority Program guaranteeing

co-payments from the National Environmental Protection and Water Management Fund to lease

electrical vehicles towards the down-payment in agreements to lease electrical vehicles. The co-

payments are up to PLN 27 thousand for passenger vehicles (M1) and up to PLN 70 thousand for delivery

vehicles up to 3.5 tons, respectively. The purpose of the program is to reduce air pollution emissions

by co-funding undertakings to reduce the consumption of fuel generating emissions in transport. The

co-funding constitutes support and an incentive to buy/lease zero emission vehicles.

The economy’s transition and clients’ implementation of sustainable development policies will in the

future be a growing source of demand for the financing offered by Millennium Leasing. We anticipate

that this growth will pertain in particular to the following:

• investments in energy saving machines and equipment to reduce the quantity and the cost of

electricity used per product unit,

• low emission means of transport supporting the reduction of CO

emissions in the transportation of

people and cargo,

• technologies for generating and storing energy from renewable sources.

2.3. EU TAXONOMY

Taxonomy - reporting obligations

Pursuant to Article 10(3) of Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021.

(hereinafter: Delegated Regulation) in conjunction with Article 8(1) of Regulation (EU) 2020/852 of

the European Parliament and of the Council of 18 June 2020 (hereinafter: Taxonomy), the Bank Group

is required to disclose, for the period from 1 January 2022 to 31 December 2023, the percentage of

exposures to Taxonomy-non-eligible economic activity and Taxonomy-eligible economic activity in its

total assets.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Taxonomy-eligible economic activity means the activity described in Annexes I and II of Commission

Delegated Regulation (EU) 2021/2139 of 4 June 2021. (hereinafter: Climate Regulation), regardless

of whether such economic activity meets any technical criteria indicated therein.

Disclosures on Taxonomy-eligible exposures should be based on the latest available data of the Bank

Group's clients that are subject to the obligation to publish non-financial information under Article

19a or 29a of Directive 2013/34/EU (the national implementation of the Directive was made in the

Accounting Act of 29 September 1994).

Since at the time of publication of this report (21 February 2022) there were no available client non-

financial reports which should form the basis for the disclosures, the Bank Group - as part of voluntary

disclosures - made its own estimates based on internal data and surveys sent out to clients.

Based on these estimates, we estimated that as at 31 December 2021, for companies subject to the

obligation to publish non-financial information in accordance with Article 19a or 29a of Directive

2013/34/EU:

• The percentage of exposures to Taxonomy-eligible activities in the Bank Group’s total assets

is 1.33%,

• The percentage of exposures to Taxonomy-non-eligible activities in the Bank Group’s total

assets is 0.86%,

In addition, as at 31 December 2021:

 The on-balance sheet exposure to central governments, central banks and supranational issuers

as a percentage of the Bank Group’s total assets was 19.13%.

 The percentage of on-balance sheet exposures on account of derivatives in the Bank Group’s

total assets was 0.1%.

 The percentage of on-balance sheet exposures to non-financial corporations not required to

publish non-financial information in accordance with Article 19a or 29a of Directive 2013/34/EU

in the Bank Group’s total assets was 16.54%.

 The percentage of trading portfolios and on-demand interbank loans in the Bank Group’s total

assets was 0.17%.

The above indicators have not been audited and are prepared to the best of the Bank Group's

knowledge.

The Taxonomy regulations are currently under intensive development and detailing. Due to the fact

that 2022 is the first time that the reports required by the Taxonomy are produced, and this has major

impact on the availability of the required data, at the time of publication of the report (21 February

2022) the Bank is in the process of implementing the requirements following from Regulation (EU)

2020/852 into its business strategy, product design processes and cooperation with clients and

business partners.

Taxonomy - reporting principles

Due to the lack of uniform interpretation of the EU regulations regarding the concept of "total assets"

included in the disclosure under the Taxonomy, it has been assumed that it includes on-balance sheet

exposures in accordance with the scope of prudential consolidation for the types of assets indicated

in Regulation No 575/2013 of 26 June 2013 (hereinafter: CRR).

In the voluntary disclosure regarding the percentage of exposures to Taxonomy-eligible activities in

the Bank Group’s total assets and the percentage of exposures to Taxonomy-non-eligible activities in

the Bank Group’s total assets, as well as in the disclosure regarding the percentage of exposures to

companies that are not required to publish non-financial information, only on-balance sheet exposures

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

to business entities that are non-financial corporations were taken into consideration. Exposures to

households, including mortgage-backed, were not taken into account.

In order to determine the group of clients that are subject to the obligation to publish non-financial

information, for the Bank Group’s clients that are non-financial corporations, internal data were

analyzed in terms of the criteria indicated in the Accounting Act, including: sales revenues, assets

and number of employees, as well as the legal form of the business. The sources of information

analyzed included: latest available standalone annual financial statements and internal information

obtained in the course of cooperation with clients.

Based on the data selection process, the Group identified and sent a survey to the group of clients

potentially obligated to publish non-financial information. The purpose of the survey was to obtain

information on whether the given entity is subject to a non-financial reporting obligation and, if so,

whether its activities can be considered Taxonomy-eligible and what percentage of its sales revenue

is generated by such activities.

If, in the survey, the client provided information on the percentage of its sales revenue from

Taxonomy-eligible activities, that client's exposure to the Bank Group is included in the calculation

of the Taxonomy eligibility and non-eligibility ratios as Taxonomy-eligible activities in the percentage

provided, and the remainder as Taxonomy-non-eligible activities. If the survey did not provide an

answer regarding the percentage of revenue from Taxonomy-eligible activity, it was assumed for the

calculation of the ratios that 100% of that client's exposure to the Bank Group is Taxonomy-eligible.

2.4. FULFILLING THE REPORTING REQUIREMENTS

Bank Millennium is getting ready to comply with new reporting requirements resulting from the

dynamic development of regulations associated with the drive to achieve the climate objectives

established in the Paris Agreement.

The Bank Millennium Group has been reporting information on its environmental impact since 2011,

including data regarding the emission of greenhouse gases under Scope 1 and Scope 2 and partially

under Scope 3. In Scope 3, the Group is working to prepare for accurate reporting of indirect emissions

data. It is expanding its knowledge on this subject by implementing projects with consulting

companies, participating in conferences and expert workshops (organized e.g. by the Polish

Association of Listed Companies and the Polish Confederation Lewiatan) and in the work done by the

Polish Bank Association. In 2021, the readiness of the Bank and selected Group entities (Millennium

Leasing, Millennium TFI) to operate in compliance with applicable regulations covering ESG and

market best practices on ESG was analyzed. The actions taken are described in the “Management

approach to sustainable development” section.

Bank Millennium takes part in the work of the task force established by the Polish Association of Listed

Companies, the Polish Bank Association, the Polish Chamber of Insurance and the Reporting Standards

Foundation. The purpose of this task force is to develop solutions to facilitate the application of

incoming regulations and standardize the format of the data used.

[GRI 307-1] In 2021 the Bank Millennium Group did not receive information on any case of having

violated environmental protection regulations.

2.5. ENVIRONMENTAL EDUCATION

Under the tenet that pro-environmental behaviour and everyday choices are at least as important as

the environmental solutions implemented in buildings, the Bank runs numerous educational

environmental campaigns. The organization is consistently building environmental awareness among

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

its employees, clients and business partners by running the following campaigns in 2021, among

others:

 Push Yourself, Not the Button Campaign - encouraging head office employees in Warsaw to

use the stairs instead of the elevators. All of the elevator banks in the head office have posters

advancing the campaign for leading a healthy lifestyle and choosing the stairs instead of the

elevator as they move about on a daily basis. On top of the fundamental goal of building the

well-being of employees, this campaign also aimed to minimize electricity consumption.

 Polish Green Record Campaign - Bank Millennium has joined the environmental campaign

#ZielonyRekord to break the Polish Green Record. In five of our buildings, new greenery and

trees have been planted, and new office plants have been added in our upgraded office

spaces. The Bank has received a certificate for its participation and exceptional involvement

in the campaign.

 Collection of electric waste and expanding the reach and duration of the environmental

charitable campaign involving the recycling of plastic bottle caps collected in the Bank (the

non-governmental organization cooperating with the Bank sells them as a recyclable raw

material and it designates the proceeds obtained to help the poor).

 Advancing the usage of reusable packaging by distributing ceramic mugs to all employees

in the head office in Wrocław to reduce the quantity of waste.

 Plants in the office. Lots of plants are used in all newly-commissioned office space, which

exerts a positive influence on the atmosphere in the office and the eco-climate.

 Advising on changes to waste collection (marketing campaigns, new containers for selective

waste with the right logo). New containers are located in the main corridors on every floor in

the office. Containers for paper and mixed waste can also be found in kitchen annexes.

 Most branches segregate waste. In the first half of 2021 the containers for waste segregated

in outlets and financial centres across Poland were replaced.

 In addition, the Bank segregates other waste, e.g. expended batteries and it collects

electrical waste. In 2021 the Bank collected 200 kg of electric waste, 150 kg of batteries

and 230 kg of plastic bottle tops delivered by Bank employees.

 The coffee shop on the premises of the Bank’s Head Office in Warsaw has discontinued the

use of plastic straws, paper packaging for sugar and plastic packaging for sandwiches, while

the staff recommends using your own mugs and dishes.

 Bicycle transport is encouraged and the infrastructure for cyclists is being expanded

(additional bicycle racks and showers). In 2021 employees received the possibility of using

another six showers installed in Warsaw and four in Wrocław. More than 80 bicycle racks were

also added in the new head office in Wrocław. In 2021 the Bank installed bicycle racks for 46

bicycles in its own buildings.

Climate education in Millennium Docs Against Gravity

Bank Millennium has been a long-term patron of the Millennium Docs Against Gravity Film Festival,

which informs viewers of many phenomena transpiring in the contemporary world and educates them

through the films shown and the events accompanying the Festival. In 2021 the festival was highly

focused on the theme of climate change.

The leading motto of the 18th edition of the festival - “The World Awakens” was taken from Greta

Thunberg’s speech. She is one of the most important environmental activists and the protagonist in

the festival’s opening film entitled “I am Greta”. Additionally, in the summer of 2021 the Millennium

Docs Against Gravity Festival ran an educational campaign entitled “The Planet Is Not Available for

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Credit” in social media channels jointly with WWF Polska and the Noizz.pl portal to build awareness

among their users about what the Day of Environmental Debt entails. During this campaign, the

“Greta’s 5 Steps” campaign - a list of steps to defer environmental debt - was announced.

A spot prepared by the Bank aired during the 18th edition of the Festival before films are shown in

cinemas and online touches on the aspect of the actions undertaken by Bank Millennium for the sake

of sustainable development: https://www.youtube.com/watch?v=jixbCGhtfio

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

BANKING INSPIRED BY PEOPLE

Bank Millennium’s priority is to ensure that all of its clients have full access to its services. The Bank

endeavours to support clients in the fulfilment of their plans and truly make their day to day life

easier. For many years, Millennium has been working on removing infrastructural, digital and physical

barriers in access to financial and non-financial services by introducing solutions based on cutting-

edge technologies.

In December 2021 Bank Millennium received the “Wrocław Without Barriers” certificate for facilities

making it easier to use digital banking and the implementation of architectural adjustments for people

with disabilities and conducting staff training on how to serve people with special needs. The

organizers also appreciated Bank Millennium’s efforts to build a socially responsible brand, which, as

the certificate states, “sets an example for the banking services sector and deserves the name of a

Bank Without Barriers”.

3.1. INNOVATIVE SERVICES

Bank Millennium’s digital channels support easy access to banking services and many non-banking

options. The Bank is constantly expanding its service offering in the mobile application and the

internet banking system to make more convenient and helpful solutions available.

In all its actions the Bank is guided by the idea of making clients’ lives better and easier every day.

The website, the Millenet internet banking system and the mobile application have been designed

with users in mind and jointly with them in the spirit of Human-Centred Design. The goal is for the

3. SOCIETY

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Bank’s interface to be friendly, offer convenient options and for contact with the Bank to build a

positive, personalized user experience. The UX, UI and Communication Teams in electronic channels

are responsible for designing services in accordance with clients’ needs and expectations. More than

10 years ago the Bank was one of the first players on the market to set up a User-Experience Lab. Its

team of researchers work jointly with users to test processes and the interface for digital channels.

It also administers surveys, etc. In this manner the Bank would like to illustrate that there are no

obstacles to gaining access to its services and no user group should feel excluded. Millennium clients

spend more and more time in the digital realm and expect that the Bank will keep pace with them

and offer more and more new and improved online services.

During the pandemic banking has proven to be much easier because the Bank, like the overall sector,

developed digital services much earlier. However, innovation and further digitalization of client

contact have become indispensable. Additionally, the Bank taps into the potential posed by open

banking, by implementing and constantly developing banking services consistent with PSD2.

Retail clients

Daily banking and digitalisation

Clients always have their phones with them. That’s why the Bank is developing services in the spirit

of omnichannel and is betting on mobile solutions in its processes. For instance, clients can apply for

additional funds through any fully-remote or hybrid online service channel with the support of a

hotline or outlet employee. Additionally, people can easily confirm their income by logging into their

account in another bank using Bank Millennium’s app, even if they submit their application in a

branch. In 2021 the scope of instructions clients can confirm in branches using Mobile Authorization

was extended, thereby modifying branch processes into paperless processes.

In 2021 the Bank streamlined its services and new solutions were added to support clients in managing

their finances on a daily basis. An option was added to the app to manage card limits and the

management of other daily limits was became easier. An option was added to generate a MilleCode

reminder in the portal and the app. We also refreshed the appearance of the main screen in the

mobile application after login. A new solution involves shortcuts to the most popular services available

immediately after login. The screen prior to login was also refreshed and the mobile application

activation process was shortened by removing one step.

The Bank continued the educational efforts it launched at the outset of the pandemic to support

clients who are just starting their online activity. Special emphasis was placed on clients who up till

now used the Bank’s services in branches. The Digital Ambassadors project launched in 2020 was

continued. This project focuses on branch employees tasked with advancing online services among

other employees serving clients in brick and mortar locations. Persons using electronic channels to a

limited extent were the second important group to which digitalisation efforts were directed.

Educational campaigns and campaigns advancing the available online solutions, e.g. Trusted profile

targeted these clients.

Lending processes

In 2021 the Bank continued to streamline credit processes available in online channels and in the

hybrid sales model. The Bank has made it easier to make early repayment – previously clients could

repay a loan solely from their main account. Now they can select the account from which the amount

will be withdrawn. The Bank also introduced a satisfaction survey in the cash loan process. In this

survey clients can express their expectations and evaluate the process. This survey is available to

clients who finish the process of applying for a loan and to people who decide not to finish it. Clients

with access to electronic banking but who do not have a current account received the option to open

an account directly in the loan process.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

2021 also led to changes in the process of consolidating external liabilities. Clients obtained the option

of external consolidation without having to take out additional funds. The Bank also expanded the

online process. It took into consideration hybrid sales - launched in an outlet or during a phone

conversation with a consultant and then completed by signing an agreement in Millenet or the mobile

application.

Streamlining the multiple channel consolidation process:

• additional information with an explanation of how consolidation works;

• spinning off the consolidation process to a separate offer, a new more accessible sequence of

components, changes to the UX;

• a detailed calculator showing the instalments clients pay now, the ones they will pay after

consolidation for the stated term along with a calculation of the monthly savings;

• other elements of the consolidation process were refined, e.g. the information displayed on

loans now contains the opening date and the original loan amount.

On top of the streamlining visible to clients the Bank made other changes that make it easier for

branch employees and hotline consultants to conduct hybrid sales.

Digital mortgages

Bank Millennium continued the mortgage loan service digitalization project started in 2020. In this

project more digital facilities are successively being introduced for clients. Solutions in this area have

been undergoing implementation for several years while the work on digitizing the application process

is currently the most intensive. In this short period the Bank designed and implemented a number of

facilities that have substantially optimized the processing of mortgage loans and made a positive

contribution to clients’ experience.

Clients submitting loan applications may do the following:

• go paperless and approve the application to provide loan information using an SMS code;

• conveniently track the status of their application in the mobile application and in the Millenet

internet service and in every instance when the application’s status changes they receive an

update;

• take advantage of an e-appraisal, or a convenient electronic process to appraise the value of

real estate.

In November 2021 the Bank made available an option to upload remotely third-party insurance policies

in the mobile application and the Millenet internet service. Now clients do not have to visit the branch

to deliver documents.

In the mortgage loan area Bank Millennium has been recognized in the voting on the “Golden Banker

of 2021” – our mortgage loan was recognized as the best one on the Polish market. In turn, it received

a distinction in the Best Mortgage Service category in the ranking for Institution of the Year.

Online investment products

Since 2020 Bank Millennium clients can invest their savings using their computer, tablet or phone. In

2021 the Bank expanded the offering of online investment products, chiefly in the mobile application.

Presently, the Bank’s offering makes the following available:

• individual investment funds of Millennium TFI and funds offered by third-party fund

management companies to clients in the Prestige and Private segments,

• off-the-shelf investment plans with varying degrees of risk,

• structured deposits.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The MIFID survey can also be filled out and updated online. Clients may conveniently confirm some

instructions regarding funds submitted in a branch in the mobile application without having to sign

any hardcopy documents.

Additionally, the Bank conducts actions to make it easier for clients to take well-informed investment

decisions, including:

 it gives access to educational materials and online films;

 it prepares a monthly summary of markets;

 it administers dedicated campaigns;

 it holds webinars run by experts.

Open banking

Bank Millennium has tapped into the potential offered by PSD2 to support innovation in open banking

services. We are a market leader in this area and we are observing that it is constantly becoming

more popular. Tens of thousands of our clients have already benefited.

Contemporary users appreciate the full service available on a mobile basis and in a single spot,

while Bank Millennium’s open banking services give them a single platform on which they can manage

their finance with ease. Checking balances and executing wire transfers from different banks are

useful solutions in daily banking while the income verification service makes it easy and speeds up

the submission of a cash loan application whether online or in a branch or using the hotline without

having to deliver any additional documents or hard copies of bank statements.

Bank Millennium makes the following available through open banking:

• The 360º Finance service making it possible to check your account balance and transaction

history on bank accounts in 9 other banks: Alior Bank, BNP Paribas, Bank Pekao, Citi Handlowy,

ING Bank Śląski, Inteligo, mBank, PKO BP and Santander Bank;

• The option to initiate wire transfers through your Millenet internet service using accounts in

6 other banks: Alior Bank, Bank Pekao, ING Bank Śląski, mBank, PKO BP and Santander Bank;

• Confirmation of income in the cash loan process by logging into one of 8 other banks: Alior

Bank, Bank Pekao, BNP Paribas, ING Bank Śląski, Inteligo, mBank, Santander Bank and PKO

BP;

• The process of opening a personal account using identity confirmation by logging into your

account in one of 7 other banks: Alior Bank, Bank Pekao, BNP Paribas,

ING Bank Śląski, mBank, Santander Bank and PKO BP;

• The process of opening a company account for sole proprietors using identity confirmation by

logging into your account in one of 7 other banks: Alior Bank, Bank Pekao, BNP Paribas, ING

Bank Śląski, mBank, Santander Bank and PKO BP;

• The process of submitting an instalment loan application – clients who would like to pay in

instalments for purchases in the web stores of Bank Millennium’s partners can confirm their

identity when submitting an application by logging into one of the banks in which they have

an account (8 banks available in this service): Bank Millennium, Alior Bank, Bank Pekao, BNP

Paribas, ING Bank Śląski, mBank, Santander Bank and PKO BP;

• The Bank also employs open banking to propose more customized products to clients who

have taken advantage of combining their accounts – based on the history from another bank

we are capable of calculating loan proposals and offer savings or investment products.

The Bank is constantly working on expanding the current services to include more banks and on

introducing new solutions that will tap into the possibilities afforded by open banking.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Cooperation with the public administration

For years Bank Millennium has been collaborating with government agencies and has participated in

building digital society and popularizing e-administration. The Bank’s clients may take advantage of

the Trusted Profile, log into PUE ZUS and the Bank, they can submit applications for 500+ and 300+

benefits in internet banking. From January 2022, customers can also submit applications for the 500+

benefit and Rodzinny Kapitał Opiekuńczy (Family Care Capital) benefits in the mobile application.

Mobile application and valuable added services (VAS)

For several years we have been observing the dynamic growth in the number of users taking advantage

of mobile applications, which is simply proportional to the rising popularity of smartphones and

recently to wearables. Young people who live in a virtual world treat mobile solutions as a standard.

In response to these expectations bank applications transcend current services and are becoming

platforms that aggregate many useful services on a daily basis.

Bank Millennium’s mobile application is a modern and convenient platform to manage daily dealings.

For instance, clients can pay for parking, motorway tolls or public transport; they can buy tickets to

the cinema or they can insure their car. The application supports the purchase of tourism insurance

using the innovative Travel Assistance service. It also helps in updating data in identity documents

and conveniently using credit products and investing savings. Access to quick assistance is also

important, e.g. through live chat or block a lost card on your own. We are also developing solutions

employing artificial intelligence. Clients can already use the assistance of Milli in Bank Millennium’s

application. This automatic assistant is ready to help 24 hours a day, 7 days a week, it learns quickly

and it can become a loyal companion in daily banking.

In 2021 this application was integrated with Huawei Mobile Services and is available in the AppGallery

– clients who have the latest Huawei mobile devices can use it.

Solutions introduced in 2021:

• We have introduced a version of the app for children aged 7-12 with an exceptional function

called “Ask for Pocket Money” and the option to open an account for a child in electronic

channels;

• We were the first bank to make BLIK contactless payments available in Poland;

• We have made an innovative app available to be paired with Apple Watch – it works regardless

of the handset and makes it possible to pay using BLIK and confirm transactions routed online

and some instructions submitted in the branch;

• We have developed access in the app to the goodie shopping platform – we have observed

growing interest in the e-commerce market and we are making it easier for clients to gain

access to these services with an option to benefit from special discounts, promotions and the

cashback offer;

• We have added the option to buy investment funds;

• We uploaded new modules to recognize speech and understand intentions. They enable the

Milli chatbot to understand the words uttered by users better and give advice, e.g. on how to

unblock their PIN code or change their limits;

• We refreshed the main screen and the screen preceding login, we added convenient shortcuts

to the most popular functions and the option to manage card limits;

• We added more instructions submitted in a branch that can be authorized in the app instead

of using a hardcopy signature;

• We have launched a contextual live chat function, e.g. on a cash loan application.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Support for business

For years Bank Millennium has blended innovation with designing services transcending the purely

banking area. That is why we also give tools to people running a business to support them in building

a modern competitive business.

We support the Bank’s clients and clients who have not had a relationship up till now with the Bank

in remotely opening a company account. We were the first to start confirming clients’ identity in the

process of opening a company account by using open banking. We are successively adding banks

through which this can be done.

In 2021 we introduced a new online process to open a company FX account. Additionally, we made it

easier to wire money between your own accounts and we started to create a remote cash loan process

for business activities. In a pilot project we made available an option to sign a loan agreement

remotely – this also applies to loans a de minimis guarantee.

One of the more important projects launched with businesses in mind was the innovative package

Smart Terminal Plus, which was introduced in the latter half of 2021. Clients who run trading activity

can take advantage of this package. In that case they obtain a modern sales position with an

innovative terminal to handle payment cards, a sales app and a compact fiscal printer. Smart Terminal

Plus supports the management of your product assortment, the merchandise base and warehouse

levels, rapid sales, adding and configuring new merchandise, setting prices, discounts, issuing

invoices, generating reports and thanks to the available analysis of sales, receipts and fiscal data this

also supports the efficient review and optimization of costs.

The Bank also participated in the distribution of funds under the grants in the Polish Development

Fund’s Financial Shield for companies that suffered damage due to the COVID-19 pandemic during

this program’s first and second rounds. The processes used to apply for and make settlements on

these grants were available in the Millenet system and in Millenet for Corporates.

New solutions for Corporate Banking clients

A module supporting two-way exchange of electronic documents with clients has been launched in

the Millenet transaction system for Corporates. Depending on the type of document being used, the

module customizes the required and possible actions to be performed by Bank Millennium and its

clients, making it a friendly and intuitive solution for its users. Clients and the Bank have the option

to approve or reject the documents being sent and to give comments on them until the final language

is agreed upon. This modules supports the uploading of documents containing a qualified signature,

while every version of the document sent to a client contains the Bank’s electronic signature. Clients

are advised by an SMS when a document is made available. Documents and the history of their

exchange are a convenient digital archive for clients, and this archive is accessible to authorized

system users. An extension of the document exchange module is slated to be launched in early 2022

to include automatic verification of electronic signatures. It will also generate certificates and

conserve electronic signatures. The digital exchange of documents will substantially reduce the usage

of paper and the number of consignments and meetings needed to exchange documents with clients,

which is also important in the context of the risks related to the COVID-19 pandemic.

The Bank also implemented new tools to support the work done by clients in the Millenet transaction

system. Currently, clients can obtain technical support from Millenet Experts through the chat

function and voice calls involving the co-browsing functionality.

The extension of the FX platform’s accessibility was a very important improvement – clients can use

it 24 hours a day, 5 days a week. The functionality of the platform has also been extended to include

conditional orders. This was made available to clients in January 2022.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Leasing clients have received a new set of reports in the Millenet lease module, giving them

convenient access to complete data pertaining to lease agreements, instalments, invoices and

insurance for the leased assets.

Clients’ interest in handling electronic orders for granting guarantees and opening letters of credit on

the Bank’s trade finance platform is on the rise. At the end of 2021, some 91% of the orders for

extending a bank guarantee and opening documentary letters of credit under lines were submitted by

clients electronically. Nearly every third guarantee took the form of an e-guarantee, i.e. an electronic

version of a guarantee with the guarantor’s qualified electronic signature.

The Bank has also developed the MillenetLINK service to integrate clients’ finance and accounting

systems with the banking transaction system. This solution has been enriched to include a reporting

module, handle prepaid cards and international wire transfers. The creation in Millenet of a register

of prepaid cards to process a large number of cards and personalize them was a major way of

streamlining for clients utilizing e-commerce transactions.

3.1.1. OFFER DESIGNED TO MEET CLIENTS’ NEEDS

Bank Millennium and the Bank’s Companies offer products and services to improve their clients’ living

conditions, facilitating management of their finances and savings that are also environmentally

friendly. Environmentally-friendly products are described in the section entitled “Environmentally-

friendly products and responsible financing” while solutions related to the COVID-19 pandemic are

described in the section entitled “Service and support for clients in the COVID-

19 pandemic second year”.

The Bank’s purpose is to provide convenient solutions that really make clients’

lives easier and help them achieve their financial targets. One example of this

approach is the Bank offering the 360° Account.

The 360°Account offering is universal and designed to address the needs of various client groups,

irrespective of their age and income.

Accounts for younger clients are always free of charge, while the 360° Account allows for a fee

exemption even if the monthly amounts credited to the account are not very high. The Bank does

not have a requirement for a minimum amount of a single incoming amount or a source of income. It

suffices for the sum total of proceeds to be at least PLN 1,000, regardless of whether that is for

proceeds from salary, social benefits, a scholarship or cash deposits.

What’s more, when fulfilling the requirement for the account to be free of charge, meaning meeting

the minimum proceeds threshold and executing at least one payment by a card attached to the

account or by BLIK in a month, the client will also not pay a fee for withdrawals from ATMs. That

means that clients who have problems with mobility (older persons or persons with disabilities) may

use ATMs in convenient locations without incurring fees for withdrawals from third party ATMs.

Clients whose finances do not suffice to pay for doctors to make house calls may benefit from them

in the event of a sudden illness or if their child falls ill under the Very Helpful Package offered in

conjunction with the 360° Account. This package also provides the assistance of a plumber or an

electrician or the repair of equipment such as household appliances, radio and television equipment,

smartphones and tablets. When selecting an account with the Very Helpful Package clients can take

advantage of 7 interventions a year. The package is free of charge for six months after opening the

account.

Having younger clients in mind the Bank’s offer contains the 360° Student Account for people aged

18 to 26 and 360° Junior Account for clients who have not yet turned 18. As it is endeavouring to

help them take their first steps in the world of finance, the Bank does not charge fees for account

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

handling, while their debit card and withdrawals from ATMs are free of charge provided that they

execute at least one transaction a month using a card or paying by BLIK. Since May of 2021, children

aged 7 to 12 may use a mobile application and a payment card for the 360° Junior Account designed

to meet the needs of the youngest users. These modern tools help introduce children to the world of

finance and teach them how to use technology safely.

3.1.2. BANKING WITHOUT BARRIERS

[GRI FS14] The Bank’s purpose is to dismantle digital and physical obstacles to financial and non-

financial services. Bank Millennium is not only a financial services centre for clients. It is also the first

access channel for other services, e.g. in the mobile application clients can buy tickets for urban

transport, pay for parking or buy car insurance simply by scanning the code in their registration

document. Remote contact with Polish government offices is also possible through internet banking.

The Bank is striving for all our clients, including clients with disabilities to have convenient access to

financial services. That is why many facilities have been implemented for blind and visually impaired

people and people who use wheelchairs for their mobility.

 Bank Millennium’s website, the Millenet internet banking system and the Bank

Millennium mobile app are continuously being adapted to meet the needs of blind

and visually impaired individuals. The websites are written in simple and easily

understandable language for the user and may be read by automated text readers. A

visually impaired user can use the website with a keyboard - the mouse is not needed

to navigate the portal. Moreover, the site has a text zoom feature and is designed for

high-contrast reading.

 Users of smartphones with fingerprint readers may log in to our mobile app with

a fingerprint. In the same manner, they may also validate online card transactions

using 3D-Secure. Also, owners of iPhone X or newer models may log in using the FaceID

facial recognition feature. Our mobile app is adapted to the needs of blind and

visually impaired persons owing to its compatibility with access-enhancing

services such as Google TalkBack (Android) and VoiceOver (iOS) that enable the

presentation of information using speech. Clients can also use the assistance of a

chatbot in the Bank’s application. Our automatic assistant available 24 hours a day,

7 days a week may serve as a valuable guide to daily banking. Clients can use the

assistance of Milli in Bank Millennium’s mobile application. It is capable not only of

greeting and responding to various questions, it can also perform orders such as

submitting a wire transfer. These types of solutions based on artificial intelligence

significantly contribute to enhancing the inclusiveness of the Bank’s services.

 Bank Millennium is one of the first companies to begin adapting its website to the

needs of people with disabilities. In recent years Bank Millennium has been honoured

with an award for its “Website without Obstacles” conferred by the “We Are Seen”

Foundation in the 9th edition of the contest for ensuring that its website is accessible

to people with disabilities. The Bank received an award in the TOP CDR contest

entitled “Technologically Responsible Firm” (first place in the Digitalization

category and the public’s award) for the digitalization of services and banking without

obstacles in April 2020.

 In response to the increased need to use online services in connection with the

pandemic, the EDUPORTAL education portal was created on the Bank’s website. It is

available at https://www.bankmillennium.pl/en/firststeponline

and directly from

the main page in the Support tab. The campaign entitled “First Online Step”

encouraging people to use digital channels was formed in parallel. Short films are an

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

important part of Eduportal. They differ from the instructional films available till now

because they employ advisors who explain the core processes in a clear and accessible

manner. The presence of a live person is in particular supposed to break down barriers

when dealing with users who prefer personal contact with an advisor and who are

afraid of automatic or remote elements. The selected actors have friendly

physiognomy, a warm tenor and a calm tone of voice – they slowly explain, step-by-

step, how to use Millenet and the mobile application.

 Children’s app – in 2021 Bank Millennium made a special version of the mobile

application available to children aged 7 to 12. This app is not only a helpful gadget,

but it is also a tool to introduce children to the world of finance and use technology

safely. During activation the application recognizes the user and adapts the version

to his or her age. The children’s app supports payments by phone or BLIK. It is friendly

to the youngest users and it was designed together with them – it has a simplified

menu, children-friendly language and a made-for-children design. At the same time,

it gives parents total control over a child’s spending, special transaction limits and

the option for a child to block a card, and for the parents to block a card using their

application. The app grows with the child. After turning 13 years of age the version

of the app installed in the birthday child’s phone automatically changes to the

currently available version for people up to 18 years of age offering a greater number

of services.

 ATMs and deposit machines – disabled people with movement impairments can use

the numeric keypad instead of function buttons next to the screen, which means that

they do not have to reach too high. In addition, ATM’s number keypad makes it easier

to use the device also by disabled people with vision impairments. After headphones

are connected to the ATM, the user may enter instructions through voice messages.

Additionally, persons with vision impairments may use a special black and white

screen mode to enhance contrast and the legibility of displayed messages. 100% of

Bank Millennium’s own ATMs are customized to meet the needs of people with

disabilities. The network of deposit machines was extended by another 107 machines

in July (deposit functions were launched in Euronet’s ATMs located in Bank

Millennium’s outlets).

 Access to outlets with architectural barriers – nearly 70% of the Bank’s branches are

accessible to people with disabilities. When modifying and upgrading its branches,

the Bank pays attention to eliminating architectural barriers.

 Customer service desks with seating offering wheelchair access are in place in all of

our outlets, while in 190 branches (roughly 46%) this also applies to cash handling

services.

 Service over the phone – clients using the Bank’s Hotline can use the voice command

feature during the call instead of using the phone’s keypad.

 Easier signing of agreements – blind or visually impaired persons or people who

cannot read can still sign an agreement with the Bank on their own in the presence

of two employees of the outlet and – upon the client’s express wish – a witness the

client considers to be a trusted individual. In such cases, an outlet employee can also

read the agreement aloud and/or in the case of customers who cannot write, they

can sign using an ink fingerprint.

 Clients with special needs have the right to receive the general terms and

conditions of agreements and bylaws in forms that make it easier for them to

familiarize themselves with their contents, e.g.: a document prepared using a large

font size, an audio file or a file prepared in the Braille language.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

 Service standards for persons with disabilities – detailed guidelines which are

binding on the employees of all of the Bank’s outlets.

 The Bank is also extending the idea of a world without barriers to other areas in which

it is active, i.e. in patronage of culture. During Millennium Docs Against Gravity,

Poland’s largest documentary film festival, cinema films were available with audio

description to make it easier for people with vision impairments to access the

world of culture.

Bank representatives also participate in the work of the Polish Bank Association to enhance the

accessibility of sites and services to people with disabilities.

Accessibility of the Bank’s

services

2021 2020 2019 2018 2017

Number of outlets 440 477 602** 361 355

% of outlets accessible to

persons with disabilities

70% 67% 63%** 72% 91%

Number of franchise

outlets*

215 225

not

applicable

not

applicable

not

applicable

% of franchise outlets

accessible to persons with

disabilities

40% 39%

not

applicable

not

applicable

not

applicable

Number of ATMs 480 479 498 487 483

% ATMs accessible to

persons with disabilities

100% 100% 100% 100% 100%

* The franchise network has been operating within Bank Millennium’s structures for the entire year

since 2020 (in previous years it operated within the former Euro Bank)

** Total data for Bank Millennium and the former Euro Bank, the decline in the number of

accessible branches stems from the merger with Euro Bank (data net of the franchise network).

[GRI FS13] Access to financial services in low-populated or economically disadvantaged areas

Access to financial services in low-

populated or economically disadvantaged

areas

2021 2020 Change

Total number of points of access to financial

services (total number of own outlets,

franchise outlets and sales islands in shopping

centres)

655 702 -7%

Number of points of access to financial

services in low-populated* or economically

disadvantaged areas**

217 228 -5%

Percentage of the number of access points in

low-populated or economically disadvantaged

areas

33% 34% -1 pp

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

* The voivodships with the lowest population density in Poland according to GUS data are as

follows: Podlaskie, Warmińsko-mazurskie, Lubuskie, Zachodniopomorskie, Lubelskie, Opolskie and

Świętokrzyskie

** The voivodships with the lowest economic activity in Poland according to the Bank’s Local Data,

are as follows: Lubuskie, Opolskie, Podlaskie, Pomorskie, Warmińsko-mazurskie,

Zachodniopomorskie, Świętokrzyskie

3.1.3. SERVICE AND SUPPORT FOR CLIENTS IN THE COVID-19

PANDEMIC SECOND YEAR

In 2021 the Bank made a number of new electronic banking solutions available as described above to

support the idea of safe banking from home and it actively educated clients on how to take advantage

of online banking services. The digital exchange of documents substantially reduces the number of

meetings needed to exchange documents with clients in Corporate Banking, too.

Branches serve clients while observing the sanitary guidelines in force. The Bank’s branches employ

safeguards in the form of shields and personal protection equipment.

Since the very beginning of the pandemic, the Bank has taken part in the distribution of public aid

programs, dealing with individual and corporate clients with the same care and attention. In 2021 the

Bank along with the entire banking sector supported the aid program under the Financial Shield 2.0

by making available the process of applying for grants and the process of submitting declarations on

the settlement of grants.

The Bank ensures a safe work environment for its employees. The measures undertaken in connection

with the pandemic, including a special employee support fund are described in the sub-section

entitled “Measures continued in connection with the COVID-19 pandemic”.

In April 2020 the Bank Millennium Foundation and Bank Millennium joined the battle against

coronavirus by endowing the amount of PLN 500,000 to the Institute of Bioorganic Chemistry of the

Polish Academy of Sciences which designed the first Polish tests to detect the presence of SARS-CoV-

2. More information on this subject can be found in the section referred to above.

The program #słuchaMYwspieraMY (#WElistenWEsupport) is our response to the needs of local

communities and clients ensuing, among other things, from the circumstances related to the

pandemic. Information regarding this program can be found in the sub-section “Charitable campaigns

and employee volunteerism”.

Financing backed with a guarantee from Bank Gospodarstwa Krajowego according to Covid rules

In collaboration with Bank Gospodarstwa Krajowego Bank Millennium ran three guarantee programs

in 2021 to secure loans extended to companies: de minimis guarantee, liquidity guarantee under the

Liquidity Guarantee Fund and Biznesmax guarantee.

De minimis guarantees are designated for small and medium enterprises. This program functioned

throughout 2021 according to modified rules to make it easy for companies to obtain access to credit

and amortize it - the term of the guarantee was extended, the cap was raised, the commission paid

to BGK for granting a guarantee was suspended and it became possible to secure loan amortization in

a foreign currency using the guarantee.

The Biznesmax Guarantee Program in the formula in force in the Bank pertains chiefly to financing

companies focused on carrying out environmentally-friendly projects and is described in the sub-

section entitled “Environmentally-friendly products and responsible financing”.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

We also continue to pursue the FGP Liquidity Guarantee Program launched in 2020. It forms an

element of the government’s anti-crisis shield. Its purpose is to support the financial liquidity of

medium and large economic entities. These guarantees secure up to 80% of the loan principal with a

maximum guarantee amount of PLN 200 million.

The FGP Liquidity Guarantee Program and the more favourable terms and conditions of the de minimis

and Biznesmax programs will be in place at least until 30 June 2022.

Millennium Leasing was one of the first companies in Poland to join BGK’s guarantee program for lease

transactions to increase the accessibility of financing during the pandemic for clients in the SME

segment.

3.1.4. TOP QUALITY CUSTOMER SERVICE

The customer service quality is one of Bank Millennium’s fundamental values. The distinct nature of

the market precipitated by the COVID-19 pandemic exerted a large impact on the Bank’s actions in

customer service and the scope and quality of products and services. The starting point was a thorough

analysis of market trends and clients’ new expectations and their approach to banking. By constantly

monitoring clients’ needs Bank Millennium effectively customizes its solutions to the rapidly changing

market.

For Bank Millennium 2021 was a period in which it continued to ramp up the accessibility of services

in its remote channels in terms of communication and the ability to execute transactions. Bank

Millennium focused on strengthening its capabilities in terms of client self-service while

simultaneously providing support to employees. The Bank combines modern banking methods

effectively and in line with clients’ needs through its mobile application and transaction system with

constant access to its highly qualified of branch advisors and telephone consultants in all its lines of

business. The rapid growth of service provided by remote advisors, also for affluent clients,

augmented convenience in access to the Bank’s products and services.

Another challenge affecting the improvement of client service in remote channels was the integration

of contact channels and even greater flow of information about client needs. The solutions developed

to accommodate service in branches and remote service make it possible for clients to switch between

service channels seamlessly and execute transactions, including ones started in some other contact

channel in a way that is convenient for clients. Augmenting flexibility and conveniently switching

contact channels give clients the feeling of consistent service, and thereby doing their banking

comfortably.

Bank Millennium has made dynamic efforts to enhance client satisfaction – not only in terms of direct

service but also in terms of the transparency of communication and simplifying the language used.

Bank Millennium’s signing of the “Declaration on the Plain Language Standard” generated an impulse

for the institution to do more work on improving quality by simplifying communication – externally

and internally.

Building processes and solutions based on clients’ perspective translates into loyalty, satisfaction and

a positive banking experience. According to the results of the internal customer satisfaction survey,

94% of retail clients were satisfied with their cooperation with Millennium, while the level of

recommendations given by retail clients held steady - the NPS score in 2021 was 51.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Bank Millennium is one of the very top rated banks in Poland in terms of satisfaction, loyalty and its

NPS score, as has been confirmed by the Client Satisfaction Monitor research performed by ARC Rynek

i Opinia and the NPS benchmark survey performed by Kantar.

The quality-focused actions taken by the Bank have garnered appreciation in one of the most

prestigious customer service rankings – “Newsweek’s Friendly Bank”. Bank Millennium took first place

in the category “Every One’s Bank” and second place in the category “Remote Banking”. Bank

Millennium was on the podium in the main category “Golden Bank – the best multichannel service

quality” in the “Golden Banker” plebiscite in 2021.

3.1.5. CUSTOMER SERVICE STANDARDS

Bank Millennium has uniform client service standards across all of its contact channels. They are

customized to the type of unit, the tasks fulfilled and the adopted business model. Standards are

available for employees of outlets, teams providing services to Prestige Clients, Corporate Banking

Clients, teams dedicated to the Hotline, electronic communication, the unit handling client

complaints and employees of the Bank’s Head Office. All guidelines are discussed in detail during

preliminary training and exercised in practice.

The Bank has implemented a new model to open accounts and start relationships with clients in

outlets. This solution makes it possible to preserve balance between clients’ needs and business

targets and the approach to digitalization. The service model has been designed on the basis of surveys

and tests with clients using design thinking, creative techniques and behavioural economics.

The Client Service Standards in force in the Bank’s outlets and hotline are the basis for the scripts

functioning in the Bank for talking with clients about various product groups:

 daily banking (personal account and accompanying products)

 credit products

 savings and investment products

Client Service Standards provide specific guidelines of conduct on how to greet/say goodbye to

clients, talk to clients, present the Bank’s products, clarify doubts and handle clients’ complaints.

In the Bank’s outlets and the Hotline, the Client Services Standards are augmented and supplemented

by Client Call Scripts regarding various products: personal accounts and accompanying products,

credit products and savings and investment products. They define the framework of calls with clients

on the Bank’s products. These scripts refer to specific parts of client service, procedural and

regulatory duties. The service standards are to limit the risk of unethical sales and providing clients

with insufficient information. In 2021 sanitary risk was an additional risk connected to the

prevailing COVID-19 pandemic. Outlet employees received detailed guidelines (verified in

accordance with the current recommendations given by the Ministry of Health) on how to mitigate

the risk of becoming infected with the virus.

3.1.6. RECOGNIZING CLIENT EXPECTATIONS

Recognizing clients’ expectations is always the first part of each and every project in Bank

Millennium. The outcome of this approach is verifying, and then modifying a process, product,

communication or client service model. Regularly performing this activity makes it possible to

maintain the quality of service at the highest possible level in every service channel and observe

trends on the financial services market.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Another important part of analysis is researching and recognizing the causes of clients’ specific

expectations and the impact exerted by the current social situation on their needs. The devised

solutions are tested with clients and employees before implementation.

In 2021 Bank Millennium conducted quantitative and qualitative research on market trends and

specific product and service assumptions. Projects employing Service Design methodology in which

fully understanding clients’ needs is crucial also provided inputs. These projects contributed to

streamlining service quality and developing the product offering.

Just as in previous years, this research was conducted using samples of retail, corporate and affluent

(Prestige) clients and microbusinesses (Small Business).

Satisfaction and the level of recommendations among retail clients remained very high, with an

NPS score in 2021 of 51 and 94% satisfied clients.

Bank

Millennium

2021 2020 2019 2018 2017 2016

NPS ratio*

51 53 53 51 51 39

*indicates the willingness to recommend the products and services to clients. The presented data

refer to the Bank’s internal research and pertain to retail clients.

The Bank also conducted research into the satisfaction of corporate clients. This research

demonstrated that the upward trend in satisfaction has also been maintained during the pandemic

(NPS rose to 49).

Incoming calls to the hotline are monitored in Millennium Leasing making it possible to analyze

telephone traffic and the reasons for which clients are calling. A survey was performed in the hotline

in connection with cooperation with Bank Millennium in 2021. Clients could share their feelings or

remarks directly after their call with a hotline consultant. The compiled responses are analyzed and

on their basis actions are taken to modify and improve the elements designated by clients. The

company also conducted two surveys by phone with clients in 2021 during which it asked about they

think is important in their ongoing cooperation and after-sales service (which also pertained to the e-

customer service point). The responses in both surveys were analyzed and on the basis of the compiled

information, a plan was prepared to introduce changes in the areas identified by clients in these

surveys.

3.1.7. COMPLAINTS MANAGEMENT

The Bank’s aim is to build a positive client experience and increase client service satisfaction during

the complaint handling process. The documents governing the issues related to complaints are the

product rules and the “Complaints Handling Instructions”. The results of this policy are visible, inter

alia in the streamlining of complaints handling processes, the shortening of the time to examine

cases and the empowering of employees who have been trained on the rules of plain

Quality and satisfaction

Survey

Bank Millennium

2021 2020 2019 2018 2017 2016

Surveys conducted 56 47 25 27 21 24

Number of Mystery

Shopping visits

3,854 3,059 2,768 3,500 4,065 3,900

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

communication with clients. [GRI 102-15] To mitigate reputational, legal and financial risks, the Bank

has implemented internal regulations aimed at ensuring full compliance with the Act on complaint

examination by financial market entities and on the Financial Ombudsman and the Payment Services

Act.

Clients may submit complaints through many channels: in the branch, by phone, through electronic

banking and by mail. Highly active clients are invited to participate in tests and issue opinions on

newly created products and systemic solutions. All of the problems raised by clients are analyzed.

The conclusions drawn from analyzing complaints and client suggestions are taken into consideration

when streamlining products and services. In 2021, under the program for eliminating the causes of

VOC (Voice of Customer) complaints, 172 smaller and larger initiatives were launched - 117 initiatives

were implemented, 22 were rejected following analysis while the other ones are still undergoing

implementation.

Multiple actions were taken to streamline the complaints handling process to shorten the time for

examining complaints and increase the level of client satisfaction:

 Roboticization was used to handle recurring operational tasks. Several robots are active in

this process. Their activity is monitored and developed on an ongoing basis. Work is underway

on implementing additional ones.

 The Bank continued to pursue monthly client satisfaction monitoring in respect of the

complaints handling process and the Close the Loop process, in other words, analysis and

contacts with clients who negatively assessed this process. In that way it is possible to track

the client satisfaction level on an ongoing basis, analyze the reasons for satisfaction or

dissatisfaction and take actions to augment client satisfaction.

 The project “Embrace the Problem” is ongoing. Its purpose is to support employees who are

directly involved in client service as they solve clients’ problems by advising them of the most

frequent cases and the need to accept justified and complete notifications.

 System-generated messages for branch and Contact Centre employees are still being used and

developed. They show how to solve client problems properly and to which department a given

request / inquiry should be directed. This makes it possible to shorten waiting time and avoid

notifications erroneously recorded as complaints.

 In 2021 a project called “Direction towards Quality” was established. The project’s main

assumptions are as follows:

 Regular e-mail education for employees of the Client Relations Department who are

responsible for examining client complaints.

 Regular workshops on plain language - employee skills in writing in plain language are

constantly being refined. In 2021 the Bank cooperated with a plain language expert

from the Plain Polish Workshop and trained plain language consultants. Another series

of training sessions was conducted on the rules of plain language for employees in the

Client Relations Department.

 The monthly qualitative evaluation of responses to complaints – the Bank evaluates

texts in the following terms:

 the merits and the solution of clients’ problems

 the structure of the information (visual transparency)

 crafting sentences in accordance with the rules of plain language

 maintaining relations.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

• In 2021 the Bank has devised and implemented a number of improvements in the application

to review complaints to enhance the effectiveness of complaints handling. They help preserve

the binding standards in respect of the timeliness of examining complaints and procuring a

high standard of replies. The largest change was implemented in May 2021 and it pertained

to preparing replies to complaints. At present, employees can prepare and edit replies

regardless of the channel of response directly in the application in which complaints are

examined. It contains a database of response templates which every employee can use. This

database is constantly being developed to include new content, which is vetted by plain

language consultants.

• The implementation of monitoring and reporting tools to control better the quality of the

process, its timeliness and efficiency.

• Implementing a reporting centre to share knowledge about the opinions and claims of clients

with the overall Bank and the owners of products and processes.

• Implementing a new motivation system combining employee evaluation and motivation in

both aspects: productivity and quality development.

• By devising the rules for cooperation between different units in the Bank the information

coming from complaints is used to streamline products and processes and prevent prospective

grievances.

Complaint reports are forwarded to the people responsible for individual products and processes. This

allows the Bank to analyze the quality of services it offers on an ongoing basis and take optimization

measures. A broad range of ratios in the complaints area is reported, while the effects of the entire

complaints handling process are presented regularly at the Process and Operational Risk Committee

meetings and also at the meetings of the Supervisory Board Audit Committee.

Client satisfaction

with the complaints

handling process in

the Bank

2021 2020 2019 2018 2017 2016

Clients satisfied and

very satisfied with

the complaint process

82% 79%

This research

was not

conducted*

85% 76% 77%

*on account of the operational merger with Euro Bank

Complaints filed*

2021 2020 2019 2018 2017

Number of

complaints filed

100,873 113,182** 91,682** 70,707 44,493

Number and % of

complaints handled

in favour of

customers

75,403

(74%)

86,619

(76%)

65,488

(71%)

52,507

(74%)

30,315

(68%)

* complaints reviewed by Bank Millennium

** the increase in the number of complaints was related, among other things, to the combination of

the complaint portfolios of Bank Millennium and Euro Bank, migration of clients’ data and the

dynamic growth in customer numbers. 2021 data as of 10 January 2022

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Group companies manage complaints on their own. Millennium Leasing has in place the procedure

for submitting and reviewing complaints submitted by the clients. Millennium Towarzystwo Funduszy

Inwestycyjnych (TFI, investment fund management company) offers its products through distributors

of units and does not have direct contact with clients. Clients’ complaints are submitted to Millennium

TFI and distributors alike. The Bank reviews complaints related to client service provided by its

employees. When it comes to the quality of products offered by Millennium TFI, complaints are

handled under an engagement from the TFI by the transfer agent who keeps registers of participants

and executes transactions pertaining to units. In the Brokerage House, complaints are handled jointly

with the Bank when they pertained to the services rendered by Bank Millennium as an Agent of

Millennium DM.

3.1.8. CYBERSECURITY

The Millenet internet banking system and Bank Millennium’s mobile application were designed in such

a way that they are not only very convenient to use but also very safe.

Certificates and encrypted connections

The usage of encrypted data transmission between the client’s computer and the Bank’s server ensure

the safety of Millenet internet banking. Transmission is secured with a 128-bit SSL protocol. Bank

Millennium employs the GeoTrust True BusinessID SSL certificate issued by GeoTrust, which specializes

in data encryption and protection. This security ensures data protection against interception by

undesirable persons. This certificate also guarantees that the login page belongs to the institution to

which it was issued. The internet connection with a phone is also encrypted.

Every PDF document downloaded from Millenet is signed with Bank Millennium’s safety certificate.

That makes it possible to track with ease whether anyone has altered its contents after signing.

Every document placed in Millenet in the section “Information on changes” has a unique checksum (a

cryptographic hash function using SHA 256). Any change to a document triggers a change in the

checksum. Documents containing a checksum are signed using an electronic certificate that utilizes

a time stamp.

Bank Millennium uses four different certificates to sign PDF documents. All of them are characterized

by an identical parameter “O” (Organization) Bank Millennium S.A. and a list of attributes that, when

they appear together, form the unique data of a given electronic signature.

Certificates used by Bank Millennium:

• Confirmation of integrity issued by Certum Digital Identification CA SHA2

• Bank Millennium S.A. issued by Certum Digital Identification CA SHA2

• Bank Millennium S.A. (OU Bank Millennium S.A.) issued by Entrust Class 3 Client CA - SHA256

• Bank Millennium S.A. (OU Confirmation of integrity) issued by Entrust Class 3 Client CA -

SHA256

Logging into an account

To log into Millenet several data known only by a given client must be provided: the login, password

and selected characters from an identification number. Moreover, once every 90 days we ask clients

for additional confirmation of their login using a password by SMS. Clients may also choose a safety

icon related to their login. This icon makes it possible to determine whether the client is logging into

the Bank’s website or to a deceptively similar site copied by criminals.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Before a client starts to use the mobile application, it must be activated. The activation process

includes entering the pertinent data known only to a given client and confirmation through an IVR

connection. During the activation process the application is assigned to a given device. That is why

clients must repeat the activation process every time they switch to a new device.

Logging into the application is secured using a 4-digit PIN code which clients select on their own. It is

also possible to log in use biometric data if a device supports that option (thumb print, face scan).

If a client loses his or her handset with the installed application, he or she can rapidly block the

mobile application in Millenet or through the hotline. After a short period of inactivity, clients are

automatically logged out of Millenet and from the mobile application.

Payment safeguards

Wire transfers and payments submitted in electronic banking or using online cards must be authorized.

1) 3-D Secure is an additional safeguard for internet transactions executed using a card, e.g. in

online shops. It protects the identity of the buyer and transaction-related data. Clients

additionally confirm payments in stores bearing the logo Visa Secure or Mastercard Identity

Check using an SMS password or by logging into the mobile application.

2) SMS passwords - are non-recurring free codes which we send to the client’s phone number.

The code in the SMS should be keyed into the designated spot in the payment form and

approved by clicking on it.

3) Mobile Authorization - is a method of approving transactions submitted in Millenet in the

mobile application and some transactions submitted in outlets. To utilize this form of

confirmation clients must have an active application.

4) Confirmation of a wire transfer in the application - clients confirm wire transfers submitted

in the application not by using the PIN number to the application but by using the password

to log into Millenet.

5) Confirmation using the PIN number to the application - some operations submitted in the

application require confirmation using the PIN number, e.g. mobile BLIK payments.

Daily transaction limits afford additional protection. Limits can be customized in the settings in

Millenet or in the mobile application.

It is also possible at any time to block a card temporarily or permanently in Millenet or the mobile

application. Clients do not have to wait for a connection to the hotline or for an outlet to open.

3.1.9. INITIATIVES TO ENHANCE CLIENTS’ FINANCIAL AWARENESS

EDUCATION ON SAFE ONLINE BANKING

[GRI FS16] The problem of fraud or embezzlement in which bank clients are the injured parties pertains

to the entire banking sector in Poland and across the globe. Since client awareness is of key

significance in each such case in terms of safely using online financial services, banks, and that

includes Bank Millennium, intensively educate their clients in collaboration with the Polish Bank

Association and unilaterally, reminding clients about the online risks they face and the need to comply

with security rules. Bank Millennium publishes security warnings and recommendations on the rules

of safety on its website. Whenever the Bank obtains information about a new method of fraud, it

promptly sends out the pertinent warnings to clients describing the method of operation applied by

criminals and explaining how to avoid the threat in question. Bank Millennium also pursues many

preventive measures and responds to every signal that may be an attempt at deceptively obtaining

client information or funds.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The number of fraudulent attempts using electronic channels has grown markedly since the outset of

the pandemic. From that time we have strengthened our communication by adding educational

content for clients, we have refreshed the website regarding safe banking on the Bank’s portal (we

also published a series of educational film clips on the safety of payments and cybersecurity to make

the message more attractive

) and we expanded the topical section in the mobile application.

Educational campaigns for clients are delivered using various channels:

• banners on a portal, in the mobile application and Millenet,

• PUSH messages in the mobile application,

• messages in the contact box available from Millenet and the application,

• SMS to clients who are less active in electronic channels.

Campaigns are refreshed regularly and the communication is additionally strengthened whenever new

operational methods employed by perpetrators of fraud are observed or their attacks on clients grow

more intense. Communication plans and content are created as a result of cooperation between

several departments, chiefly the Security Department, the Electronic Banking Department, the

Quality Department and the Client Knowledge Department. Campaigns target clients in general and

selected groups based on risk profiles. These campaigns enjoy extensive client interest that is growing

from month to month.

Clients may use a dedicated hotline run by a specialized team of consultants. Safety issues are also

discussed in other contexts, e.g. when establishing a relationship with a new client.

The Bank organized a training webinar for the employees of financial departments in local government

entities in December 2021. It was devoted to best practices to raise the safety of digital processes

and the methods of counteracting fraudulent attempts. The Bank’s experts on transaction banking

and the risk of fraud based on examples of the methods used by criminals showed how to identify

attempts at fraud to avoid financial losses.

OTHER EDUCATIONAL ACTIVITIES TARGETING CLIENTS

Corporate Banking clients

Bank Millennium supports clients through its educational activities and the distribution of information

regarding important changes affecting how business is done. The Bank publishes a monthly bulletin

presenting macroeconomic information, discussing tax changes and describing new product and

system-related solutions to support clients. The other educational activities focused on two

communities supported by the Bank: chief financial officers and family companies. The Bank’s experts

appeared during direct and online meetings of the CFO Club to share knowledge about tax changes,

legal regulations regarding sustainable development, the impact of macroeconomic changes on

business development and the soft skills needed by a CFO. In turn, meetings held with the Family

Companies Forum were an opportunity for the Bank’s experts to share their experience in client

analytics and building client experience in digital channels.

Individual clients

In 2021, 12 regular webinars were held for Prestige/Private segment clients and a selected group of

Retail segment clients. These were meetings on investment issues (market, current events) and

providing information about the Bank's products and services. The events were also attended by

experts who introduced the participants to the principles of safe banking, market trends,

technological innovations, environmental and economic topics.

The Bank is systematically expanding the group of clients targeted by online meetings. In December

Bank Millennium together with Millennium TFI organized a webinar for Retail clients - the main topic

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

was inflation and ways to protect against its impact on the value of savings. In addition, Millennium

TFI regularly publishes podcasts about key market trends.

3.2. RESPONSIBLE ADVERTISING AND SALES

3.2.1. RELIABLE MARKETING COMMUNICATION

[GRI 103-1,103-2, 103-3, 417-1] In the process of developing marketing communication we adhere to the

following principles: Bank Millennium's advertisements are not misleading and show the important

features of the products and services and related benefits and costs. They also depict their legal

nature and provide information about the level of possible risk carried by the client. If the message

pertains to a promotional offer, its conditions are specified. Clients are also advised on where they

can obtain detailed information regarding a given promotion.

Any change or introduction of a document or marketing material for buyers of respective products is

preceded by consultations within the Bank, verification by the legal, compliance, marketing

communication and product teams, in order to provide clients with a clear and reliable, legally-

required information about the products offered. Implementation of the marketing communication

standards reduces the reputation risk and the risk of sanctions for non-compliance with the

regulations.

Marketing materials prepared by Bank Millennium are compliant with the laws and regulations

applicable to this area, including in particular:

 the Recommendations laid down by the Code of Ethics in Advertising devised by the SAR

Marketing Communication Association,

 the Principles for Advertising of Banking Services of 2008 laid down by the Polish Financial

Supervision Authority,

 the Best Practices on consumer loans advertising standards of the Polish Bank Association of

2015,

 Provisions of the amended Consumer Credit Act of 22 October 2017,

 Mortgage Loan and Supervision of Mortgage Loan Intermediaries and Agents Act,

 Act on Trading in Financial Instruments,

 Internal instructions applicable to devising of informational and advertising materials for

banking products and services in Bank Millennium as well as the rules for devising commercial

publications for the financial products and instruments in Bank Millennium.

Millennium TFI advertises products solely on its website and through distributors of units. The method

of advertising products complies with the provisions of law regulating the operation of investment

funds and investment fund management companies and the guidelines of the Polish Financial

Supervision Authority. To the extent to which product advertising is not subject to detailed

regulations TFI submits to the standards of the Bank Millennium Group, including standards of ethics

and it does not use messages that are forbidden by law in its advertising.

TFI has adopted for application the Corporate Governance Principles for Supervised Institutions and

it strives to adhere to them in reference to practices pertaining to advertising messages. TFI submits

to the standards of the Bank Millennium Group in all other aspects.

Millennium Dom Maklerski advertises products on its website and through its agent (Bank Millennium).

Standards of advertising ethics are contained in appropriate internal regulations of Millennium Dom

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Maklerski specifying requirements to be met by all communication directed by a brokerage house to

clients and prospective clients, disseminated for the purpose of advertising or promotion of provided

services. In this respect Millennium Dom Maklerski applies the standards following from the Code of

Best Practices of Brokerage Houses.

[GRI 417-3] In 2021, there were no cases of non-compliance by Bank Millennium, Millennium TFI,

Millennium Dom Maklerski, Millennium Leasing and Millennium Bank Hipoteczny with regulations

relating to marketing communications. As a result of the administrative proceedings launched by the

Voivodship Pharmaceutical Inspectorate in Gdańsk, a fine of PLN 5,000 was imposed on the company

doing business as Millennium Goodie. The Inspectorate found that the website goodie.pl, which

presents discount offers for many different brands engaged in an illegal advertisement of pharmacies

whereby information containing discount codes and the promotions of two pharmacy networks along

with links redirecting people to the websites of these pharmacies was placed there. Millennium Goodie

stopped the advertising immediately after the Inspectorate launched the proceedings.

3.2.2. TRANSPARENT INFORMATION ABOUT PRODUCTS AND SERVICES

The Bank provides clients with clear and understandable product information through its employees,

in sales channels and client service channels such as outlets and the hotline, and in the form of text

messages in electronic channels. All the employees who provide clients with information are properly

trained in the scope required by the law, sectoral regulations, best practices and quality standards

implemented by the Bank. Bank employees are informed on an ongoing basis about any significant

changes in sales and client service, which is done through the Bank’s various internal communication

channels. The product sales process is executed on the basis of standardized models making it possible

to present an offer to clients that is adjusted to their needs and expectations with options that

may be of interest to them, along with the information necessary to make an informed decision about

the scope of the given product purchased. The observance of sales standards and the scope and quality

of information provided to clients are evaluated on a regular basis through Mystery Shopper surveys

and as part of client satisfaction surveys. The selling and client service method is also verified and

improved using topics of inquiries and complaints received from clients.

Informing about bank accounts

One of the fundamental goals is to find the right match between the offer and the needs of every

client. The Bank strives to ensure that offers / services are presented after an in-depth needs analysis

and meet the expectations of clients, while being fully comprehensible and transparent to them. In

the process of opening an account and initiating a relationship with a client, employees use aids that

are prepared in an attractive format, are highly transparent and feature clear and comprehensible

language for the purpose of communication. These materials have been developed on the basis of in-

depth research and interviews with clients and are used to diagnose client needs correctly and

optimally and adapt the sales pitch accordingly.

Every person visiting the website may obtain detailed information about the offering and the services

recommended by the Bank depending on the client’s current needs. There is also a hotline available

to clients 24 hours a day and 7 days a week.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of personal accounts, nor were

there any consumer boycotts.

Informing about savings products

Information on savings products in the form of a set of the most important attributes or in more

detail, while paying attention to the constituent elements of given products may be found on the

Bank’s website, may be obtained in any branch, through the hotline or in electronic banking channels.

The Bank regularly improves the method of presenting product information, especially in its remote

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

channels. Employees are trained in such a manner so as to be able to convey a given scope of

information on every product, including a uniform information document on the scope of savings

products in which one can easily and readily compare the attributes of all products. The Bank also

analyses clients’ questions and complaints to eliminate their causes.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of savings accounts, nor were there

any consumer boycotts.

Informing about investment products

Marketing materials prepared by the Bank comply with the laws and regulations applicable to this

area, including the Canon of Best Financial Market Practices and the guidelines laid down by the Polish

Financial Supervision Authority. Bank Millennium tracks and modifies materials on an ongoing basis to

meet the recommendations of the Polish Financial Supervision Authority. Trade publications are

subject to review by legal and compliance teams, among others. These units are responsible for

ensuring that materials are in compliance with the law and with the guidelines of supervisory

authorities.

In addition, prior to purchasing an investment product, clients fill out an Investment Survey. Its

purpose, among other things, is to verify a client’s knowledge and experience regarding financial

instruments and services and check whether a client belongs to the target group of recipients of a

specific instrument or service.

Based on the responses provided, the client receives the Investment Survey result with information

about the financial instruments and services for which the client is part of the target group and which

of them are suitable or unsuitable to that client. In accordance with prevailing laws, the Bank does

not apply limitations on the sales of investment products to specific groups of people.

Any proposal to start offering a new product is commented upon at several levels; opinions are issued

among others by the risk, compliance and legal units. Participation of those entities in the opining

process allows the Bank to assess whether:

 the identified material risks and their mitigation methods arising in connection with the

launch or change of a product/service are permissible,

 the proposed product/service complies with the requirements concerning: provision of

relevant information to potential clients before the agreement is signed, fulfilment of

information obligations during the provision of the financial service, identification of

conflicts of interest in order to take prior measures to prevent their occurrence, reliability

and completeness of information provided,

 the proposed product/service complies with the applicable law and assessment of legal risks.

Security of investments

The Bank complies with the requirements of the MiFID 2 directive (Markets in Financial Instruments

Directive). In accordance with the requirements of MiFID 2, the Bank, by offering investment services,

is obligated before the purchase of a product, in particular:

 to classify the client to one of the three categories of investors,

 to carry out an Investment Survey, which is designed to test the client's knowledge and

experience with individual financial instruments or services, as well as to check whether the

client belongs to the target group of recipients of a specific financial instrument or service,

 to provide reliable information that is not misleading about products and risks associated with

investments in those products as well as all the related costs,

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

 to develop a policy of acting in accordance with the best interests of its clients and a policy

to prevent the conflict of interest and inform the client about these policies.

To ensure the best possible protection level to its customers, the Bank applies some MiFID 2 guidelines

also to insurance and investment products, even though this is not legally required.

All the marketing publications prepared by the Bank describe, among others, the risks associated

with investments and sample scenarios related to a given financial instrument or product. Clients

are presented with complete and reliable information on the Bank's own products and products

distributed by the Bank, including their issuers and the terms of the complaint process. Information

on services rendered, agreements and other bank documents and letters sent to clients are drafted

in a precise, comprehensible and transparent manner.

[GRI 417-1] Any information materials concerning investment products offered by Bank Millennium

provide relevant information on the risk associated with investment, legal disclaimers as well as the

sites where additional information on the funds (for example on funds or selected financial data) is

published.

If a client wants to purchase a product the Bank considers to be unsuitable or if the Bank does not

have the ability to assess a given product, the Bank advises the client thereof by issuing a warning to

the client during the process of submitting the order. The client also receives this warning on the

order form. The client is obligated to review the warning and if the client still wants to buy the

product, the client is obligated to accept it. Similar rules apply to the target group evaluation process.

Before starting to offer investment products, the relationship manager should have at least twelve

months of professional experience in this area and have passed a product knowledge test. Each

relationship manager must also undergo mandatory training on the MiFID 2 and a product training in

the e-learning form. The product training describes detailed characteristics of a given product and

clearly points to the risks associated with investments in a given product or financial instrument. If

the relationship manager does not have the required level of experience or knowledge, he/she works

under the supervision of the so-called authorized employee who regularly verifies his/her work.

If the law or internal regulations governing investment products change, e-learning refresher

training is made available to relationship managers. As a result, the employees have adequate and

current knowledge of the investment products offered. Additionally, relationship managers take

advantage of regular market and product conference calls. The Bank’s employees also have

permanent access to current product presentations.

[GRI 419-1] In 2021 no penalties were imposed on the Bank for non-compliance, nor were there any

consumer boycotts concerning the investment products offered by the Bank.

Informing about mortgage products

A client filing a loan application will receive full information about the product and the associated

risks from an employee at each stage of the process. In 2021 the Bank delivered preliminary online

training and webinars on a major scale pertaining to product structure and the lending process to

remind them in a clear, accurate and transparent manner on how to convey product details to clients

and select the best offer for them. Approximately 3,500 mortgage experts were trained in the

brokerage network in 2021. Preliminary and typical product training sessions were held. The webinar

training sessions aimed, among other things, to promote innovative solutions relating to processes

and products among the experts cooperating with the Bank. In 2021 nearly 600 employees of the Bank

Millennium branches underwent specialist training on mortgage products on different levels of

sophistication in preparations for “Mortgage Certification”. During the first round of certification

more than 100 managers in the Bank’s branches tested their knowledge in the certification exam and

their mortgage skills confirmed by their sales results, thereby obtaining a Mortgage Certificate.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of mortgage products being

currently offered, nor were there any consumer boycotts. The legal issues connected with Swiss franc

mortgage loans are described on p. 87.

Informing about consumer loans

Before the purchase of a product, the Bank investigates the client’s needs and helps to establish the

client’s financial standing and thus adjust the manner of communication and offer a suitable product.

The risk of over-indebtedness and household budget mismanagement is minimized owing to advanced

methods of assessing clients’ creditworthiness and capabilities used by the Bank. The Bank may offer

to its clients the opportunity to consolidate the debt repaid to other lenders, which often allows them

to reduce their monthly credit charges in the household budget and improve their financial security.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of consumer loans, nor were there

any consumer boycotts.

Informing about insurance products

Information regarding insurance products is presented by the Bank in a manner customized to the

sales channel for a given product, orally or at the various stages of the sales process in remote

channels. This information is also set forth in the insurance documentation and/or banking

documentation of the bank product to which the insurance is offered. The Bank takes into

consideration the aspect of customizing insurance to clients’ needs and expectations in the process

of offering insurance.

Insurance documentation contains standardized specific provisions regarding insurance stemming

from the regulations of law and the guidelines set forth in Recommendation U concerning best

practices in bancassurance and the Insurance Distribution Act that provide for transparently

presenting products to clients.

The Bank employs the rules of ethical sales of products by providing for standards consistent with the

guidelines set forth in Recommendation U concerning best practices in bancassurance and the

Insurance Distribution Act.

The Bank educates its employees to procure the appropriate level of quality in the process of selling

insurance products. On top of product training sessions ending with an exam to confer authorization

to commence the sales of insurance, Bank employees go through annual professional training sessions

to enhance their competences systematically in terms of performing tasks involving insurance

intermediation services. Besides legal issues much attention during training sessions is devoted to the

general rules and practical aspects of distribution activity.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of insurance products, nor were

there any consumer boycotts.

3.2.3. ETHICAL STANDARDS IN CLIENT SERVICE

[GRI 103-1, 103-2, 103-3, FS15] Activities concerning ethical sales place strong emphasis on service being

compliant with the regulatory requirements and fulfilling the following assumptions:

 Tools and guidelines in call scripts focused on giving clients the best possible service by

conveying full and precise information on various products and processes;

 Call scripts refer to the necessity of vetting client needs and analyzing products in terms of

their expectations and circumstances;

 Assumptions and tools concerning product models are subject to verification by the

compliance unit.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Implementing sales standards in sales units (including ethical sales) is achieved under the following:

preliminary training, e-learning training and post-implementation activities by the persons and units

appointed to do that (including bosses).

The guidelines set forth in the Book of Client Service Standards obligate employees to do the

following in particular: analyze client needs, present the Bank’s offering clearly, discuss the rules on

how the product works, present cost information, diagnose client doubts, provide explanations and

ultimately – confirm that the rules on how the product works are comprehensible to the client prior

to signing an agreement.

At the Bank Millennium Group, ethical sale of products is regulated not only in such guidelines as the

Code of Ethics, Book of Standards or other internal procedures. Attaching great importance to

quality and a high level of ethics in sales, the Bank also prepared Client Call Scripts about daily

banking products, credit products and savings and investment solutions. These scripts have been in

operation for several years and are updated and optimized successively. Each implementation of a

new script involves a mass implementation of the solution among direct customer service employees

and training sessions. All the changes made to the scripts centre on ensuring complete transparency

in terms of the information provided and client education so that they can benefit from the services

offered by the Bank with full awareness.

Compliance with the Scripts and Client Service Standards is constantly monitored by a unit

specially set up for this purpose, while the results are conveyed to the Bank’s Management Board

and the direct superiors of the employees subject to evaluation and are used to take remedial efforts

across the Bank. Compliance with sales standards and ethics is also monitored independently of the

Bank by using various types of service quality rankings. The Bank attaches great importance to them

and takes into account all the conclusions drawn from them.

In terms of insurance products, the Bank employs standards consistent with the guidelines set forth

in Recommendation U concerning best practices in bancassurance and the Insurance Distribution Act.

Companies have distinct regulations regarding ethical sales. Millennium Dom Maklerski has

implemented a number of documents governing the rules of conduct to maintain due diligence in

client contacts. The most important ones are as follows: the rules and regulations for rendering

brokerage services, contracts executed with clients and the “Policy of executing orders and acting in

accordance with the best interest of the Client in Millennium Dom Maklerski S.A.”

Assistance in repayment of debt

Bank Millennium offers a debt consolidation loan with an option to pay down debt in other banks to

clients who are looking for an opportunity to reduce the costs of servicing their current liabilities. In

addition, clients may take advantage of a deferred payment of one instalment of a cash or

consolidation loan (credit holidays), which represents important help in a case in which the funds

designated for an instalment in a given month must be used for other purposes.

If a loan is not repaid, the Bank first seeks an amicable settlement of the matter, offering the client

the opportunity to enter into restructuring agreements.

The debt restructuring offered by the Bank in the process of pursuing receivables involves the

execution with the client of an annex to the original agreement (in a traditional form in a Bank outlet

or through electronic contact channels) or a separate restructuring agreement whose content modifies

the binding debt repayment terms in accordance with the client's standing and financial capabilities.

The receivables are restructured and collected by organizational units in the Bank that have been

established especially for this purpose. There are separate units dealing with receivables from

corporate and retail clients (including Biznes clients, too) based on internal (instructions and

guidelines) and external regulations.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The process of pursuing receivables from retail clients is conducted while using a supporting IT system

linked to the Bank’s operating system and the credit card administrative system making it possible to

identify receivables at risk, verify and monitor them, archive actions, progress and the outcomes of

collection, dispatch key correspondence and report and manage various receivables.

3.2.4. SETTLEMENTS AND OTHER SOLUTIONS FOR FOREIGN CURRENCY

LOAN BORROWERS

For many years, Bank Millennium has been consistently following the strategy of seeking and

implementing amicable solutions to resolve problems related to mortgage loans indexed to or

denominated in Swiss francs. The solutions offered to clients are customized to their needs and are

aimed at, among others, making it easier for borrowers who repay a loan in Swiss francs to convert

the currency of the loan (i.e. change the repayment currency to Polish zloty) or repay the loan on

favorable terms and conditions. The Bank makes efforts to limit the formalities associated with these

orders to the necessary minimum.

Bank Millennium is one of the first bank to have made available settlements to foreign currency loan

borrowers on a significant scale. In 2021 as a result of the negotiations the number of active FX

mortgage loans decreased by 8,449 compared to over 57,800 active loan agreements at the end of

2020. We aim the rate of effective negotiations with our clients to be maintained over the next 12

months.

Since 5 May 2020, orders given by clients with mortgage loans indexed to or denominated in Swiss

francs (including repayment of loan installments), have been fulfilled by Bank Millennium using the

exchange rate equal to the average exchange rate of the National Bank of Poland for Swiss francs

published in Table A – Average foreign currency exchange rates.

Since January 2015, when quick increase of the Swiss franc exchange rate was recorded, Bank

Millennium has been offering special solutions comprising the so-called “six-pack”, including:

(1) Accepting a negative LIBOR rate for calculating the interest rate for mortgage loans.

(2) A significant reduction of the so called exchange rate spread, which causes a

perceivable decrease in the amount of loan installments paid by clients (replaced

with the average NBP exchange rate in 2020)

(3) At a client’s request, extension of the repayment term or temporary suspension of

loan installment repayment so that the installment amount is not higher or is only

slightly higher than before the exchange rate was freed. Such requests were only

available to the borrowers residing in the financed property.

(4) Resignation from demanding new collateral and loan insurance from borrowers who

repay loan installments on a timely basis.

(5) Allowing borrowers to convert the loan currency from CHF to PLN at the exchange

rate equal to the average exchange rate published by the NBP (standard offer).

(6) Making the rules for mortgage loan restructuring more flexible for clients residing in

the financed properties.

The borrowers who are Bank Millennium clients may also receive aid from the Borrower Support Fund

designed for the individuals, who experience financial hardships and are obligated to make

repayments of mortgage loan installments (irrespective of the loan currency) constituting a

substantial burden on the household budget.

A borrower who has been awarded such support will receive monthly funds to cover the repayment

of a loan installment. The funds are paid for a period no longer than 36 months in the amount

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

corresponding to the loan installment amount, but no more than PLN 2,000. If the amount obtained

from the sale of the real property is not sufficient for full repayment of the mortgage loan, a borrower

may receive a debt repayment loan (zero-interest form of aid) in the maximum amount of PLN 72,000.

Repayment of the aid received begins two years after the last part of the support or debt repayment

loan is paid out and is divided into 144 installments with no interest. A portion of the amount may be

forgiven, provided that repayments are made on a timely basis.

The money at the Fund’s disposal are contributed by banks and, according to information provided

by Bank Gospodarstwa Krajowego, at the end of September 2021, their balance was PLN 607.4 million.

As at 31 In December 2021, the Bank had 11,070 loan agreements and additionally 913 loan

agreements from the former Euro Bank that were the subject matter of currently pending individual

lawsuits – these figures do not include claims filed by the bank against clients, i.e. collection cases.

94% of the loan agreements are adjudicated before first instance courts and 6% before second instance

courts.

The Bank is a party to a class action lawsuit filed in 2014 seeking to establish the Bank’s liability for

unjust enrichment in connection with the concluded foreign currency mortgage loans. This is not a

lawsuit seeking any payment. A ruling in these proceedings will not award any amounts to the

members of the group. There are 3,281 loan agreements included in these proceedings. At this stage,

the composition of the group has been established and confirmed by the court. The proceedings have

entered the phase of examining the merits. In the meantime, more than 6% of the loan agreements

under this class action were subject of settlements (regarding conversion to PLN or early repayment)

between the Bank and the borrower under the settlements process above described.

[[GRI 103-1, 103-2, 103-3, GRI 206-1] A report on court cases, including proceedings related to cases of

restricting competition, can be found in the chapter entitled “Court cases” in the Annual Financial

Statements of the Capital Group of Bank Millennium S.A. for the 12-month period ended on 31

December 2021.

RESPONSIBLE EMPLOYER

Bank Millennium creates a friendly work environment for all staff regardless of their gender, age,

race, religion, nationality, ethnic origin, disability, political beliefs, trade union membership or sexual

orientation, so that everyone may thrive in conditions conducive to professional development in an

atmosphere of cooperation and mutual respect.

Bank Millennium was ranked second in the ranking of Poland’s Best Employers 2021 by Forbes and

Statista in the Banks and Financial Services category. The criteria taken into account included:

development and outlook, relations between employees and management, and sustainable

development. In 2021 Bank Millennium was also honoured with the title of Reliable Employer for the

eighth time in a row. This title is proof of the recognition shown to the Bank as a financial institution

with a stable foundation that cares about its employees.

Bank Millennium was also included in the "European Diversity Leaders 2022" ranking. In the list

published by the Financial Times, 850 employers were selected from among 15,000 employers that

support and promote diversity in their organizations. The ranking was based on feedback from 100,000

employees and human resources and recruitment experts. The research firm Statista is a substantive

partner of the project.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

3.3. HEADCOUNT STRUCTURE

At the end of 2021 the headcount in the Bank Millennium Group was 7,079 people. Most of the

employed workers were women (67%), and the average age of employees was 38. The total monthly

employee turnover rate had grown to 4% versus 3% in 2020.

[GRI 102-8] Number of employees in 2021

Men

Total men

Women

Total

women

Grand

total

<30

yrs

30-50

yrs

>50

yrs

<30

yrs

30-50

yrs

>50

yrs

Bank Millennium

Group

531 1,518 293 2,342 998 3,243 496 4,737 7,079

Bank Millennium 516 1,399 236 2,151 963 3,056 450 4,469 6,620

[GRI 102-8] Employees by type of employment in 2021

Bank Millennium Group Bank Millennium

Men Women Total Men Women Total

Full-time 2,290 4,577 6,867 2,142 4,394 6,536

Part-time 52 160 212 9 75 84

Mandate

agreement

67 68 135 50 50 100

Employment

contract

2,342 4,737 7,079 2,151 4,469 6,620

For an

indefinite

term

1,991 4,052 6,043 1,817 3,809 5,626

For a definite

term

351 685 1,036 334 660 994

[GRI 401-1] Newly-hired employees

Men

Total men

Women

Total

women

Grand

total

<30

yrs

30-50

yrs

>50

yrs

<30

yrs

30-50

yrs

>50

yrs

Bank

Millennium

Group

(percentage

in a given age

category)

266

(50%)

180

(12%)

(5%)

462

(20%)

485

(49%)

295

(9%)

(4%)

802

(17%)

1,264

(18%)

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Bank

Millennium

(percentage

in a given age

category)

260

(50%)

155

(11%)

(4%)

425

(20%)

471

(49%)

267

(9%)

(4%)

756

(17%)

1,181

(18%)

[GRI 401-1] Terminations - number of employees

Men

Total men

Women

Total

women

Grand

total

<30

yrs

30-50

yrs

>50

yrs

<30

yrs

30-50

yrs

>50

yrs

Bank

Millennium

Group

(percentage

in a given

age

category)

274

(52%)

325

(21%)

(10%)

629

(27%)

461

(46%)

683

(21%)

(17%)

1,227

(26%)

1,856

(26%)

Bank

Millennium

(percentage

in a given

age

category)

273

(53%)

304

(22%)

(9%)

599

(36%)

449

(47%)

652

(21%)

(17%)

1,176

(26%)

1,775

(27%)

[GRI 401-1] Employee turnover ratio*

Men

Total

men

Women

Total

women

Grand

total

<30

yrs

30-50

yrs

>50

yrs

<30

yrs

30-50

yrs

>50

yrs

Bank

Millennium

Group

8% 3% 1% 4% 8% 3% 2% 4% 4%

Bank

Millennium

9% 3% 1% 4% 8% 3% 2% 4% 4%

* Sum of new hires and departures in a given year divided by year-end headcount multiplied by 12 for each

age group and by gender

[GRI 202-2] Employees hired locally*

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Bank Millennium Group Bank Millennium

Men Women Total Men Women Total

Number (and

percentage) of

employees

2,289

(97.7%)

4,664

(98.5%)

6,953

(98.2%)

2,101

(97.7%)

4,399

(98.4%)

6,500

(98.2%)

Number (and

percentage) of

Management Board

members and senior

managers

(89.9%)

(100%)

(92.9%)

(87%)

(100%)

(90.9%)

* Polish citizens working in Poland

[GRI 405-1] Employees by position and gender

Bank

Millennium

Group

Men

Total

men

Women

Total

women

Grand

total

<30

yrs

30-50

yrs

>50

yrs

<30

yrs

30-50

yrs

>50

yrs

Management

Board

7 7 7

Upper

management

29 33 62 16 13 29 91

Management 12 323 67 402 16 520 88 624 1,026

Sales personnel 355 508 38 901 826 1,762 195 2,783 3,684

Technicians 109 569 128 806 65 708 181 954 1,760

Other

employees

55 89 20 164 91 237 19 347 511

Total 531 1,518 293 2,342 998 3,243 496 4,737 7,079

Bank

Millennium

Men

Total men

Women

Total

women

Grand

total

<30

yrs

30-50

yrs

>50

yrs

<30

yrs

30-50

yrs

>50

yrs

Management

Board

7 7 7

Upper

management

24 23 47 13 10 23 70

Management 11 307 53 371 16 487 72 575 946

Sales personnel 353 491 31 875 822 1,736 193 2,751 3,626

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Technicians 104 507 104 715 55 631 161 847 1,562

Other

employees

48 70 18 136 70 189 14 273 409

Total 516 1,399 236 2,151 963 3,056 450 4,469 6,620

3.4. WORKING CONDITIONS

3.4.1. HR POLICY

[GRI 103-1, 103-2, 103-3] The Bank Millennium Group has in place the “Bank Millennium Group’s Human

Resource Policy” concerning such issues as employee recruitment, management, development and

retention as well as planning and monitoring employment.

The Bank has compensation policies in place for employees as well as persons having material impact

on the Bank’s risk profile. They formulate the assumptions used to shape the fixed and variable

components of these employees' compensation.

Bank Millennium operates in compliance with the policies for selection and assessment of Supervisory

Board Members and Management Board Members as well as key functions holders. The application of

these policies ensures that the persons discharging the most important functions in the Bank

Millennium Group, including functions in the management bodies, have the requisite professional

qualifications and the appropriate reputation.

This policy fosters sound Group management, the generation of stable results and the appropriate

risk management in the long-term perspective.

Another policy in force is “Diversity Policy”, which shows that Bank Millennium operates while

respecting human dignity and the right of equal treatment regardless of age, gender, ethnic or

national origin, religion, creed, family status, sexual orientation, health condition, convictions, trade

union membership and other premises that could trigger discrimination.

The Bank Millennium Group applies employee regulations that are as uniform as possible, in particular:

Work Rules and Regulations - laying down the organization and order of work and the related rights

and duties of the employer and employees as well as Compensation Rules and Regulations

establishing the rules and conditions for paying compensation and awarding other benefits.

The result of applying HR policies is as follows:

 Creating uniform rules of employment, access to benefits and compensation;

 Checking compensation systems periodically, including base salaries, including comparisons

with market benchmarks;

 Using balanced appraisal systems aligned to the mid and long-term targets while taking into

account quantitative and qualitative criteria;

 Checking qualifications and conscientiously selecting employees for the top positions in the

Group;

 Countering conflicts of interest and decision making that poses a threat to the Bank’s long-

term interests by introducing more detailed criteria for appraising the work of people in

managerial positions referring to their impact on the risk;

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

 Counteracting discrimination and mobbing through communication, training and

implementing an abuse reporting system;

 Building an organizational culture based on values by extensively advancing organizational

values and implementing the “Leadership Code”.

3.4.2. COMPENSATION POLICIES

[GRI 103-1, 103-2, 103-3] The Bank Millennium Group also has a uniform “Compensation Policy for

employees of the Bank Millennium S.A. Group”, which articulates the assumptions used to shape

the fixed and variable components of compensation for all the Group employees. The policy aims to

provide a formal framework for shaping the practice of compensating all the Group’s employees from

the perspective of corporate governance, institutional safety and the adequacy of compensation to

the Group’s standing, scale of operations and growth potential.

Furthermore, for employees identified as having a material impact on the risk profile (the so called

Risk Takers), there is “Compensation Policy for employees having a material impact on the risk

profile at the Bank Millennium S.A. Group”, which specifies detailed rules for granting variable

components of compensation and other terms and conditions affecting the decisions on their

payment. At Bank Millennium, the “Instruction for identification of Risk Takers at the Bank Millennium

Group” also applies and it includes guidelines for the annual process of identifying Risk Takers.

In subsidiaries: Millennium Dom Maklerski SA and Millennium Towarzystwo Funduszy

Inwestycyjnych SA, in accordance with the statutory obligation, separate compensation policies are

in place and the solutions comprised therein are contained in the framework adopted in the

“Compensation Policy of the Bank Millennium S.A. Group”.

The adopted policies form a framework for organizing principles of compensation in key aspects:

 principles for defining the amounts of compensation,

 the relationship of variable compensation to fixed compensation,

 decision-making process for changing compensation,

 supervision of all the compensation decisions at the Bank and in the Group,

 linking bonuses to good results of both the company and the employee,

 counteracting incentives that induce actions and decisions that threaten the long-term

interest of the Bank and its clients,

 defining assessment criteria corresponding to short-, medium- and long-term goals set for

employees,

 taking into account additional qualitative criteria for assessing work in units where work is

especially directed to sales results.

The Bank consistently uses stable forms of employment and compensation. Employees have

employment contracts and fixed compensation makes up a major part of their overall compensation.

The policy defines the framework to determine fixed compensation of employees, taking into

consideration the tasks and competences required in specific teams and units. The assumed

compensation levels on individual positions are verified based on the market situation and data from

reports on compensation levels in business sectors.

The Bank constantly monitors the solutions adopted in individual business lines so that they do not

create stimuli for actions and decisions that threaten the long-term goals of the Bank, exceed the

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

accepted risk profile, and do not encourage actions that are inconsistent with the best interests of

the Group’s clients and investors.

At the Bank, regular salary and position reviews are conducted. Pursuant to an assessment of the

Group’s financial condition and its business environment, the Bank’s Management Board may make a

decision to award a pool of funds to be used to modify employees’ base salaries. Salary levels are

reviewed taking into account the periodic assessment of performance and skills and are compared

with salary information presented in salary studies on the financial markets.

[GRI 202-1] Ratio of entry level wage by gender compared to minimum wage in 2021

Bank Millennium Group Men Women Total

120% 120% 120%

Policy of variable compensation components

As part of implementation of the Compensation Policy in the Bank Millennium Group, there are in

place, verified on an annual basis, "Regulations for granting variable compensation components",

which comprehensively describe bonus rules for all Bank units. These regulations are a reference point

for all bonus solutions in the Bank’s individual units. The provisions of the document supplement the

“Rules and Regulations for Compensating Employees of the Bank Millennium S.A.’s Head Office”.

Variable compensation is an additional motivational part of the overall compensation, shaped using

differentiated bonus schemes whose purpose is to motivate employees to achieve their business and

organizational plans. The bonus systems and periodic evaluation criteria in the Bank Millennium Group

have been adapted to the specific nature of work performed by employees in the Group’s various

areas.

The Bank does its best for the motivation mechanisms addressed to the employees of sales units and

other units involved in processes related to client service to be devised in such a way that they do

not lead to a conflict of interest or incentives that may incline Group employees to place their own

interests or the firm’s interest first thereby creating a prospective loss for any Group client.

The bonus pool amount depends each time on overall results and on the general condition of the

Bank. Bonuses are paid out monthly in the Bank’s sales network and other head office units involved

in the customer service of retail clients or quarterly for employees of the Bank’s Head Office.

An important part of this approach is a separate assessment for those in management positions, which

encourages managers to pay special attention to the Bank’s long-term interests and avoid excessive

risk exposure.

The bonus for key employees with material impact on the risk profile in Bank Millennium Group in

accordance with policy requirements is paid in 50% in cash and the remaining 50% is paid in the form

of a financial instrument. A minimum of 40% of the awarded variable compensation is deferred for

payment in subsequent years. If the variable annual remuneration falls below a specific threshold,

the bonus may be paid fully in cash.

3.4.3. SIGNIFICANT RISKS RELATED TO THE EMPLOYEE AREA

[GRI 102-15] A significant risk factor is the employee turnover ratio and the prospective loss of

competences of importance to the Bank’s development. Shortages of employees having specific

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

competences in the labour market and competition for acquiring specialized employees may cause a

periodic risk of making decisions to recruit employees and compensate them at higher rates than

those prevailing in the organization. As a result, there may appear compensation disparities between

similar positions. The Bank takes actions to prevent that undesirable phenomenon, especially by

setting recommended recruitment compensation levels and performing periodic compensation

reviews.

Another risk associated with the compensation policy may be the applied motivation mechanisms

inclining employees to work in a task-based manner which may potentially cause a conflict of interest.

The risk of employees acting too one-sidedly as a result of incentive mechanisms aimed at achieving

higher sales, and therefore bonuses, is mitigated by taking into account quality criteria when

evaluating work.

In addition, the consistent implementation of the adopted Compensation Policy allows for minimizing

risks by, among others, maintenance of the right ratio of fixed to variable compensation, application

of a formal assessment system including criteria adjusted to the nature and special character of work

and a long-term perspective for assessing business results, the mechanism of managing the variable

compensation pool dependent on the Bank’s financial standing.

3.4.4. SUPPORTING DIVERSITY AND COUNTERACTING DISCRIMINATION

[GRI 103-1, 103-2, 103-3] In accordance with the "Human Resources Policy" in force in the Bank Millennium

Group the use of any discriminatory practices with features of mobbing or harassment in relation to

employees is prohibited. The Bank Millennium Group operates while respecting human dignity, it

adheres to the law on equal treatment regardless of age, gender, ethnic or national origin, religion,

creed, family status, sexual orientation, health condition, convictions, trade union membership and

other premises that could trigger discrimination. The Bank has “Diversity Policy” and is a signatory to

the Diversity Charter, which is a pledge signed by organizations that choose to prohibit discrimination

in the workplace and work to create and promote diversity.

Issues of respecting diversity in the Bank’s Group are also governed by the “Code of Ethics”, the

“Work Rules and Regulations” and regulations pertaining to recruitment. The result of implementing

these policies is a series of measures. All employees go through mandatory training on ethical issues.

In addition, the management is trained on combating mobbing and discrimination in employment.

The Bank has anti-mobbing and anti-discriminatory procedures. Employees may report abuse

anonymously to the stated email address.

Bank

2021***

Group

2021***

Bank

2020**

Group

2020**

Bank

2019*

Group

2019*

[GRI 412-2] Number

and % of managers

trained on anti-

discrimination and

mobbing in a given

year

(3%)

(10%)

102

(9%)

(10%)

Total percentage of

trained managers

61.45% 62.08% 61.83% 63.26% 79.97% 80.07%

* New managers and directors were trained; the data does not include ex Euro Bank employees

** The data do not include employees of franchised branches. In franchised outlets in 2020, training

was completed by 76 managers.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

*** The data do not include employees of franchised branches. In franchised outlets in 2021,

training was completed by 17 managers.

 During employee recruitment, criteria putting one in jeopardy of discriminatory

behaviour are not applied. These rules also apply to the termination of employment, terms

of employment, promotions and access to training to raise professional qualification.

Candidates are selected based on objective criteria, such as in particular: education,

professional experience, general and specific competences, proficiency in foreign languages

and the overall match with the profile.

 The Bank analyzes on an ongoing basis the compensation structure and equality of earnings

and jobs by gender, age and nationality. Interviews are held from time to time with persons

leaving the Bank to grasp the reasons for them to leave.

 Extensive communication and support are addressed to employees who are parents. The Bank

advises them of their parental rights. People with small children may take advantage of forms

of recreation co-financed by the Bank under the Yes to Parenting program.

 Benefits such as medical care, group insurance, co-financing for sport and recreation are

offered to all employees, also part-time employees.

 The Bank encourages employees to take their holiday leaves.

 The Bank lends a helping hand to people in a challenging financial and health-related

situation through the existing social assistance system predicated on the Company Social

Benefits Fund.

 People with disabilities may take advantage of office infrastructure that is aligned to their

capabilities.

[GRI 405-1]

Employees with

disabilities

Bank

2021

Group

2021

Bank

2020

Group

2020

Bank

2019*

Group

2019*

Bank

2018

Group

2018

Number and % of

employees

(1.01%)

(0.97%)

(0.92%)

(0.89%)

(0.68%)

(0.62%)

*without former Euro Bank’s employees

 The Bank runs management training whose aim is to strengthen appropriate attitudes,

including also to overcome stereotypes and promote openness to employees’ various

convictions and mould their own responsibility and that of their reports.

 Employees may freely express their views on an internal internet forums.

The HR Department keeps a register in which all employee claims are recorded. They are reported

to the Process and Operational Risk Committee. A notification is examined using a procedure, which

involves, among others: collecting documentation to review the claim, conducting a survey among

employees, making a decision to accept or reject the claim and issuing a response to the employee.

[GRI 406-1] Two notifications pertaining to actions involving mobbing were recorded in 2021. In each

case, anti-mobbing surveys were carried out and conversations held with managers of teams and units.

In neither of these cases was bullying confirmed, but nevertheless the managers were instructed on

the absolute necessity to ensure that the relationships between team members comply with the rules

of social coexistence.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

The coronavirus pandemic has not blocked a grass-roots

initiative 3xM(ille) - implemented for women, at work and after

work. In 2021, activities were developed through creating a

culture of diversity and innovation and conducting an effective

and engaging communication.

The cooperation with Vital Voices Poland in the project for young

women aged 16-19 #I am a Leader has been successfully finalized in the form of external mentoring

of female leaders from the organization and the implementation of a social project with the mentee.

In addition, several important concepts were implemented, including the launch of a social breast

cancer prevention campaign, „3xM(ille)j bez raka” ("3xM(ille)j without cancer”).

Compensation for women and men

In accordance with the Human Resource Policy in force in Bank Millennium, the Bank incorporates

information in the compensation policy concerning the market levels of compensation for similar

positions. Employee compensation is periodically checked on the basis of the Bank’s current strategy,

market data, job performance assessments and employee career stages. The Bank strives to devise

bonus schemes in which the incentive is linked to the nature of the work in a given unit – by

formulating reasonable and fair ratios describing job performance and the appropriate incentive

systems for a given unit in the Bank.

[GRI 405-2] Ratio of women’s base compensation to men’s*

Bank Millennium Group

2021

2020

2019**

2018

Upper management 0.86 0.83 0.83 0.81

Management 0.75 0.76 0.78 0.75

Sales personnel 0.92 0.91 0.91 0.88

Technicians 0.72 0.74 0.71 0.68

Other employees 0.79 0.79 0.81 0.80

All employees 0.69 0.70 0.71 0.68

Bank Millennium 2021 2020 2019** 2018

Upper management 0.87 0.83 0.85 0.85

Management 0.74 0.76 0.77 0.75

Sales personnel 0.92 0.92 0.91 0.89

Technicians 0.73 0.75 0.72 0.69

Other employees 0.76 0.77 0.78 0.77

All employees 0.69 0.71 0.72 0.69

* Weighted average, taking into account the group size and the percentage of women in a given

group. The difference in compensation levels arises from the calculation method: a category

contains positions with different responsibilities and different pay.

**without data from former Euro Bank

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

[GRI 405-2] Ratio of women’s overall compensation to men’s*

Bank Millennium Group 2021 2020 2019** 2018

Upper management 0.78 0.81 0.82 0.81

Management 0.72 0.71 0.74 0.73

Sales personnel 0.85 0.83 0.87 0.85

Technicians 0.73 0.74 0.69 0.71

Other employees 0.85 0.75 0.86 0.91

All employees 0.66 0.66 0.67 0.66

Bank Millennium 2021 2020 2019** 2018

Upper management 0.77 0.81 0.83 0.86

Management 0.72 0.71 0.74 0.71

Sales personnel 0.85 0.84 0.88 0.86

Technicians 0.75 0.75 0.71 0.68

Other employees 0.83 0.73 0.84 0.91

All employees 0.66 0.67 0.68 0.66

* Weighted average, taking into account the group size and the percentage of women in a given

group. The difference in compensation levels arises from the calculation method: a category

contains positions with different responsibilities and different pay.

**without data from former Euro Bank

The difference in the average salary of men and women does not include the differences in geographic

location, scope of duties and headcount structure of men and women in various positions in different

areas of the Bank. It should be emphasized that the last factor in particular is of major significance

for the shaping of the average employee compensation. Most women are hired in the sales network,

while men work chiefly in high technology areas, where the market, due to a shortage of specialists,

dictates significantly higher levels of remuneration. The Bank reviews in detail all factors that may

contribute to the differences in employee compensation between men and women.

3.4.5. FREEDOM OF ASSOCIATION

[GRI 102-41] There are three trade union organizations in operation in Bank Millennium. More than

540 employees belong to the trade unions. The Bank cooperates with the trade unions within the

scope defined by the legal regulations and the Trade Unions Act.

Dialogue with employees is also conducted using the internal social forum and the intranet.

These tools serve to inform employees of the most important issues relating to the Bank while making

it possible to submit remarks and exchange opinions on various topics. Additionally, the HR

Department runs an HR Zone intranet site on which it regularly posts all the information of interest

to employees about employee matters. In 2020 the Bank implemented the new TETA HR and Payroll

System. Every employee has access to his/her own HR information through the TETA ME module. In

2021 more functionalities were deployed: management reporting and holiday leave plans as of 1

January 2022. Further system development and extension of the scope of information available to

employees are planned for 2022, i.e. access to scans of documents in personnel files and launching

managers’ requests. If this information is insufficient, an employee may also file a direct inquiry to

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

the HR Department using the HR Service employee service system or talk to the dedicated HR

Department employee responsible for serving him/her – the HR relationship manager.

3.4.6. EMPLOYEE APPRAISAL

[GRI 404-3] All Bank employees who are actively working in a given period (that is all of the Bank’s

employees except for the ones who are on long-term leave and holidays) are subject to regular

appraisals. Bank Millennium has issued “Instructions on how to conduct employee appraisals in Bank

Millennium S.A.”, which contain guidelines on devising the rules for employee appraisals in reference

to the various forms, i.e. in particular, the evaluation of work performance or competences.

Appraisals are conducted on the basis of previously communicated, objective criteria. The rules of

employee appraisals are aligned to the nature of work and refer to attitudes towards cooperation,

commitment, quality and effectiveness.

The evaluation of work performance forming the basis for various recommendations is run in a manner

so as to prevent rewarding for poor performance. The appraisers also take into account the

employee’s attitude towards risk mitigation, in particular accurately reporting risks.

The appraisal system makes it possible to compare the work performance of different employees and

the achievement of targets.

Promotions*

Bank Millennium Group Men Women Total

Upper management 5% 3% 4%

Management 7% 6% 6%

Sales personnel 16% 11% 12%

Technicians 19% 12% 15%

Other employees 7% 8% 8%

Total 15% 10% 12%

Bank Millennium Men Women Total

Upper management 6% 4% 6%

Management 7% 5% 6%

Sales personnel 17% 11% 12%

Technicians 20% 12% 16%

Other employees 9% 9% 9%

Total 15% 10% 12%

*% of employees in a given group who were promoted

3.4.7. RECRUITMENT AND PROFESSIONAL DEVELOPMENT

Most job offers in the Bank Group are addressed to internal and external candidates. An employee

who would like to develop his or her skills in some other area than up to now may express an interest

in an internal job transfer.

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Selected employees are assigned to interdepartmental projects initiated and supervised by the

Bank’s Management Board. This affords an opportunity to share knowledge and gain new skills.

The number of people transferring internally in 2021 revisited the stable level from prior to the

merger and the pandemic.

* Data for Bank Millennium, without data on internal rotation in other Group’s companies

Sourcing talent

Employer branding activities are an important part of the Bank’s activity. They are cantered on

several prospective employee groups: students and graduates, IT and Digital specialists, sales and

support specialists and business development experts. Despite the persisting pandemic the Bank has

efficiently adapted to the change and successfully carried out many different activities online. One

example of such activities is the Week with Career Counsellors during which students had the

opportunity to learn about career possibilities in Bank Millennium. Another event supported by the

Bank was the BIG DATA conference organized by the Student Scientific Club on Statistics during which

Bank experts presented issues in the technological area. Additionally, as part of the Sails of Business

competition dedicated to smart organizations established by students and run by students, doctoral

students or the graduates of the Warsaw School of Economics, the Bank acted in the capacity of a

member of the competition jury. All of these activities were carried out in the Warsaw School of

Economics. For several years the Bank has been a member of the Warsaw School of Economics’

Partners Club and closely cooperates with this university by playing an active role in academic life.

Bank representatives take part in meetings with the Council of the Warsaw School of Economics’

Partners Club during which elements of the university’s strategy and the possibilities of educating

students on key competences are discussed.

Bank Millennium also participated in virtual job fairs such as Jobicon and Warsaw IT Days. These types

of events aimed to provide insight to prospective candidates on the specific nature of a job and the

career development opportunities in the Bank. Job fairs also offer space to share professional

knowledge on the merits with participants.

The Bank takes advantage of the communication opportunities afforded by social media such as

LinkedIn and Goldenline and fifteen or so image and recruitment portals to reach candidates

efficiently with information regarding the employer and job offers.

Rewards for employees

Programs are run in Bank Millennium in which employees who stand out through their above average

commitment receive rewards.

IMPAKT Employee Reward Program in which employees reward their female and male work

colleagues. In 2021, 48 employees were recognized for their commitment, improvement

of quality, innovative solutions and accepting challenges to inspire others. The program

gala and the awards ceremony took place virtually with some 120 persons in attendance.

Additionally, the ceremony was aired live to all employees.

Internal recruitment –

Bank Millennium*

2021

2020 2019

2018

Number of employees 158 753 87 95

100

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

Once a year, the best employees and managers are rewarded with the President’s Prize for their

above average professional achievements. In 2021 they were presented to 12 employees in the head

office and the sales network.

Training

[GRI 103-1, 103-2, 103-3] Training in Bank Millennium is a major part of daily activity and is treated as

an investment in human capital. The purpose of training is to enhance the competences of employees,

which translates into improving quality and work productivity and achieving current and future

business objectives.

Every year Bank Millennium employees have an opportunity to participate in internal and external

training and in conferences and congresses. On account of the pandemic, as part of the care for

employee health, most training was administered remotely or in a hybrid form, while some was held

on-site while observing the sanitary regime. Some of the training courses were delivered in the form

of e-learning - e.g. “PLN and foreign currency teller course” and “Prevention of money laundering

and financing of terrorism”.

* The increase stems from training ex Euro Bank employees

* The increase stems from migrating training sessions from two external platforms to the Bank’s

internal training platform. The pandemic has also contributed to holding more training sessions

online.

The most important training sessions held in 2021:

Introductory training for new Bank Millennium Group employees – these training sessions were held

on a fully remote basis using the MS Teams software due to the pandemic.

Millennium Campus - a program to develop knowledge and skills with the objective of supporting the

growth of innovation across the organization. The offer to participate in this program is addressed to

all employees, it allows them to look at many topics from a different perspective. Lectures are held

online, while recordings and aids are made available on the training platform and in the intranet in

the World of Millennium. 11 remote meetings were held in 2021.

Training for branch and franchise network employees

 Specialist introductory training for new employees in own branches and the franchise

network.

 Certification workshop on the Savings and Investment Model (MOI) - prepares people to sell

savings and investment products according to the MIFID regulations and supplies knowledge

about the standards required under the savings and investment model.

 “Mortgage loans” - this training consists of three parts that constitute the successive parts of

the process of introducing employees to the mortgage product and its sales.

 “Phone sales” – learning about the practical skills of holding a sales call by phone while using

the principles of influence and effective reasoning” for employees in the own network and

the franchise network.

Number of

e-learning

training topics

Group

2021

Bank

2021

Group

2020

Bank

2020

Group

2019

Bank

2019

1,009** 1,002**

490 495 483* 478*

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 “Offer of business accounts for the franchise network” for employees.

 “On the Critical Topic” – a one-day training session held on-site for the managers of retail and

franchise outlets on the “On Topic” model. Workshop training held on-site has delivered

knowledge and made it possible to practice the application of the standards described in the

model.

 “Savings and Investment Model (MOI) – 2021” – training on changes in the binding model for

the sales of savings and investment products.

 “Train the Trainer” training sessions for regional trainers to prepare them to run training on

the sales model “On Topic” and the Savings and Investment Model (MOI).

 Product and sales training sessions for retail network employees pertaining to credit products:

Creditworthiness; Covid - restriction package; Creditworthiness; Consolidation- available

immediately; Internal and external databases.

 Product and sales training sessions for retail network employees pertaining to savings and

investment products.

 Training sessions for retail network employees presenting an account offering to commercial

undertakings.

Training for Corporate Banking relationship managers

Bank Millennium conducts training for employees of the Corporate Banking sales network, presenting

financing opportunities for businesses from public programs, including the National Reconstruction

Plan, Multi-year Financial Framework or EU funds. The training courses delivered in 2021 addressed

the issues of innovation, financing the implementation of new products and services, support for

conducting research and development in enterprises. These training courses both provide information

to relationship managers about the programs, along with the criteria and parameters for financing

new projects, and support in talks with clients about investments, in particular in the area of financing

innovations, green investments and digitization.

Employees of the Corporate Banking area also participated in a series of training sessions entitled

"Financing investment projects", improving their competencies in analyzing investment projects of

their clients. The Bank regularly provides relationship managers with knowledge of the current

macroeconomic situation and its impact on the markets and the companies' operations. We do this in

the form of monthly webinars conducted by the employees of the Bank's Macroeconomic Analysis

Office. The information is supplemented by industry analyses made available on the intranet.

In 2021, all Corporate Banking relationship managers were invited to participate in storytelling

training. Employees also participate in training on new solutions for Corporate Banking clients, as

exemplified by webinars on Financial Shield 2.0 on applying for and forgiveness of subsidies in Millenet

for Companies, a webinar on the document exchange module in Millenet, or a series of training

sessions on solutions available to clients in eBOK Millennium Leasing.

Training for employees selling insurance products

On top of product training sessions ending with an exam to confer authorization to commence the

sales of insurance, Bank employees who sell insurance products went through annual professional

training sessions to enhance their competences in terms of performing tasks involving insurance

intermediation. Besides legal issues much attention during training sessions is devoted to the general

rules and practical aspects of distribution activity.

[GRI 404-2] Management programs

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Management Development Program for the managers of retail outlets in the Bank’s own network.

The following stages are part of this program: The ABCs of a contemporary manager, Goals,

Development. The program’s goal is to improve the practical managerial skills of defining,

communicating and controlling goals, building team commitment towards their active achievement

and sales team management. Particular attention is focused on planning development activities and

working on competences of employees in reference to the allocated tasks.

Management Competences Workshops for the IT area. Workshop participants worked on unifying

their knowledge on the leadership competences used on their positions.

Lectures on processing personal data for the IT Area, Corporate Area, Retail Liabilities Collection

Department, Millennium Goodie and Millennium TFI. The subject matter covered the most important

issues concerning the processing of personal data and the legal requirements in this area.

Workshops on plain language. This training session was part of the plain language project across the

bank. It prepared participants to play the role of a plain language consultant. Internal trainers

continue to deliver training in the organization.

In 2021 the main tool used to deliver training and hold meetings was MS TEAMS. The implementation

of the tools was accompanied by online training aiming to familiarize users with the tool functions

and popularize it.

[GRI 404-1] Average number of training hours by gender and position

Bank Millennium Women Men Total

Average number of hours per

employee

43.4 36.7

41.3

Management Board 26.5 26.5

Upper management 24.3 18.1 20.1

Management

45.1

35.7

41.4

Sales personnel 55.0 61.3 56.5

Technicians

15.3

13.0

14.3

Other employees 12.5 13.1 12.7

[GRI 404-2]

On account of the small number of employees in retirement age, no programs are currently

being run to support the continuity of employment and facilitate the process of retiring. Individual

training sessions, however, are possible upon request.

Bank Millennium Group

Women

Men

Total

Average number of hours per employee

41.3

34.1

38.9

Management Board

26.5

Upper management

21.0

15.5

17.2

Management

42.3

33.5

38.8

Sales personnel

54.4

59.7

55.7

Technicians

14.2

12.0

13.2

Other employees

10.3

11.1

10.6

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3.4.8. SOCIAL BENEFITS

[GRI 401-2] Bank Millennium Group employees are offered the same social and financial benefits

regardless of the type of the employment agreement (for a definite/indefinite term) and the working

time (part-time/full-time). The amount and scope of benefits depend on the employee’s life and

financial situation. A private medical care plan is offered to employees employed for at least one half

of a full time equivalent. The range of the plan varies for different positions.

The Bylaws of the Company Social Benefit Fund regulate the Bank’s social activity. According to these

Bylaws, the Bank pursues the following initiatives:

 conducting leisure, cultural, sporting, recreational and tourist activity,

 organising events and group meetings,

 providing material or financial assistance,

 providing financial assistance in individual events of chance, a particularly difficult financial,

family or life situation (financial assistance that does not have to be repaid), also in states of

emergency or epidemiological risks.

Companies tap into the social benefits offering offered by the Bank but they finance it using their

own Social Benefits Funds.

Medical care

The private medical care plan allows all the Group employees equally to have access to basic and

specialist medical consultations, detailed diagnostic tests and prevention programmes. Additionally,

employees may purchase healthcare packages for their immediate family members. After their

employment ends, retired employees may also continue their private medical care plan on

preferential terms.

Hardship assistance

Under their social assistance the Bank and Companies offer assistance to employees who are in a

particularly difficult financial, family or life situation.

Benefits awarded to Bank employees 2021 2020 2019 2018

Financial assistance (PLN) 517,320 388,550 316,800 452,200

Number of employees who received financial

assistance

122 120 100 133

Life insurance

Employees may join a group life insurance on preferential terms. The insurance covers life and health

of the insured and their family members. Six insurance variants are available so that everyone can

match the offer to their needs.

Life insurance Bank

2021

Group

2021

Bank

2020

Group

2020

Bank

2019

Group

2019

Bank

2018

Group

2018

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Number and % of

employees who took

advantage of the offer

3,120

(47%)

3,267

(46%)

2,840

(45%)

2,982

(44%)

2,915

(49%)

3,067

(48%)

2,940

(50%)

3,100

(49%)

MyBenefit cafeteria platform

[GRI 403-6] A new benefit in the form of a purchasing platform where online purchases can be made

with the Social Fund’s resources was launched in 2021. On the platform, the employee can use more

than one thousand various benefits related to tourist, cultural, sports and recreational services. The

employee can choose the benefits of interest to them and use them at any place and time. The

platform offers also the MultiSport card, which gives the employees comprehensive access to various

sports activities, such as swimming pool, gym, fitness, squash, dance and yoga classes, combat sports

and climbing wall. The card provides employees with an opportunity to live a healthy and active life.

They can also purchase a card for their relatives on specially negotiated pricing terms.

Christmas benefit

Before Christmas, employees can count on financial support in the form of a Christmas benefit. The

benefit amount varies depending on a given employee’s financial situation.

Social benefit for low-income persons

The pandemic forced the Bank to develop new solutions. In 2021, it was not possible to execute social

projects, such as trips and meetings, which the Bank had organised for employees for many years.

Therefore, a cash benefit for low-income persons was introduced to the formula of the Company

Social Benefit Fund. The benefit was intended as a financial support for the employees whose financial

situation became difficult as a result of the pandemic.

Special Support Fund for Employees in the event of coronavirus infection

In the face of the expanding coronavirus pandemic, the Bank Millennium Management Board decided

to continue the Special Support Fund for Employees, which was established in 2020. The Fund received

a contribution of PLN 1,000,000 from the Bank’s own cash. The Fund provides financial assistance in

the form of a non-refundable hardship assistance in the form of cash to the Bank Millennium Group

employee and their immediate family members (spouses, partners, children) who have been infected

with coronavirus. The amount of the support depends on the needs presented by the employee in

their application.

3.4.9. FRIENDLY WORKPLACE

In addition to providing attractive working conditions, development and social support, Bank

Millennium supports employees returning to work after a maternity/parental leave, and encourages

participation in charitable activities, employee volunteerism, sports and cultural activities.

[GRI 401-3] Returning after maternity/parental leave

Bank Millennium Group Men Women

Total

2021

Total

2020

Total

2019*

Employees entitled to leave 2 709 711 821 501

Employees who took leave 2 405 407 472 272

Returned to work after leave 2 362 364 438 235

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Employed 12 months after returning from

leave

3 327 330 198 222

Percentage returning after leave 100% 89% 89% 93% 86%

Percentage of employees retained by the

Bank who returned from leave

75% 75% 75% 84% 83%

Bank Millennium Men Women

Total

2021

Total

2020

Total

2019*

Employees entitled to leave

2 684 686 798 485

Employees who took leave

2 395 397 459 265

Returned to work after leave

2 353 355 426 231

Employed 12 months after returning from

leave

3 315 318 186 179

Percentage returning after leave

100% 89% 89% 93% 87%

Percentage of employees retained by the

Bank who returned from leave

75% 75% 75% 84% 81%

*no data for Euro Bank

Individual approach to the form and time of work

Bank Millennium Group employees are subject to one of the following working hour schedules: fixed

(the main one), shift-based, task-based or balanced. The selection of a system depends on the type,

organisation and place of work and the business requirements in a specific area.

In response to an employee’s written request, their superior may set an individual work time schedule

within the framework of the system applicable to that employee. Working remotely is also possible

through individual arrangements. Employees may work part-time insofar as the conditions for the

Group to operate in a given area facilitate that. Many employees with parental rights are taking

advantage of this solution.

The Bank’s priority for 2021 was to ensure safety to employees during the COVID-19 pandemic. In

order to comply with the sanitary authorities’ recommendations arising from the epidemiological

situation in the country, the Bank enabled the option of remote work to a large extent. A more

detailed description can be found in section “Measures continued in connection with the COVID-19

pandemic”.

Employee volunteerism

The actions taken by volunteers of the Bank Millennium Group in 2021 are described in section

“Socially beneficial activities”.

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3.5. EMPLOYEE HEALTH AND SAFETY

3.5.1. MEASURES CONTINUED IN CONNECTION WITH THE COVID-19

PANDEMIC

[GRI 403-6] On 3 March 2020, the Bank’s Management Board appointed the COVID-19 Pandemic Action

Coordination Team, which has held regular meetings and reported the action plan and status of the

individual tasks to the Bank’s Management Board since its appointment. The COVID-19 Pandemic

Action Coordination Team is composed of representatives of all areas of the Bank.

The area of the Team’s activities covers:

• ongoing monitoring of the situation in the country, adaptation of the Bank’s actions to the

current government guidelines;

• organisation of the Bank’s operations during the pandemic;

• provision of hygiene products for branches and head offices;

• preventive measures leading to minimisation of the number of infections among Bank

employees and clients;

• supply of laptops and mobile phones to all employees who are critical for the Bank’s continued

operation;

• ongoing communication addressed to employees;

• strict monitoring of employee behaviours, support for employees and their families.

The COVID-19 Pandemic Action Coordination Team adapted the Bank’s activities to the pandemic

situation in the country on an ongoing basis in 2021. The performance of the activities was monitored

at regular team meetings and reported at Management Board meetings.

As a general rule, in 2021, employees of the Bank’s head offices worked in the hybrid model with the

option of flexible adaptation (increasing or decreasing the time of working in the remote model) by

unit heads.

The Special Support Fund for Bank Millennium Group Employees in the event of coronavirus infection

and the necessity to cover the costs of treatment and rehabilitation was established in April 2020. Its

resources were released on an ongoing basis at employees’ requests also in 2021.

In 2021, the Bank, together with the healthcare provider, coordinated COVID-19 and influenza

vaccination for its employees.

3.5.2. OHS STANDARDS

[GRI 103-1, 103-2, 103-3, 403-1] Occupational Health and Safety activities are regulated in the Instructions

for managing occupational health and safety and fire protection in Bank Millennium. They include

standard occupational health and safety topics, fire protection, labour law basics and training in these

areas. In 2020, the catalogue of topics was expanded by the rules of conduct in case of the COVID-19

risks published in the PANDEMIC catalogue. Group companies are bound by the same regulations.

[GRI 403-2] The OHS audit activity is a scheduled activity based on the annual audit plan, which covers

at least 50% of all the Bank’s branches in any given year. All the materials from reports, post-

inspection recommendations or post-accident documentation are used by the Bank’s relevant

organisational units for improvement of safety.

[GRI 102-15] The key risks related to failing to observe

OHS rules pertain to the possibility of employees sustaining unfavourable health consequences (chiefly

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falling, getting hit, mental and physical burdens and SARS-CoV-2 infection), the ensuing absence from

work and the requirement to disburse damages.

An effective way of preventing these types of risks is to deliver training to employees and administer

regular inspections of offices and the Bank’s branches with an eye to compliance with the rules of

fire protection and OHS. All new employees are familiarised with the occupational risk assessment for

individual jobs.

[GRI 403-3] The health care provided to employees comprises occupational medicine services, including

preventive healthcare examinations for employees during their working hours and at the employer’s

expense.

[GRI 403-4] The ongoing consultations are held with the participation of trade union representatives.

An additional platform for consultations and improvement of working conditions is the activity of

Social Labour Inspectors. The Bank is intensively working on the implementation of the rules for

cooperation of all social representatives and the employer to the activities taken by the OHS

Committee.

[GRI 403-5] All new employees take part in obligatory OHS and fire protection training. The management

staff is additionally obliged to attend regular refresher and complementary training in this field.

Depending on the needs, the Training Team organises first aid training.

[GRI 403-7] The reduction in cash use in retail outlets significantly mitigates crime-related risks and its

adverse effects (physical and mental injuries). The launch of electronic channels for providing bank

services, in turn, mitigates the risks involved in direct contact and the risk of SARS-CoV-2 infection.

[GRI 403-9]

Occupational

health and

safety

Group

2021

Bank

2021

Group

2020

Bank

2020

Group

2019

Bank

2019

Accidents

at work*

40 39 36 34 39 38

Fatal accidents

at work*

0 0 0 0 0 0

Lost days ratio**

0.07% 0.07% 0.08% 0.07% 0.10% 0.10%

Absence

rate***

9.00% 9.33% 11.20% 11.85% 7.28% 7.4%

OHS training**** –

number and % of

participants

1,264

(18%)

1,181

(18%)

1,175

(17%)

1,099

(17%)

1,465

(23%)

1,408

(24%)

Branch audits

306 292 197 197 185 185

*Number of employees who had accidents.

**Impact exerted by accidents and occupational disease on employee absenteeism. This indicator is

computed by comparing the total number of days lost with the total number of hours planned to be

worked.

***Indicator measuring an absent employee’s actual number of days lost expressed as a percentage

of the total number of days planned to be worked by employees in this same timeframe.

****Introductory and periodic training (conducted once every 5 years).

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BANK IN SOCIAL ENVIRONMENT

3.6. SOCIAL ENVIRONMENT

[GRI 102-42] In 2021, the Bank Millennium Group, with a support provided by an external consulting

firm, verified the list of its stakeholders and their significance. No new stakeholder groups were

identified in the update process. For the purpose of the significance verification process, an online

survey was conducted between 27 August and 6 September. It consisted in selected Bank Millennium

employees rating stakeholder categories in terms of their influence on the company and interest in

its activities. The 1-10 scale was applied in both cases, where 1 represented the lowest and 10 – the

highest level of influence/interest. There were 24 employees taking part in the survey and the

stakeholder significance was determined based on the arithmetic means of the obtaining ratings. It is

illustrated in the chart below.

3.7. COMMUNICATION WITH STAKEHOLDERS

[GRI 102-43, 102-44] The stakeholders’ expectations and opinions are taken into account when

innovations and improvements are made to the Bank’s products, services and operations. In 2021, the

Bank updated the matrix of important topics as part of an extensive dialogue with representatives of

various stakeholder groups. The process is described in detail in section “Defining the content of the

report – dialogue with stakeholders” of this report.

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The feedback from stakeholders is received additionally from the following sources:

Stakeholder Communication channels Topics raised Bank's actions

INVESTORS

AND MARKET

ANALYSTS

 Shareholder Meeting

 Roadshows

and conferences

 Meetings

 Stock exchange

communication

and press releases

 Transparent activity,

quick

and easy access to

information about the

Bank, ethical

and socially responsible

business.

 Compliance with

corporate governance

rules, ensuring

transparency, security

and ethical

character of

operations, quick

exchange of

information through

multiple

communication

channels with

shareholders.

CLIENTS

 Branches, Internet

and mobile

banking,

 Intranet, community

forum,

 Hotline

 Complaints

 Satisfaction surveys

 High quality of

products and services

offered, ethical

marketing

and selling practices,

safety of deposited

funds, ease of use of

products

and communication

with the Bank,

improvements in

accessibility

of the Bank’s services

and non-banking

services.

 Fast and easy access

unfettered by obstacles

to banking and non-

banking services,

ethical advertising and

sales, providing explicit

information about the

conditions for using

services, easy contact

with the Bank, ensuring

the safety of client

funds.

EMPLOYEES

 Intranet, Internet,

community forum

 Whistleblowing system

 Market analyses

 Employee evaluation

 Stability of

employment

and professional

development

opportunities, fair

salary, friendly working

conditions, possibility

to engage in social

activities.

 Communication

with employees

and responding to their

expectations,

professional

competence

development

programmes,

programmes for

parents, co-funding of

activities outside the

workplace, and

employee volunteerism

offer.

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SUPPLIERS /

BUSINESS

PARTNERS

 Periodic meetings

 Telephone, e-mail

 Negotiations

and performance of

agreements

 Fair rules for selecting

and cooperating with

suppliers.

 Use of objective

procedures for

selecting suppliers;

timely performance of

agreements; selection

of suppliers

in consideration of

ethical and

environmental criteria.

SOCIAL

ENVIRONMENT

 Offers of cooperation

 Meetings with

students

 Employee

volunteerism

 Supporting social

projects by the

company and

employees.

 Merit-based and

financial support for

social projects;

financial education;

encouraging employees

to take part in social

and volunteering

campaigns.

ENVIRONMENT

(ORGANISATIONS

INVOLVED IN

ENVIRONMENTAL

PROTECTION

ACTIVITIES)

 Environmental

rankings

 Monitoring changes in

market trends and

legislation

 Reducing our own

unfavourable impact on

the environment,

engaging in responsible

project finance,

environmental

education.

 Monitoring

lowering impact on the

environment, rules

governing the provision

of funding for projects

exerting an impact on

the environment,

environmental

education programs.

REGULATORS

(KNF, BFG,

UOKIK, NBP,

KSF)

 Reports

 Communication

 Regulatory audits

 Recommendations

regarding

communication with

customers, reports on

the Bank’s activities,

assessment of risks

related to the Bank’s

activities.

 Reporting and

implementing

recommendations

provided by regulators.

3.8. SOCIALLY BENEFICIAL ACTIVITIES

[GRI 103-1, 103-2, 103-3, 203-1, 413-1] Social programs are chiefly run by Bank Millennium through the

Bank Millennium Foundation. They pertain to financial education, patronage of culture, academic

education and employee volunteerism. As early as at the beginning of 2020, in connection with the

outbreak of the epidemic, the Bank Millennium Foundation and the Bank became involved in support

projects aimed at the development of Poland’s first coronavirus test under the auspices of the Polish

Academy of Sciences and the provision of assistance to employees infected with coronavirus. This

involvement was continued in 2021. In 2021, the Bank refreshed its employee volunteerism formula

by expanding the #słuchaMYwspieraMY (#WElistenWEsupport) program, promoting commitment to

local communities.

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Donations (D)

and sponsorship (S) in

PLN

2021

BM Group

2021

BM Group

2021

Bank

2021

Bank

2020*

Bank

D S D S D S

Culture 0 478,101 0 478,101 0 489,649

Education 500,000 0 500,000 0 300,000 30,750

Charitable activities 275,522 0 275,522 0 0 0

Sports 0 0 0 0 0 0

Media 0 0 0 0 0 0

Social organisations 205,198 0 193,580 0 0 0

Trade unions 0 0 0 0 0 0

Other 50,000 48,484 50,000 45,484 549,000 77,044

Total 1,030,720 526,585

1,019,102 523,585

849,000

597,443

* In 2020, apart from Bank Millennium, other companies of the Bank Millennium Group did not spent funds for

the purposes included in the table

3.8.1. EDUCATION PROGRAMS OF THE BANK MILLENNIUM FOUNDATION

[GRI FS16] Since 2016, the Bank Millennium Foundation has been running its own financial education

program for kindergarten children, called the “Financial ABCs.” In 2020 and 2021, despite the

pandemic, the Foundation continued to execute the project remotely by creating a series of modern

educational materials for children and their parents. One of its new components is the 4th episode of

the cartoon movie featuring Mr. Sebastian, which in an accessible manner explains to kids the basics

of finance, modern technologies and issues of online security. Printed handbooks, which have their

counterparts in multimedia-version cartoon movies, are accessible on the Foundation’s YouTube

channel.

For preschoolers, their parents and all other persons interested in this topic, other online educational

materials are also useful, such as a guide for parents “How to teach finance to children” with tips on

educating children and interviews with Dr. Małgorzata Chojak of the Maria Curie-Skłodowska

University in Lublin on the same topic.

In November and December 2021, as part of the seventh edition of the program, the Foundation

conducted 200 workshops in 54 kindergartens. Over 5,000 preschoolers aged 3 to 6 participated in

these workshops. According to observations, the pandemic only contributed to the dissemination of

the knowledge taught during of the workshops. The challenges faced by families in terms of changes

in the labour market, household budget management and flexible responses to changes continue to

be reflected in the project curriculum. Because project meetings took place during the fourth wave

of the COVID-19 pandemic, a special epidemiological and sanitary procedure was developed prior to

the launch of activities, and all meetings were conducted in compliance with sanitary guidelines.

3.8.2. CHARITABLE CAMPAIGNS AND EMPLOYEE VOLUNTEERISM

Funds for the first Polish coronavirus test

In 2020, the Bank Millennium Foundation and Bank Millennium joined the battle against coronavirus

by endowing the amount of PLN 500,000 to the Poznań-based Institute of Bioorganic Chemistry of the

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Polish Academy of Sciences which designed the first Polish tests to detect the presence of SARS-CoV-

2. The Institute of Bioorganic Chemistry was Poland’s first research unit to create a laboratory for

COVID-19 diagnostic work. The test prototype, based solely on Polish reagents, was created after two

weeks of intense work and was adopted for mass production. The support provided by the Bank

Millennium Foundation contributed to the continuation of research on more sensitive test generations.

A year after the establishment of this cooperation, in response to difficulties with diagnostics in the

Wielkopolska region, the idea emerged to create a broadly accessible molecular diagnostics laboratory

– PANgen, which was launched in May 2021. The laboratory, which, owing to the generosity of its

sponsors, has been equipped with state-of-the-art equipment, will serve the purposes of broadly

construed medical diagnostics so as to make the best use of the available technology, machinery and

experience of specialists from the Viral Support Group.

Employee support fund

The Special Support Fund for Bank Millennium Group Employees in the event of coronavirus infection

and the necessity to cover the costs of treatment and rehabilitation was established in April 2020. Its

resources were released on an ongoing basis at employees’ requests also in 2021.

#słuchaMYwspieraMY – involvement in the challenges faced by local communities

[GRI 103-1, 103-2, 103-3, 413-1] The Bank Millennium Group attaches great significance to the involvement

of its staff in social campaigns. In order to enable their pursuit of their own volunteerism ideas,

competitions are held for grants to be used for the execution of interesting and socially beneficial

charitable projects. Within the Bank Millennium Group, community-focused initiatives are managed

chiefly by the Bank Millennium Foundation. In 2021, the formula of this type of involvement was

refreshed. The employee volunteerism program #słuchaMYwspieraMY (#WElistenWEsupport) is a

competition for grants provided to volunteerism projects to be carried out by the Bank’s employees

for the benefit of specific individuals, organizations and local communities in need of such support.

All employees of the Bank Millennium Group may participate in the program. Within its framework,

various initiatives are pursuit by employees – from the idea and execution to settlement and

promotion in the form of an article, photo report or video material in the Bank’s intranet space. In

respect of projects involving the provision of support to individual beneficiaries, the Bank Millennium

Foundation evaluated the impact on the life of the beneficiary. In turn, in respect of group

beneficiaries, the project’s impact on the local community was evaluated.

The purpose of the #słuchaMYwspieraMY is by no means confined solely to the provision of financial

support or basic necessities. In addition to the funds provided for or disbursed under the project, the

following aspects also play a prominent role: commitment, time spent on helping the beneficiaries

and own work by the volunteers. In 2021, grants were awarded to 21 project leaders. 139 volunteers

along with their family members and friends took part in these activities. Support was granted to

2,638 beneficiaries – children taken care of by social welfare institutions, people with disabilities,

preschoolers, junior and high school students, including those attending integration and special

classes, and senior citizens. Every gesture, however large or small, and every item shared with the

beneficiaries was thought out carefully, because the volunteers thoroughly scrutinized the stories and

circumstances of the people they decided to help.

Support for the beneficiaries of the Forani Foundation

Bank Millennium and Millennium Leasing once again responded to the needs of a local community by

donating computer and office equipment to the beneficiaries of the Forani Foundation, which

facilitates access to work and helps children and adults in remote learning. This time, computer

hardware and multifunctional devices were provided to care, medical and educational centres in

Mazowieckie and Kujawsko-Pomorskie voivodships selected by the organisation.

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3.8.3. PATRONAGE OF CULTURE

For more than 30 years, cultural involvement has been an important part of Bank Millennium’s social

activities. The Bank supports cultural undertakings with a national and local range alike. It is a 360°

patron of culture as it promotes art in nearly all its manifestations, including music, painting,

sculpture, film, theatre, photography, literature and performance. Bank Millennium’s interest spans

niche and popular culture. Its assumption is to be a long-term partner. For 17 years, the Bank funded

the Golden Sceptre award for outstanding creators of culture, for 11 years, the Bank was the patron

of the “Millennium Pearls” (“Perły Millennium”) joint program of Bank Millennium and Polish TV (TVP),

whose purpose was to produce, promote and present artistic events in the high art realm on Polish

TV. For 17 years, the Bank was a sponsor of the Złota Tarka [Golden Grater] Old Jazz Meeting, an

International Traditional Jazz Festival. For many years it has also supported the Sacrum Profanum

contemporary music festival, the Bella Skyway Festival - a multimedia show prepared by an

international group of artists, the "Two Theatres" Festival, the Gdańsk Music Festival, the Mozart

Festival in the Warsaw Chamber Opera, and many others.

In 2021, Bank Millennium was awarded for its involvement in the promotion of culture - with the

Culture Atlas title for the 6th time by the Kraków Festival Office for its sponsorship of the Sacrum

Profanum festival. In turn, in the Golden Banker competition, the Bank Millennium-supported

Millennium Docs Against Gravity Film Festival, together with the 2020 Docs Against Isolation event,

were recognized by Internet users, taking the second place on the podium in the "Golden Banker"

competition in the "Socially Sensitive Bank" category.

Millennium Docs Against Gravity Film Festival

The Millennium Docs Against Gravity Film Festival was the most important cultural project endorsed

by the Bank in 2021. It is the largest film festival in Poland and a major documentary film festival in

the world. Bank Millennium has been a partner of the Festival for 16 years and has signed an

agreement to extend its cooperation for 2022-2024.

In September 2021, the 18th edition of the Millennium Docs Against Gravity Festival took place, for

the second time in the hybrid formula. Bank Millennium and the festival organizer met the needs and

expectations of all fans of culture by giving them access to 150 documentary films from around the

world in cinema halls in seven cities and online on the festival platform. Additionally, as part of the

Millennium Docs Against Gravity Festival Weekend event, selected films were presented in 27 cities

in Poland. The festival is not only about film screenings, but also debates and initiatives concerning

important social issues, such as ecology or diversity. The 2021 hybrid edition of the Festival attracted

a total audience of 134,000.

The Millennium Docs Against Gravity Film Festival is the biggest celebration of documentary cinema

in Poland and its popularity is growing every year. The authors of the festival, as well as its sponsor -

Bank Millennium - want to bring knowledge about the modern world to as many people as possible.

The festival owes its intensive development, among other things, to its nomadic character. The

festival's presence in multiple cities and, starting in 2020, online, allows the best documentaries from

around the world to reach a wide audience. Thanks to that Millennium Docs Against Gravity achieves

its main goals - film and social education, brining audiovisual culture to a wide audience (not only in

big cities) and bringing emotions.

Bank Millennium extends the barrier-free community concept also in the non-banking sphere. In 2021,

for the third consecutive year, during the 18th edition of the festival, selected films were available

with audio description and voice-over, making it easier for people with visual impairments to access

the world of culture.

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3.8.4. SUPPORTING EDUCATION

[GRI 203-1] In 2021, the Bank continued its cooperation with renowned universities, including the

Warsaw School of Economics and the University of Warsaw, supporting universities in improving the

quality of their infrastructure and changing their operating model during a pandemic, as well as

students and graduates in developing their competencies. An example of cooperation is the coworking

centre established by Bank Millennium and Warsaw School of Economics. It is a place for physical or

virtual meetings, networking, consultations with business theoreticians and practitioners from the

University and the Bank. The coworking centre serves students and alumni who have founded or are

planning to found their own startup and want to bump their ideas up to business reality. In 2021, due

to the pandemic, most of the activities were completed online.

As part of its cooperation with the Warsaw School of Economics, in 2021 Bank Millennium took part in

a conference on Big Data, organized by the Students' Statistics Circle. For the first time the conference

was organized in the on-line formula, which made it possible to increase its range and reach out to

students and graduates of all universities in Poland. Bank Millennium’s representatives ran one of the

presentations. The Bank also participated in the 4th edition of the Business Sails competition

dedicated to smart organizations. Bank Millennium’s representative was a member of the competition

chapter. In October 2021, there was a presentation of the winners during the Warsaw School of

Economics Entrepreneurs' Club meeting.

3.8.5. SUPPORTING DIVERSITY

[GRI 103-1, 103-2, 103-3] The Bank is a signatory to the Diversity Charter and takes steps to support

diversity within the banking community and outside the organization. In 2021, it took action to support

the role of women in society and supported an initiative presenting the issue of neurodiversity. The

Bank was included in the "European Diversity Leaders 2022" ranking. In the latest Financial Times list,

850 employers were selected from among 15,000 European companies as supporters and promoters

of diversity in their organizations. The ranking was based on feedback from 100,000 employees and

human resources and recruitment experts. The research firm Statista is a substantive partner of the

project.

“Believe in yourself” project

In 2019 Bank Millennium became one of the patrons of the scientific and educational project "Believe

in yourself" exploring the areas of self-esteem, the impact of appearance on self-esteem and self-

confidence. The project was carried out by scientists and NEUROHM in cooperation with, among

others, Kozminski University.

Support for female Paralympic athletes

Bank Millennium has funded a scholarship for one of the Polish female Paralympic athletes in

cooperation with the Unaweza Foundation and the #CorinneRunsForGood campaign. Bank Millennium

did not remain indifferent to women with disabilities who play sports professionally, struggling with

their barriers and training hard, as well as the runner who decided to run one of the toughest

ultramarathons in the world to raise awareness of the Paralympic athletes' situation. The Bank

supported the female Paralympian fundraising by making a donation to cover the cost of a one-year

scholarship for one Paralympian, which will help her prepare for the Paralympics in Paris.

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MANAGEMENT

4.1. APPLICATION OF CORPORATE GOVERNANCE PRINCIPLES

The Bank operates on the basis of best ESG (Environmental, Social, Governance) practices and

complies with corporate governance principles. The company is listed in WIG-ESG - the index of

socially responsible companies on the Warsaw Stock Exchange and for several years has been reporting

on issues related to running a responsible business.

Best corporate governance practices

On 29 March 2021, the WSE Supervisory Board adopted new corporate governance rules for companies

listed on the WSE Main Market - “Best Practices for WSE Listed Companies 2021" (Best Practices 2021,

DPSN2021). Best Practices 2021 replaces the previous document in force since 2016, reflecting current

trends in corporate governance. Best Practices 2021 came into force on 1 July 2021 and the deadline

for the first report on their application was set for 31 July this year.

The Bank has meticulously reviewed the new rules. To this end, dedicated problem-solving workshops

were organized to clarify stakeholder concerns, ensuring proper assessment of compliance and

determining possible adjustment actions.

This resulted in ultimate adaptation to the text of DPSN2021 within the timeframe set by the WSE,

which was also confirmed in the relevant report. In the Bank's opinion, the Bank complies with all the

rules set forth in the document entitled "Best Practices for WSE Listed Companies 2021".

4. GOVERNANCE

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4.2. GOVERNANCE STRUCTURE

[GRI 102-18] According to the Articles of Association of Bank Millennium, the Bank’s governing bodies

include: Shareholder Meeting, Supervisory Board and Management Board.

The Shareholder Meeting - among other things it examines and approves the financial statements

and the activity report of the Bank and the Bank’s Group for the financial year, it adopts a resolution

on distribution of profit or coverage of loss, its grants a discharge to members of the Bank's governing

bodies on the performance of their duties, it selects and dismisses Supervisory Board members and

sets their compensation, adopts resolutions to issue its opinions on the Supervisory Board’s report on

compensation.

The Supervisory Board supervises the Bank’s operations, including the operation of risk management

and internal control systems. It also defines the number of the Bank’s Management Board members,

appoints and dismisses the Chairman, Deputy Chairmen and other members of the Bank’s Management

Board and sets their compensation.

The Supervisory Board may establish standing or ad hoc committees to perform specific activities.

The Supervisory Board’s standing committees are the Audit Committee, the Personnel

Committee, the Strategic Committee and the Risk Committee. Most Audit Committee members,

including its Chairman are independent within the meaning of the Act on Statutory Auditors, Audit

Firms and Public Oversight. The Supervisory Board has 12 members (9 men and 3 women). Seven

members of the Supervisory Board, including its Chairman, are Polish citizens. Seven of the

Supervisory Board members are not related to any shareholder with at least 5% of the Bank's

shares. The term of office of the Supervisory Board lasts three years.

The Bank's Management Board manages all of the Bank's operations and represents it externally.

Based on the basic organizational structure approved by the Supervisory Board, the Management Board

determines a detailed organizational chart of the Bank. The Management Board defines the principles

pertaining to Bank’s operation, work organization and its human resource policies. Additionally, the

powers of the Management Board include, among others, developing and submitting reports and other

documents describing the Bank’s operations to the Supervisory Board and the Shareholder Meeting,

convening a Shareholder Meeting, establishing the Bank’s internal regulations, appointing committees

authorized to monitor specified matters in a continuous manner. The Bank’s Management Board has

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7 members. Four members of the Management Board are the citizens of Poland. The Management

Board’s term of office shall be three years.

Within the management structure, the President of the Bank's Management Board is responsible for

overseeing the area of sustainable development.

In 2021, the provisions of the Bank's Articles of Association regarding the Bank's governing bodies were

amended to reflect changes in the law (e.g. § 8.1, § 15.1 and § 15.3, § 21.5 of the Articles of

Association) - the consolidated text of the Articles of Association is available on the Bank's website.

[GRI 405-1] Bank

Millennium’s

Management Board

by age group

Men Women

Total

[30-50] 0 (0%) 0 (0%) 0 (0%)

≥50 7 (100%) 0 (0%) 7 (100%)

Total 7 (100%) 0 (0%) 7 (100%)

Governance structure in the Bank’s companies

The entire Management Board of Bank Millennium sits on the Supervisory Boards of the following

companies: Millennium Dom Maklerski SA, Millennium Leasing sp. z o.o. and Millennium Goodie sp. z

o.o. In the Supervisory Boards of the remaining companies of the Bank Millennium Group, members

of the Bank's Management Board constitute a majority of the Supervisory Board composition, except

for a new company in the Group structure - Millennium Financial Services sp. z o.o. (the company was

registered under the name Millennium Financial Services sp. z o.o. in KRS on 18 January 2022, its

previous name was Flambortille Investments sp. z o.o.), which does not have a Supervisory Board.

Additionally in the case of Millennium Bank Hipoteczny S.A. (apart from 4 members of the Bank

Millennium S.A. Management Board) the Supervisory Board is composed of independent members in

accordance with the law.

Millennium Dom Maklerski is the owner of Millennium TFI. Representatives of Millennium Dom

Maklerski and independent members, in accordance with the legal regulations, sit on the Supervisory

Board of Millennium TFI. As the Bank’s Management Board sits on the Supervisory Board of Millennium

Dom Maklerski, it also supervises Millennium TFI (the mutual fund management company).

Pursuant to the Act on Covered Bonds and Mortgage Banks, a trustee and at least one deputy trustee

is appointed by the Polish Financial Supervision Authority at each mortgage bank on the motion of the

supervisory board of such bank. On 20 May 2021, the Polish Financial Supervision Authority, on the

motion of the Supervisory Board of Millennium Bank Hipoteczny, appointed a Trustee and Deputy

Trustee at Millennium Bank Hipoteczny.

4.3. MANAGEMENT APPROACH TO SUSTAINABLE DEVELOPMENT

[GRI 102-12] The basis for defining the approach to managing sustainable development is an agenda

formulated by the United Nations that includes 17 goals, 169 targets, and 304 indicators. Bank

Millennium signed a declaration regarding the implementation of the UN Sustainable Development

Goals in 2017.

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The Bank is guided by all 17 goals, but the following goals receive the highest attention:

Good health and

well-being

Quality education

Gender equality

Decent work and

economic growth

Industry,

innovation and

infrastructure

13.

Climate action

17.

Partnering for the

goals

As of 2018, the Bank is a signatory to the Diversity Charter. The Charter is a pledge signed by

organizations that choose to prohibit discrimination in the workplace and work to create and promote

diversity.

In Bank Millennium, actions towards sustainable development are an integral part of the business

strategy. ESG is also included in the Group’s new strategy for 2022-2024, which was announced in

December 2021. This issue is discussed in detail in Section 1.4 of this report ("ESG is an integral part

of the new strategy for 2022-2024").

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Bank Millennium’s priority is to provide the highest quality of client service, conduct ethical

marketing and sales and facilitate the utilization of banking and non-banking services (e.g. e-

administration) by introducing facilities for people with disabilities and innovative services. Also

employees are the recipients of ESG activities. In addition to ensuring stable and attractive working

conditions and offering an opportunity to get involved in social activities the Bank promotes

diversity in the organization. Social programs are run through the Bank Millennium Foundation and

focus primarily on financial education and development of employee volunteerism.

[GRI 102-11] The Bank also attaches great importance to environmental and climate protection issues

and carries out its activities in the spirit of the strategy formulated by the European Union and its

member states. The Bank has defined its approach to these issues in the "Environmental Policy of the

Bank Millennium Group". These issues are discussed in detail in section "Managing Environmental

Impacts and Climate Protection".

Work on a model for managing ESG issues in the organization

In 2021, the readiness of the Bank and selected Group entities (Millennium Leasing, Millennium TFI)

to operate in compliance with applicable regulations covering ESG and market best practices on ESG

was analyzed.

The analysis included, among other things:

• Review and adaptation of the organizational structure to meet new challenges;

• Development of a methodology for reporting data/indicators based on external data;

• Identification of new reporting duties and expected disclosures to be presented in annual ESG

reports of the Bank Millennium Group in 2021-2024 resulting, among others, from EU

regulations;

• Definition of other reporting duties beyond the annual ESG report;

• Development of an approach to climate scenarios;

• Development of an approach to emissions targets;

• Further development of approaches to new opportunities and risks following from climate

issues.

Establishment of Sustainable Development Committee and Sustainable Development Department

[GRI 102-26] The President of the Bank’s Management Board is responsible for overseeing the pursuit

of the sustainable development goals at the highest level.

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Bearing in mind the growing significance of sustainable development for the Bank Millennium Group’s

business, in 2021 the Bank established within its structures the Sustainable Development Committee

and the Sustainable Development Department.

The Sustainable Development Committee is chaired by the President of the Bank’s Management Board.

The Committee is composed of all members of the Bank's Management Board, as well as

representatives of the units performing tasks related to sustainable development in the Bank and the

Bank's Group. The Committee meetings are held not less frequently than once a quarter. The

Committee's tasks include recommending a sustainable development strategy to the Bank's

Management Board, adopting operational plans related to the implementation of this strategy and

monitoring the implementation of the planned actions, evaluating the impact of sustainable

development principles on the Bank's activity, approving and monitoring KPIs and KRIs in the area of

sustainable development, providing the Bank's Management Board with periodic information on key

aspects of sustainable development.

The Bank has also established a Sustainable Development Department supervised directly by the

President of the Bank’s Management Board. The purpose of the Department is to supervise and

coordinate the implementation of sustainable development principles in the Bank and the Bank's

Group. The scope of the Department’s tasks includes, among others: coordination of work related to

the sustainable development strategy, cooperation with other units of the Bank and entities of the

Bank's Group in the implementation of the sustainable development principles, ensuring identification

of risks related to climate change in the Bank's operations, cooperation with other units of the Bank

in the implementation of sustainable products, conducting activities aimed at promoting sustainable

development principles among the Bank's employees.

Sustainability activities in the respective reporting areas are the responsibility of the individual units

of the Bank and the Bank’s Group in accordance with their areas of responsibility, forming an integral

part of the business.

[GRI 102-26, 102-31] The execution of the strategy is subject to regular reviews and assessments. They

are carried out by the Bank’s Management Board, based on information prepared by the entities

responsible for their implementation and by the Bank’s Supervisory Board. Global assessment of the

Bank’s activities, including the management of economic, environmental and social issues, is

performed by the Supervisory Board based on the Bank’s published statements. They are analyzed

and presented to the at the Shareholder Meeting and form the basis for granting a discharge to the

Bank’s Management Board on the performance of its duties in a given financial year.

All ESG activities have been summarized once a year since 2006 in the Bank Millennium Group’s

Corporate Social Responsibility reports.

Confirmation of the quality of conducted activities in market assessments

The Bank’s adherence to sustainable development principles has been confirmed by external

assessments. Since 2010, the Bank has been included in the Warsaw Stock Exchange’s index composed

of companies fulfilling the highest standards of corporate social responsibility. In 2010-2019, the Bank

was included in the Respect Index, and since 2019 it has been incorporated in the WIG-ESG index,

which is created by attaching additional weights to companies in the form of an ESG (Environmental,

Social and Governance) rating provided by the global ratings firm Sustainalytics and by conducting a

corporate governance assessment by the Warsaw Stock Exchange.

Bank Millennium has an ESG rating of "A" by MSCI and "Medium Risk" by Sustainalytics.

In 2021, the Bank was once again awarded the CSR Golden Leaf, the highest category of distinction

in the Polityka weekly ranking.

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4.4. RISK MANAGEMENT

[GRI 102-11] Bank Millennium manages different types of risk. The overriding risk for the Bank is the

risk related to the safety of its clients’ funds. It is the product of other risks, including, among others,

financial and operational risks, as well as social, environmental, employment and human rights risks.

Every year the Bank evaluates the significance of the types of risk identified, it drafts the relevant

management procedures and it sets up capital buffers if justified. Due to the nature of its activities,

the risk of the Bank's direct impact on the environment has been assessed as immaterial. However, in

order to fully understand the wide range of interrelationships between the Bank's activities and

environmental risks, the Bank has chosen to incorporate various environmental aspects into the

assessment of other risks directly related to the Bank's operations as separate risk factors. Currently,

the environmental aspect is taken into account in the annual assessment of the materiality of

individual risks in the context of credit risk, market risk, operational risk, including reputation risk.

The risk management process in the Bank and the Bank Millennium Group is uniform to a high degree

and it may be treated as a common system applicable to the overall Group.

[GRI 102-30] The risk management structure defines individual management levels and the scopes of

duties and responsibilities. The owners of business and supporting processes play a crucial role in the

Group’s daily activity. Owners are best fit to identify and curtail the threats that occur as the first

line of defence based on their profound process knowledge. The second line of defence is the level

of specialized entities that deal with the organization of management processes and the control of

an acceptable level of risk, with special emphasis on the following areas: compliance, countering

abuse, employee issues, safety and ensuring business continuity, insurance and subcontracting. The

third line of defence is the independent internal audit unit.

The Bank’s Management Board designs and introduces a risk management system and monitors its

operation. The Bank’s Supervisory Board oversees the implemented system and assesses its adequacy

and effectiveness at least once a year.

4.5. ETHICAL STANDARDS AND HUMAN RIGHTS

[GRI 102-16] The Bank Millennium Group has a system for managing ethics that consists of the

following:

 Code of Ethics - lays down our ethical principles. The Compliance Department is responsible

for articulating the principles described in the Code, communicating and evaluating the

adherence to the principles of ethics;

 By its actions and conduct, the Bank's Management Board promotes high ethical and

professional standards, including in particular an awareness of the importance of risk in the

Bank's business and a risk culture;

 Ethics Officer – the function of the Ethics Officer is exercised by the head of the Compliance

Department. The tasks of the Ethics Officer include safeguarding the compliance with the

Code of Ethics, promoting and disseminating information about ethical standards, ordering

inspections of compliance with ethical principles and verifying cases of their breach;

 system for training in ethics and notifying changes in the rules of ethics;

 procedures, policies and rules containing guidelines on proper conduct;

 system for reporting breaches of ethical standards, also anonymously;

 rules of ethics compliance monitoring system - the Compliance Department at least annually

assesses the risks associated with ethics violations. A report from the assessment is drafted,

which is presented to the Bank’s Management Board. The Bank's Management Board

periodically verifies and assesses compliance with the rules of ethics in order to adjust them

to the changing internal situation in the bank and the bank's environment, and at least once

a year informs the Supervisory Board about the results of the assessment.

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The Code of Ethics contains principles and values that should guide employees in the performance

of their duties and in their relations with their colleagues and with the Bank as an employer. The

Code also sets out guidelines for relations with clients, the market and suppliers, referring to such

areas as: respect for human rights, quality of service, ethical sales, fair competition and

communication, focus on ensuring long-term continuity and sustainable development, principles for

conducting business relations, anti-money laundering, anti-corruption, including rules on accepting

and giving benefits, and participation in and organisation of tenders. The Code of Ethics also applies

to franchisees and employees at franchise locations.

The Bank also has in place a separate Code of Ethics for the employees providing services to the

Prestige and Private Banking segment clients. The Code outlines, in particular, the rules for ethically

performing the financial operations, collaboration with third parties, performance of operations on

own accounts, and transaction authorization rules. It also sets forth the employees’ duties and the

rules on how to handle confidential information and professional secrets which may be accessed by

them in the course of performance of their professional duties. Treasury Department employees

responsible for executing client transactions and interbank operations also adhere to their own codes

of conduct.

Every employee is obligated to become familiar with the Code by completing a mandatory e-

learning course, confirm their knowledge and apply the rules included in the Code in their daily

work.

[GRI 102-17] Employees have the possibility to report violations of ethical standards via email

or postal mail (also anonymously). In 2021 there were no reported violations of the Bank's rules of

ethics.

Notwithstanding the above, employees receive mandatory training in the area of managing conflicts

of interest and information considered confidential. These materials are intended to sensitize

employees on how to identify and handle situations, which in any way may cause a conflict between

the interests of Bank Millennium and the client, as well as how to handle information, which is or may

be price-sensitive and its disclosure could affect the price of financial instruments.

As part of such training, employees also learn what responsibilities (including legal orders and

prohibitions) are associated with conflict situations and with coming into possession of price-sensitive

information. The role of employees as those who must actively identify their own behaviour as well

as that of other employees and clients is highlighted in the examples.

All the above-mentioned training makes up a mandatory package of regulatory training that every

Bank employee is required to undergo.

[GRI 205-2, 412-2] Trained Bank Group Bank Group Bank Group

on the Code of Ethics* 2021 2021 2020 2020 2019 2019

Managerial staff trained in the year

22 25 20 25 22 27

2.29% 2.43% 2.80% 3.30% 2% 3%

Other employees trained in the year

1,064 1,108 751 781 1,217 1,265

18.38% 18.25% 10.50% 10.20% 24% 23%

Total percentage of trained managers 94.09% 93.99% 93.49% 93.46% 92.59% 92.17%

Total percentage of trained other

employees

93.10% 92.97% 92.92% 92.76% 91.48% 91.44%

* Number and % of persons trained on the Code of Ethics. The training covers all persons employed in the

Millennium Group.

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In addition, the employees of Millennium Dom Maklerski comply with the “Code of Best Practices of

Brokerage Houses” adopted by members of the Brokerage Houses Chamber.

To ensure safety of the funds entrusted by clients, full information on the principles of operation of

products and their advertising and sales Millennium Towarzystwo Funduszy Inwestycyjnych, apart

from applying the Bank Millennium Group’s Code of Ethics, also complies with the law binding on

investment fund companies.

[GRI 103-1,103-2,103-3] The issues concerning respecting human rights are described in the Bank

Millennium Group’s Code of Ethics, the diversity policy as well as in anti-discrimination and anti-

mobbing procedures.

In 2021, Bank Millennium conducted a self-assessment process of its human rights policies. The

assessment covered, among other things, employment policies and labour and safety standards.

Impact on local communities or relationships with suppliers/business partners were also analyzed. The

results of the review are subject to detailed internal analysis.

[GRI 103-1,103-2,103-3] The Bank Millennium Group acts with respect for human dignity, opposes

discriminatory practices and observes the right to equal treatment irrespective of gender, age,

disability, race and ethnic origin, skin colour, ancestry and territory of origin, religion, nationality,

political beliefs, trade union membership, creed, sexual orientation, employment for a definite or

indefinite period of time, full-time or part-time employment, and other premises, which expose an

employee to discriminatory behaviours. Such information does not constitute a criterion for selecting

employees, terminating their employment, setting terms and conditions of employment, promotion,

or access to benefits or training to improve professional qualifications.

In the Bank Millennium Group, employees enjoy, among others, the right to information and

consultation, collective bargaining agreements and collective action, social and housing assistance as

well as good working conditions and access to health care. The Group’s policies and the results of

their application are described in the “Employees” section.

Every supplier taking part in a tender procedure must undertake to observe the rules included in

the Bank Millennium Group’s Code of Ethics, including the respect of human rights and compliance

with anti-corruption policies, by signing a representation to that effect. A clause requiring

compliance with the Code of Ethics is also included in contracts with suppliers.

In addition, Bank Millennium has provisions in its lending rules and regulations for Corporate Banking

clients on all clients having to meet the requirements of environmental protection and respecting

employment rules. In addition, the rules and regulations contain certain restrictions regarding the

financing of socially harmful activity featured on the EBRD Environmental and Social Exclusion List.

The limitations commit all borrowers, among others, not to use the funding received from a loan

for projects associated with forced labour and all forms of discrimination in employment.

4.6. THE BANK IN THE MARKET ENVIRONMENT

4.6.1. RELATIONS WITH THE CAPITAL MARKET

Bank Millennium is the first Polish bank listed on the Warsaw Stock Exchange (since 1992). Presently,

the Bank is a member of the WIG, WIG 30, Mwig 40, WIG Banks and the WIG-ESG indices.

Fast and accurate information for investors

The priority in investor relations is to fairly provide timely information concerning the strategy,

business and financial performance of the overall Bank Millennium Group. The list of communications

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published by the Bank Millennium Group, including their frequency and place of publication, is

available on the Bank’s website in the Investor Relations section

https://www.bankmillennium.pl/en/about-the-bank/investor-relations

On the website you will find always up-to-date information about, among others, the prices of Bank

Millennium’s shares on WSE, the company's shareholding, Shareholder Meeting, dividend history or

credit ratings. It also contains current and periodic reports, profit and loss presentations, xlsx

spreadsheets with key financial information and other important information about the Bank. It is

worth noting that the website is responsive, which means that it is adapted to mobile devices - tablets

and smartphones.

[GRI 102-43] The Bank uses various communication channels in order to reach present and prospective

shareholders. These are mostly:

 regular conferences with the participation of the Management Board on the quarterly

performance of the Bank’s Group (4 in 2021),

 participation in conferences organized for investors in Poland and abroad (8),

 individual and group meetings with capital market players (431),

 current stock exchange reports (36) and press releases,

 dedicated website in the Bank’s portal on investor relations,

 encouraging people to participate in the annual Shareholder Meeting,

 ongoing contacts with market participants (by e-mail or telephone).

To ensure best practice in equal access to information, since 2006 the Bank has enabled unlimited

access to these conferences via the web (video transmission in Polish and English) and by telephone.

A transcript of every conference is available on the Bank’s website. The Bank also offers a webcast

of the Shareholder Meeting. A transcript of the discussion and resolutions is also available on the

Bank’s website.

Meetings with capital market players 2021 2020 2019 2018 2017

Number of meetings 114 123 168 155 183

Number of participants 431 434 360 355 373

Bank Millennium is analyzed by 12 analysts representing local and international brokerage firms, who

publish their reports and recommendations on Bank Millennium’ stocks. A full list of the analysts can

be found on the Bank's website

https://www.bankmillennium.pl/en/about-the-bank/investor-

relations/analysts

In 2021, according to the Bank's knowledge, brokerage houses have issued 49 recommendations for

Bank Millennium shares, out of which 16 are "Buy", 17 "Hold", 4 "Neutral" and 12 "Sell". As at 31

December 2021, the recommendation structure (not older than 6 months) was as follows:

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Buy

Hold

Sell

5 2 2

4.6.2. COOPERATION WITH TRADE ORGANIZATIONS

[GRI 102-13] The Bank is a member of a number of trade organizations operating on a regional, national

and international level. Some of them focus on the area of corporate business (Chambers of

Commerce, Trade and Industry), others - on improving relations and knowledge of employees with

specific competencies (Polish Chamber of Statutory Auditors or Institute of Internal Auditors). The

most important industry organizations are: Polish Confederation Lewiatan (representing the interests

of employers in Poland), Polish Association of Listed Companies, ACI Poland Financial Markets

Association, Polish Association of Factors, Employers of the Republic of Poland, Polish-Portuguese

Chamber of Commerce, Polish-German Chamber of Industry and Commerce, Pomeranian Employers,

Polish Business Council, SinoCham Polish-Chinese Main Chamber of Commerce.

The Bank is also a member of the Polish Bank Association, an organization associating and

representing the interests of all banks operating in Poland. It helps banks and clients form the right

relationships and optimal development. The Bank's specialists participate in the work on solving

difficulties and issues specific to the whole sector, among others in the work of the Committee on

the Quality of Financial Service and the Banking Cybersecurity Centre.

Millennium Leasing is a member of the Polish Leasing Association and Millennium TFI of the Chamber

of Fund and Asset Management (IZFiA).

4.6.3. BUSINESS PARTNERS

Procurement policy

[GRI 102-9] The Bank cooperates with many business partners as the buyer of products and services

from various market segments. The key business partners render services associated with the lease

of and support for branches and office space, services and purchase of IT equipment and security and

marketing services.

[GRI 103-1,103-2,103-3] The principles of cooperation with Bank Millennium’s suppliers are described in

the Instructions for selecting suppliers and making purchases. These instructions define, among other

things, how the procurement process is organized, the role played by the various process participants

and the supplier selection criteria. Suppliers are selected in tenders, which allows the Bank to use

objective selection criteria. To ensure transparency of the procurement process, the substantive

and commercial evaluations of bids are done by independent Bank units. The chief risk ensuing from

inappropriate cooperation with suppliers involves a limitation on the ability to render banking

services.

The Bank collaborates with brokers on the basis of agency agreements. Collaboration involves the

Bank entrusting businesses to perform the activities prescribed by the agreement related to acting as

an intermediary in the sales of mortgage products. Ordinarily, the agency agreements entered into

by the Bank are outsourcing contracts. Some of the Bank's branches are operated under franchise

agreements with entrepreneurs.

The Bank’s Companies collaborate with business partners on the basis of agency cooperation

agreements. These agreements are entered into with business entities or individuals working in a

given organizational unit (Representatives).

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Criteria for selecting suppliers

The criteria for selecting suppliers in tender procedures include: good ratio of quality to cost of the

services or products and the terms of delivery and payment. The bidder's substantive capabilities and

financial reliability are also taken into account.

Geographical location of the suppliers is not one of the selection criteria. In justified cases, the Bank

also includes environmental and social factors among the aspects that affect its choice of

suppliers.

For purchases of goods used by the entire Group, the Bank's supplier selection policy is applied.

Specific supplier selection criteria are employed by Companies if separate regulations require that,

e.g. the ones governing the operations of funds and investment fund companies at Millennium TFI.

Ethical and environmental standards

[308-1, 414-1] The requirement to apply ethical and/or environmental clauses in agreements, where

applicable, is an important element of the regulation pertaining to the procurement process (for

example OHS regulations in the contracts for provision of construction or environmental services in

agreements on waste disposal).

[GRI 205-2, FS5] Every supplier taking part in a tender procedure must

undertake to observe the rules included in the Bank Millennium Group’s Code of Ethics, including the

respect of human rights and compliance with anti-corruption policies, by signing a representation to

that effect. In addition, a clause confirming supplier compliance with the Code of Ethics has been

included in currently concluded supplier agreements. In 2021, all Bank Millennium suppliers

participating in tenders familiarized themselves with the anti-corruption policies contained in the

Bank Millennium Group’s Code of Ethics.

The performance of agreements of significance to the Bank is monitored. The quality and

timeliness of services and goods and financial standing of the suppliers are evaluated.

In justified cases, audits are conducted in suppliers' offices to assess their security and continuity of

their business activity. In 2021, the quantity and quality of goods and services supplied was monitored

for approx. 1,946 agreements by the Bank. In the case of 35 agreements, the suppliers’ financial

standing and their contingency plans were monitored. The quantity and quality of goods and services

supplied was monitored for roughly 2,131 agreements by the Bank Millennium Group.

Products and services

purchased

Group

2021

Bank

2021

Group

2020

Bank

2020

Group

2019

Bank

2019

[GRI 102-9, 102-10]

Number of suppliers

13,831 6,639

12,592

6,679 13,948 6,352

[GRI 204-1] % of

amounts paid to local

suppliers*

93% 95%

95%

94% 92% 91%

* with registered offices in Poland

Invoice payment

term

Group

2021

Bank

2021

Group

2020

Bank

2020

Group

2019

Bank 2019

Up to 30 days

83%

75%

77%

67%

81%

60%

31-60 days

14%

21%

18%

26%

16%

33%

Over 60 days 3% 4% 5% 7% 3% 7%

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Millennium TFI’s partners

[GRI 102-9] The activity of Millennium TFI and the funds it manages involves different types of

business partners. These include: the transfer agent maintaining the participants' registers, the

custodian of the funds' assets, the distributors of units, the entity maintaining the funds' books and

calculating the value of the funds' assets, the providers of office, transport, legal and IT services, the

entity maintaining the documents and the entity handling the circulation of correspondence, the

entity maintaining the Company's books (Bank), banks and brokerage houses as business partners of

the funds. The main categories of service providers to the Company and the funds are unit

distributors, transfer agent, custodian of the funds’ assets, the funds’ business partners (banks and

brokerage houses), legal advisors, financial auditors and IT service providers.

Agreements with Millennium TFI’s suppliers are concluded, and the terms and conditions for the

provision of services are defined, on the basis of legal regulations governing the activity of funds and

fund management companies. To the extent not covered by the above regulations, the Company

applies the Bank Millennium Group’s Code of Ethics regulating the principles of establishing and

maintaining relations with suppliers of goods and services.

The main criteria for selecting suppliers are set out in the regulations governing the activity of funds

and investment fund companies. Due to different regulations concerning companies and banks, the

criteria used by the Company may differ significantly from the criteria used by Bank Millennium. To

the extent to which the Company employs group solutions for purchases of goods and services, the

applied supplier selection policy is consistent with the principles laid down in the Bank Millennium

Group’s Code of Ethics.

[GRI FS5] The Company did not commit its suppliers to comply with ethical or environmental standards.

Such commitments are applied in cases where the Company concludes group contracts with suppliers,

in accordance with the principles contained in the Bank Millennium Group’s Code of Ethics.

Millennium Leasing’s partners - suppliers of leased assets

Millennium Leasing cooperates with suppliers of fixed assets, which are the subject of leasing

agreements. The cooperation is implemented through Vendor Programs. A potential partner, before

entering into cooperation, is verified by Millennium Leasing in terms of business potential, existing

portfolio of joint contracts, credibility, and in certain cases a screening of the potential Vendor is

performed by the Millennium Leasing Risk Department.

In most cases Millennium Leasing concludes cooperation agreements with suppliers of leased

assets, providing for remuneration for the supplier for leads delivered to Millennium Leasing. The

agreements have the nature of agency agreements and do not bind the parties on an exclusive basis.

Within the framework of the Vendor Programs Millennium Leasing cooperates both with leading

suppliers (importers, dealers) - leaders in their segments, as well as with smaller, local players, e.g.

with car consignment stores. Millennium Leasing’s Vendors are suppliers of cars and trucks, truck

tractors and semi-trailers, construction machinery, forklifts, production machinery, e.g. for metal,

plastic and wood working machinery, printing machines, as well as PV installations.

[GRI FS5] The Company did not commit suppliers of leased assets to comply with ethical and

environmental standards. Such commitments are applied in cases where Millennium Leasing concludes

group contracts with suppliers, in accordance with the principles contained in the Bank Millennium

Group’s Code of Ethics.

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4.7. TAX POLICY

[GRI 103-1, 103-2, 103-3, 207-1] The Bank perceives the fulfilment of its tax obligations, including the

proper and timely payment of tax liabilities, as an element of corporate social responsibility and its

important social mission contributing to the sustainable social and economic development of the

Republic of Poland providing also the necessary foundations for the sustainable development of the

Bank.

The Bank's tax policy is set out in the document "Tax Policy of Bank Millennium S.A." available at:

https://www.bankmillennium.pl/en/about-the-bank/corporate-bodies-and-governance

The tax strategy is approved by the Bank’s Management Board based on the recommendation of the

Head of the Tax Department. The tax strategy is subject to ongoing reviews and updates by the Head

of the Tax Department adapting it to the dynamically changing regulatory environment in Poland.

[GRI

207-2]

Chapters III and IV of the "Bank Millennium S.A.’s Tax Policy" describe in detail the principles

and process of tax risk management in the Bank.

Tax planning and interpretation of tax laws in the classification of various events and projects is done

keeping in mind the Bank's low appetite for tax risk and maintaining the highest standards of diligence

to ensure tax compliance. In order to ensure tax compliance, the Bank maintains appropriate tax

governance governed by intra-bank acts defining the roles and responsibilities of the Bank's

organizational units, as well as senior and junior management within the tax processes, taking into

account the guidelines issued by the National Revenue Administration (KAS) resulting from the Internal

Tax Supervision Framework published by the Ministry of Finance providing assurance of proper

performance of duties.

[GRI 207-3] In its relations with KAS authorities, the Bank ensures transparency and due diligence in the

performance of its duties, in particular by providing reliable, complete and timely explanations in

accordance with the highest standards. As a member of the Polish Bank Association and Polish

Confederation Lewiatan, the Bank participates in social consultations regarding draft amendments to

the tax law. The Bank is open and collects stakeholder opinions and concerns on tax issues by

responding in writing to the issues presented. The Bank also publishes on its website the ongoing

stakeholder-related tax processes. The Bank discloses detailed information on tax matters in the

annual information on the implemented tax strategy published pursuant to Article 27c of the CIT Act

(link: https://www.bankmillennium.pl/en/about-the-bank/corporate-bodies-and-governance)

In 2021, Joao Bras Jorge, President of Bank Millennium, during the Congress 590 received from the

hands of Tadeusz Kościński, Minister of Finance, a distinction for Bank Millennium’s high position

among the largest CIT payers.

CORPORATE SAFETY

4.8. SAFETY OF CLIENT FUNDS

Ensuring safety of the funds entrusted by clients is a priority in the activity of the Bank Millennium

Group. Efficient management of this area is governed by the Bank's and Group Companies' safety,

fraud prevention and risk management policies, code of ethical conduct and best market practices.

The Bank’s internal regulators serve the prevention and identification of various risks related to the

conduct of banking business. Employees are trained regularly on the rules for preventing abuse and

ensuring protection of the clients’ funds and data. Additionally, a number of technical safeguards

operating in a multi-layer model (defence in depth) have been implemented in this area.

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Millennium TFI ensures safety of funds entrusted by clients to funds managed by the Company in

accordance with the provisions of law regulating the operation of investment funds and investment

fund companies. Under the Act, the maintenance of participant records and the execution of

participant instructions has been entrusted to a specialized entity, the transfer agent. Safety of assets

belonging to the funds is ensured by their custodian, which for Millennium Funds is Bank Millennium.

4.8.1. SAFETY OF INFORMATION AND TRANSACTIONS

[GRI 102-15, 103-1,103-2, 103-3] The Bank uses its best efforts to ensure the protection of clients’ funds

and privacy. To this end, risk analyses are conducted both before the preparation of new products

and services and globally - describing the whole ICT environment of the Bank. The key risks associated

with inadequate protection of clients’ funds and privacy are leakage, loss or unauthorized

modification of client data.

The information security system in place in the Bank Millennium Group is modelled after the

international ISO/IEC 27001 standard which defines the requirements for establishing,

implementing, operating, monitoring, reviewing, maintaining and improving information security

management in the organization. The information security management system consists of a set of

the documented processes in force in the Bank and in the Bank Millennium Group’s companies in the

part aligned to the profile of the activity they conduct.

The accepted information security management model determines the comprehensive system for

protecting all information processed in the Bank, including information on clients, employees,

business partners and transactions. In order to achieve this goal, the Bank uses a broad range of

organizational, IT, telecommunication measures and in particular device protection mechanisms,

systems, applications, databases and communication channels. The information security management

model was constructed to safeguard against influence being exerted by key risks such as a potential

loss of information concerning financial transactions, a leak of confidential information and

inaccessibility of services.

The data and resources of Bank Millennium clients are under constant oversight of a dedicated

specialist team ensuring security of all the channels used to access the Bank’s products and

services. The company attaches particular importance to the security of our customers using

electronic channels to access banking products and services by improving technical and operational

security measures. The Bank has been using tested and safe methods to confirm identity of IT system

users and is constantly developing them to ensure safe and convenient access to the Bank’s systems.

Our clients may use innovative identification methods such as biometric fingerprint data.

Implemented solutions and the implementation of existing policies and legal requirements are

subject to regular audits and tests performed by both professional teams of internal auditors and

recognized companies in the IT security area.

New threats and methods employed by criminals are undergoing constant analysis to be able to

counter them even more effectively. In addition, the Bank has been actively collaborating with

other financial sector entities in Poland and internationally, sharing its knowledge about

contemporary threats, trends and the evolving methods of abuse.

The obligatory educational program applicable to all employees is a significant part of the Bank’s

information security system. It contains a set of information about the best practices in personal data

protection, banking secrets, company secrets and other confidential data. The training covers both

employees of the Bank Millennium Group and employees of cooperating companies, who may have

access to the Bank's network.

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Safety training

Bank Millennium Group

2021 2020 2019 2018

% of employees trained 90% 91% 91% 92%

4.8.2. PROTECTION OF PERSONAL DATA

[GRI 103-1, 103-2, 103-3] Bank Millennium processes personal data inter alia to conclude an agreement,

to perform a number of duties imposed on the Bank, to maintain bank accounts, to securely execute

instructions and to inform clients about new products and services. The Bank as a data controller

makes every effort to implement the requirements of the Data Protection Regulation 2016/679 (GDPR)

to the fullest extent possible and thus protect personal data. Supervision over proper processing of

personal data in the Bank Millennium Group is exercised by the Data Protection Officer. In addition,

a special unit was created in the Bank, i.e. Data Protection Office, whose task is to support the Bank's

employees in fulfilling their duties in the area of data processing.

Bank Millennium processes personal data of clients, employees or other persons who are in

relationship with the Bank, using technical and organizational means necessary to ensure data

security. Personal data is one of the key resources for the Bank and its security is a top priority. The

Bank is constantly improving its technical and organizational measures to ensure the protection of

personal data processing, in particular protecting the data against unauthorized access, loss or

unauthorized modification.

At the same time, in case of Bank Millennium clients, personal data are also covered by banking

secrecy, which entails the obligation to provide even more extensive protection of client relationship

data. In order to ensure the highest standards also in this respect, training is provided in the field of

security of protected information, including personal data protection and bank secrecy.

[GRI 418-1] Significant

complaints concerning

violation of the client’s

privacy and loss of data

in 2021

Number of justified complaints

concerning violation of the

client’s privacy received from

external parties and

acknowledged by the

organization*

Completed proceedings

conducted by the

President of the Office

for Personal Data

Protection (PUODO)**

Total number of

identified incidents of

leaked, stolen or lost

client data***

109

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Of which requiring

reporting to PUODO

* pertains to client complaints filed in person or by representative entities, does not include

PUODO proceedings that are handled outside of the complaint process

** proceedings before PUODO concerning personal data protection violations concluded in 2021

(does not apply to proceedings concluded by an appealed decision)

*** pertains to GDPR incidents registered during the calendar year

4.8.3. FRAUD PREVENTION

Elements of the fraud prevention system are built and tailored to the company's current needs based

on the Fraud Risk Management Program. The system enables coordination of actions taken by the

Bank’s various units involved in fraud detection, investigation and prevention. At the same time it

provides professional tools and solutions to ensure effective protection of the clients’ funds. To this

effect, numerous preventive mechanisms have been designed and implemented to monitor

transaction systems. These tools are constantly developed in order to better identify fraudulent

schemes.

The Bank pays due attention to the training of those responsible for handling clients who report

attempted fraud or who are unwittingly victims of criminals. One of the goals of the Security

Department (which is the owner of the anti-fraud process) is to consistently inform employees of the

risks to which they and the clients are exposed. Among other things, to attain this goal, the

department prepares and publishes substantive articles in the intranet newsletter "Millennium World".

Additionally, in coordination with other units, it sends periodic push/sms/Millenet alerts to clients

and publishes information about criminal schemes on the Bank's websites.

[GRI 102-17] Another important constituent element of the program is the dedicated electronic mail

account and the alarm telephone number that operate 24 hours a day, 7 days a week and 365

days a year. Every Bank employee may immediately clear up any doubt related to a suspicion of

fraud. Alerts are routed to the Fraud Management Department, which plays a support role, making

decisions and directing further actions to minimize the risk of fraud.

The Bank is constantly developing its technical solutions to prevent fraud and uses the latest types of

security features, including those based on artificial intelligence mechanisms.

4.8.4. ANTI-MONEY LAUNDERING AND COUNTERING TERRORISM

FINANCING (AML/CTF)

Bank Millennium identifies and assesses the risks of money laundering and terrorist financing relating

to the Bank's activities, taking into account risk factors concerning clients, countries or geographical

areas, products and services, transactions, their delivery channels, taking into account the nature

and size of the Bank.

The Bank's Internal Procedure for Anti-Money Laundering and Combating Terrorism Financing

(AML/CTF) is a comprehensive system to identify risk areas related to the crime of money laundering

or terrorism financing. In order to minimize the risk, the Bank operates in accordance with the

AML/CTF Procedure, which defines the rules of conduct consistent with national and international

laws and banking standards.

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The Bank applies financial security measures with respect to its clients, appropriate to the level of

identified AML/CFT risk, takes steps to mitigate the risk of opening relationships and conducting

business with persons or entities suspected of obtaining their funds illegally.

The Bank complies with Polish AML/CFT regulations, European Union and United Nations legal

regulations and international banking standards concerning specific restrictive measures (sanctions).

The AML/CFT internal procedure is reviewed at least once a year for compliance with applicable laws

and regulations.

All Bank Millennium employees are obliged to make every effort to prevent the use of the Bank's

products and services for money laundering and terrorist financing and to report any suspicious

activity promptly to the appropriate banking unit.

The Bank conducts AML/CFT training for all employees in order to meet the highest standards, in

particular with regard to the applicable AML/CFT regulations, including inter alia the application of

financial security measures and specific restrictive measures within the client business relationship

and the typology of money laundering. The Bank has procedures and channels in place to report AML

violations that ensure anonymity and fully reflect the requirements of the Act.

The most important functions, roles and responsibilities as well as specific areas, in particular high

risk areas, are adequately described in the Bank's internal regulations. A dedicated AML unit is

appropriately placed in the Bank's organizational structure, and the persons responsible for the Bank's

AML activities have appropriate competence and qualifications.

The Bank's Management Board is regularly informed on how the AML/CFT Procedure is being

implemented. In particular, reporting includes the most relevant information as part of management

information, including major changes in laws and regulations, statistical data and other data required

to present a complete picture of AML/CFT risk in the organization. The Bank has in place a specialized

AML Committee, which receives regular information on this subject, as does the Supervisory Board,

which is informed on at least an annual basis.

Bank Millennium Group companies which are obligated institutions have separate AML/CFT policies

and apply the requirements of AML/CFT regulations in a consistent manner. Employees performing

AML/CFT related duties are appropriately trained in this respect, according to the training program.

4.8.5. PREVENTING CONFLICTS OF INTERESTS

[GRI 102-25] The Bank has implemented Policy for the prevention of conflicts of interest at Bank

Millennium S.A. According to its contents, the Bank has introduced the following rules governing

this area:

 accepting and giving monetary and non-monetary performances ("incentives"),

 review and approval of products,

 appropriate organizational structure (including transparent official reporting structures) and

information barriers,

 compensation policies applied,

 personal transactions,

 engaging in additional or competitive activities,

 transactions with entities from the Bank Millennium Group.

The Bank’s Management Board is responsible for the proper management of conflicts of interests and

supervising them. Periodically, at least once a year, on the basis of the recorded cases of existing

conflicts of interest, the Compliance Department analyzes the reasons for their occurrence and

presents to the Bank's Management Board conclusions aimed at eliminating them in the future.

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Some Companies adhere to specific regulations on top of the regulations that span the Bank Group,

e.g. Millennium Dom Maklerski has a Policy for the prevention of conflicts of interest in Millennium

Dom Maklerski S.A. and Millennium Towarzystwo Funduszy Inwestycyjnych applies the Rules and

regulations for managing conflicts of interest in Millennium TFI S.A.

4.8.6. ANTI-CORRUPTION

[GRI 103-1, 103-2, 103-3] The Bank's approach assumes zero tolerance for any form of corruption, which

can be briefly reduced to accepting or giving benefits (both financial and non-financial) aimed at

achieving a certain behaviour or omission of the other party.

To this effect, in 2021 the Bank implemented a separate regulation dedicated to this subject, entitled

"Anti-Corruption in Bank Millennium S.A. Polices and Guidelines".

The document attempts to comprehensively cover the topic of corruption and addresses the following

areas:

 The roles and responsibilities of individual persons, units and bodies of the Bank - the

responsibility for counteracting corruption rests with each Bank employee, which means that

they are obliged, in the case of suspicion that an act of this kind has been committed, to

immediately inform the relevant Bank services, and if they fear the consequences of their

report, they can provide the information anonymously. The regulation also defines the roles

of the Bank's Management Board and Supervisory Board, which should properly oversee the

implementation and periodic evaluation of the adequacy and effectiveness of the

implemented anti-corruption system. The Bank has also established the function of a

Coordinator responsible for the implementation of the anti-corruption process and

independent monitoring of compliance with the rules imposed by the aforementioned

regulation.

 Relations with business partners - the Bank considers proper relations with its business

partners to be fundamental to the efficient and transparent functioning of the Bank and the

provision of specific services by the Bank to its clients. This imposes a special obligation on

the Bank to analyze each business partner, both at the stage of establishing the relationship

and throughout its duration. Within the framework of this analysis, the relevant Bank services

should pay special attention to such issues as: key personnel of the business partner, negative

information from publicly available sources (including the media), capital and personal

relations with other entities or verification of references.

 Relations with officials - this type of relationship is considered by the Bank in two aspects,

that is, employment and interaction at the official level. As far as the former aspect is

concerned, the Bank, when employing such persons, makes every effort to prevent conflicts

of interest, taking into account the legitimate interests of such persons and the provisions of

generally applicable laws (especially in the areas of personal data protection and labour law).

In the latter case, the Bank has decided to strictly prohibit the giving or receiving of benefits,

irrespective of their value or nature; this includes the prohibition of benefits of an incidental

nature, typically given or received on such occasions.

 Relations with other organizations - in the case of political parties, the Bank has adopted a

policy of complete neutrality, which means not undertaking the financing of political parties,

either directly or indirectly. With respect to non-profit organizations (such as charities or

foundations), the Bank permits the financing of such organizations in accordance with its

internal regulations.

 Giving and receiving benefits - the Bank divides benefits into three main categories, i.e.

gifts, representation events and business events. Depending on the type of benefit, the path

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forward varies. However, the main principle is the recording of benefits and, in certain

situations specified in the regulation, their prior approval by the relevant Bank services. All

this is to tighten the process of circulation of various types of benefits, which may be received

or given by the Bank's employees.

[GRI 205-2] Within the framework of mandatory training on the Code of Ethics employees familiarize

themselves with the Bank Millennium Group’s anti-corruption policy. Additionally, in connection with

the implementation of the new regulation "Anti-Corruption in Bank Millennium S.A. Polices and

Guidelines", an educational campaign was conducted through internal communication channels by

publishing articles explaining the most important aspects of counteracting corruption in the

organization.

Employees may also pose questions and report observed irregularities via an e-mail inbox or they may

contact their immediate supervisor or the person running the Compliance Department.

[GRI 205-1] As part of the assessment of individual components of operational risk, also the aspect of

vulnerability to corruption risk of different types of Bank's activities is analyzed by the Internal Audit

Department in the course of audit activities. Past experience in this area confirms the adequacy and

effectiveness of the control mechanisms implemented for this purpose, such as procedures,

segregation of duties, authorizations and limits. Periodic audits of the Internal Audit Department

cover all activities of the Bank and all business processes within the Bank Millennium Group.

[GRI 205-

No detected cases of corruption in 2021.

In addition, some Companies have their own anti-corruption regulations. Millennium Dom Maklerski

as implemented, among others, the Anti-Corruption in Millennium Dom Maklerski S.A. Polices and

Guidelines, Rules and regulations for persons employed in Millennium Dom Maklerski to invest in

financial instruments and the Procedure for identifying, classifying and assessing the cash and non-

cash benefits accepted and given by Millennium Dom Maklerski S.A. in connection with the rendering

of brokerage services. Millennium Towarzystwo Funduszy Inwestycyjnych applies the regulations

stemming from the legal requirements applicable to this category of entities set forth in the Rules

and regulations for accepting and giving incentives.

4.9. INTERNAL CONTROL SYSTEM

4.9.1. COMPLIANCE

[GRI 103-1, 103-2, 103-3] The rules and standards of ensuring compliance with external and internal

regulations are described in the document entitled Bank Millennium S.A. Compliance Policy. Within

the compliance risk management process, Bank Millennium considers the following areas to be

particularly important:

 monitoring changes in legislation and market standards,

 ensuring compliance of the Bank's internal regulations with the generally applicable provisions

of law, as well as recommendations issued by regulatory authorities,

 monitoring and approving new products and modification or withdrawal of existing products,

 approving marketing materials,

 reporting violations of applicable laws, internal regulations or market standards,

 preventing money laundering and financing of terrorism,

 preventing and managing conflicts of interest,

 preventing corruption,

 observing the ethical principles;

 personal transactions,

 protecting confidential information and professional secrets,

 monitoring and ensuring compliance with respect to financial products and services covered

by the MiFID2 directive.

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A report on the operation of the system for supervising legal compliance is presented quarterly to the

Bank's Management Board and the Supervisory Board Audit Committee, and annually to the Supervisory

Board.

[GRI 419-1] In 2021, no financial penalties were imposed on the Bank by final judgment for non-

compliance with generally applicable laws.

4.9.2. INTERNAL AUDIT

[GRI 103-1, 103-2, 103-3] The activity of Internal Audit is regulated by the „Audit charter – the principles

pertaining to internal audit activity in Bank Millennium S.A.”. This is scheduled activity based on the

annual audit plan. The planning process is based on the evaluation of risks in individual areas and

processes of the Bank and of the Subsidiaries to identify the elevated risk and supporting the priorities

and resources for implementing tasks. The planning process takes into account consultations with

senior management and key process owners. The annual audit plan is approved by the Bank’s

Supervisory Board and is implemented, on a quarterly basis, by experienced and qualified

professionals.

Internal audit is a separate, within the internal control system of Bank Millennium S.A., independent

and objective advisory activity, performed by the Internal Audit Department, aimed at generating

value and improving processes in the Bank/Group of Bank Millennium S.A. as well as assessing the

adequacy and effectiveness of the risk management system and internal control system. Advisory

activity may be performed if its character does not compromise the principle of the internal auditor’s

objectivity and independence.

In 2021, as part of the assurance activity, the Internal Audit Department performed audit tasks in the

Bank, in the Bank's subsidiaries, in third party companies to which, where permitted by law, the Bank

outsourced the performance of banking and banking-related activities and within the BCP Group. The

Department’s planned activity covered, among other things, the performance of audits of key business

processes and support processes of branches and compliance with external regulatory requirements.

Tasks performed by the Internal Audit Department also included clarification procedures and

preventive audits. As part of its advisory activities, the Department performed tasks related to the

coordination of the SREP process, inspections and supervisory / external audits carried out at the

Bank.

The Internal Audit Department is an independent unit reporting to the Chairman of the Bank’s

Management Board, which delivers results of its activities to the Audit Committee of the Supervisory

Board and to the Bank’s Supervisory Board. The results of the operating review of the entire internal

control system and of its selected elements are presented regularly and evaluated by the Audit

Committee of the Bank’s Supervisory Board.

136

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

5.1. APPROACH TO REPORTING

About this report

[GRI 102-50] The ESG Report of Bank Millennium and the Bank Millennium Group depicts the operations

of the Bank Millennium Group in the period from 1 January 2021 to 31 December 2021 unless stated

otherwise. The report was published on 21 February 2022.

[GRI 102-54] This report has been drafted in

accordance with the GRI Standards: “Core” application level (Financial Services Sector Supplement

has also been used) and in accordance with the non-financial reporting requirements imposed by the

amended Accounting Act. The report constitutes the report on non-financial information referred to

in Article 49b of the Act. It contains a recap of the Bank Millennium Group’s activity in the sustainable

development context, i.e. in the economic, social and environmental areas.

[GRI 102-52] The Bank

Millennium Group publishes reports at annual intervals.

[GRI 102-51] The most recent report prepared

for 2020 was published in February 2021. The Bank published its first corporate social responsibility

report for 2006.

[GRI 102-45] The report describes the operations of the Bank and the Bank Millennium

Group’s other major companies (Millennium Leasing, Millennium TFI, Millennium Dom Maklerski,

Millennium Bank Hipoteczny, Millennium Goodie).

[GRI 102-10] Following the merger of Bank Millennium

and Euro Bank in November 2019, the reported period continued to see significant changes in the

organization, mainly in the employment structure and further optimization of the branch network.

[GRI 102-49] There have been no significant changes in the scope and boundaries of reporting since the

last publication in 2021.

[GRI 102-48] In order to increase the quality of the carbon footprint

calculations, changes were made to the methodology for 2020 and 2021 by systematising the emission

factors used, performing calculations for electricity according to the location-based (using the

average emission factor for Poland) and market-based (using emission factors specific to energy

sellers) methods, and changing the calculation method for business trips (changing the data source

from estimates of the distance travelled for air and rail trips to the distance between the city of the

5. ABOUT THE REPORT

137

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

start and end of the trip). Detailed information can be found in "Greenhouse gas emissions" section.

As a result of changes in the accounting principles implemented in 2021, the comparable data on the

amount of loans for 2020 presented in the table on page 11 have been adjusted.

[GRI 102-56] This report has been externally verified by Deloitte.

5.2. ACCOUNTING ACT COMPLIANCE TABLE

Mandatory items from the Accounting Act Group (page) Bank (page)

Description of the business model 13 13

Description of the policy on combating corruption 133 133

Significant risks adversely affecting the issue of combating

corruption

19 19

Description of the policy on human rights 121 121

Significant risks adversely affecting the issue of human

rights

19 19

Description of the policy on social issues 110, 112, 114 110, 112, 114

Significant risks adversely affecting social issues 19 19

Description of the policy on employee issues 92, 93, 94, 106 94, 95, 94, 106

Significant risks adversely affecting employee issues 19, 94 19, 94

Description of the policy on environmental issues 27, 28, 29 27, 28, 29

Significant risks adversely affecting environmental issues 19, 29 19, 29

5.3. GRI STANDARDS CONTENT INDEX

For the Materiality Disclosures Service, GRI Services reviewed that the GRI content index is clearly

presented and the references for Disclosures 102-40 to 102-49 align with appropriate sections in the

body of the report.

138

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

[GRI 102-55]

GRI standard name

Indicator

no.

Indicator name

Reporting

level

Page

number in

the report

External

audit

GRI 101. Foundation 2016

[GRI 101 does not include any indicators]

PROFILE DISCLOSURES

GRI 102. General disclosures

2016

GRI 102-1

Name of the

organization

Full

GRI 102-2

Activities, brands,

products and services

Full

GRI 102-3

Location of headquarters

Full

GRI 102-4

Location of operations

Full

GRI 102-5

Ownership and legal

form

Full

8, 10

GRI 102-6

Markets served

Full

GRI 102-7

Scale of operations

Full

GRI 102-8

Information on

employees and other

workers

Full

Yes

GRI 102-9

Supply chain

Full

125, 126,

127

GRI 102-10

Significant changes to

the organization and its

supply chain

Full

8, 10, 126,

136

GRI 102-11

Precautionary principle

or approach

Full

29, 119, 121

GRI 102-12

External initiatives

Full

117

GRI 102-13

Membership of

associations

Full

125

GRI 102-14

Statement from senior

decision-maker

Full

GRI 102-15

Key impacts, risks, and

opportunities

Full

17, 19, 29,

75, 94, 106,

129

Yes

GRI 102-16

Values, principles,

standards and norms of

behaviour

Full

11, 13, 121

Yes

GRI 102-17

Mechanisms for advice

and concerns about

ethics

Full

122, 131

Yes

GRI 102-18

Governance structure

Full

116

GRI 102-25

Conflicts of interest

Full

132

GRI 102-26

Role of highest

governance body in

setting purpose, values

and strategy

Full

119, 120

Yes

GRI 102-30

Effectiveness of risk

management processes

Full

121

Yes

GRI 102-31

Review of economic,

environmental and social

topics

Full

120

GRI 102-40

List of stakeholder

groups

Full

GRI 102-41

Collective bargaining

agreements

Full

139

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

GRI 102-42

Identifying and selecting

stakeholders

Full

22, 108

Yes

GRI 102-43

Approach to stakeholder

engagement

Full

108, 124

GRI 102-44

Key topics and concerns

raised

Full

22, 108

Yes

GRI 102-45

Entities included in the

consolidated financial

statements

Full

136

GRI 102-46

Defining report content

and topic boundaries

Full

GRI 102-47

List of material topics

Full

GRI 102-48

Restatement of

information

Full

136

GRI 102-49

Changes in reporting

Full

136

GRI 102-50

Reporting period

Full

136

GRI 102-51

Date of most recent

report

Full

136

GRI 102-52

Reporting cycle

Full

136

GRI 102-53

Contact point

Full

146

GRI 102-54

Claims of reporting in

accordance with the GRI

Standards

Full

136

GRI 102-55

GRI content index

Full

137

GRI 102-56

External assurance

Full

137

SPECIFIC DISCLOSURES ON MATERIAL TOPICS

Economic topics

Reporting aspect: Financial performance

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 10

GRI 103-2

The management

approach and its

components

Full 10 Yes

GRI 103-3

Evaluation of the

management approach

Full 10 Yes

GRI 201. Economic

performance 2016

GRI 201-1

Direct economic value

generated and

distributed

Full 10

Reporting aspect: Market presence

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 92

GRI 103-2

The management

approach and its

components

Full 92 Yes

GRI 103-3

Evaluation of the

management approach

Full 92 Yes

GRI 202. Market presence

2016

GRI 202-1

Ratio of wages of entry-

level employees to the

minimum wage

Full

Yes

GRI 202-2

Proportion of senior

management hired from

the local community

Full 90

Reporting aspect: Indirect economic impact

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 110 Yes

140

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

GRI 103-2

The management

approach and its

components

Full 110 Yes

GRI 103-3

Evaluation of the

management approach

Full 110

GRI 203. Indirect economic

impacts 2016

GRI 203-1

Infrastructure

investments and services

supported

Full 110, 114

Reporting aspect: Procurement practices

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 125

GRI 103-2

The management

approach and its

components

Full 125 Yes

GRI 103-3

Evaluation of the

management approach

Full 125 Yes

GRI 204. Procurement

practices 2016

GRI 204-1

Proportion of spending

on local suppliers

Full 126

Reporting aspect: Prevention of corruption

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 133

GRI 103-2

The management

approach and its

components

Full 133 Yes

GRI 103-3

Evaluation of the

management approach

Full 133 Yes

GRI 205. Anti-corruption

2016

GRI 205-1

Operations assessed for

risks related to

corruption

Full 134

GRI 205-2

Communication and

training about anti-

corruption policies and

procedures

Full

122, 126,

134

Yes

GRI 205-3

Confirmed incidents of

corruption and actions

taken

Full 134 Yes

The reporting aspect: Anti-competitive behaviour

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 87

GRI 103-2

The management

approach and its

components

Full 87 Yes

GRI 103-3

Evaluation of the

management approach

Full 87 Yes

GRI 206. Anti-competitive

behaviour 2016

GRI 206-1

Legal actions for anti-

competitive behaviour,

anti-trust, and monopoly

practices

Full 87 Yes

Reporting aspect: Taxes

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 128

GRI 103-2

The management

approach and its

components

Full 128 Yes

141

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

GRI 103-3

Evaluation of the

management approach

Full 128 Yes

GRI 207. Tax 2019

GRI 207-1 Approach to tax Full 128

GRI 207-2

Tax governance, control,

and risk management

Full 128

GRI 207-3

Stakeholder

engagementand

management of concerns

related to tax

Full 128

Environmental topics

Reporting aspect: Materials

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 30

GRI 103-2

The management

approach and its

components

Full 30 Yes

GRI 103-3

Evaluation of the

management approach

Full 30 Yes

GRI 301. Materials 2016

GRI 301-1

Materials used by weight

or volume

Full 31, 32 Yes

Reporting aspect:

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 36

GRI 103-2

The management

approach and its

components

Full 36 Yes

GRI 103-3

Evaluation of the

management approach

Full 36 Yes

GRI 302. Energy 2016

GRI 302-1

Energy consumption

within the organization

Full 36, 37 Yes

GRI 302-4

Reduction of energy

consumption

Partial 45

Reporting aspect: Water and sewage

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 36

GRI 103-2

The management

approach and its

components

Full 36 Yes

GRI 103-3

Evaluation of the

management approach

Full 36 Yes

GRI 303. Water and

effluents 2018

GRI 303-5 Water consumption Full 37

Reporting aspect: Biodiversity

GRI 304. Biodiversity 2016

GRI 304-1

Operational sites owned,

leased, managed or

adjacent to protected

areas or areas of high

biodiversity value

outside protected areas

Full 30

Reporting aspect: Emissions

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 27

GRI 103-2

The management

approach and its

components

Full 27 Yes

142

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

GRI 103-3

Evaluation of the

management approach

Full 27 Yes

GRI 305. Emissions 2016

GRI 305-1

Direct (Scope 1) GHG

emissions

Full 46 Yes

GRI 305-2

Energy indirect (Scope

2) GHG emissions

Full

GRI 305-3

Other indirect (Scope 3)

GHG emissions

Full

Yes

GRI 305-4 GHG emissions intensity Full

GRI 305-5

Reduction of GHG

emissions

Full

Reporting aspect: Waste

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 30

GRI 103-2

The management

approach and its

components

Full 30 Yes

GRI 103-3

Evaluation of the

management approach

Full 30 Yes

GRI 306. Waste 2020

GRI 306-1

Waste generation and

significant waste-related

impacts

Full

GRI 306-2

Management of

significant waste-related

impacts

Full

GRI 306-3 Waste generated Full 33, 34, 35 Yes

GRI 306-4

Waste diverted from

disposal

Partial 35

Reporting aspect: Compliance with environmental regulations

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 27

GRI 103-2

The management

approach and its

components

Full 27 Yes

GRI 103-3

Evaluation of the

management approach

Full 27 Yes

GRI 307. Environmental

compliance2016

GRI 307-1

Non-compliance with

environmental laws and

regulations

Full 58

Reporting aspect: Environmental assessment of suppliers

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 125

GRI 103-2

The management

approach and its

components

Full 125 Yes

GRI 103-3

Evaluation of the

management approach

Full 125 Yes

GRI 308. Supplier

environmental assessment

2016

GRI 308-1

Percentage of new

suppliers that were

screened using

environmental criteria

Partial 126

Social topics

Reporting aspect: Employment

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 91

143

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

GRI 103-2

The management

approach and its

components

Full 91 Yes

GRI 103-3

Evaluation of the

management approach

Full 91 Yes

GRI 401. Employment 2016

GRI 401-1

New employee hires and

employee turnover

Full 88, 89 Yes

GRI 401-2

Benefits provided to

employees

Full 103 Yes

GRI 401-3 Parental leave Full 104 Yes

Reporting aspect: Occupational health and safety

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 106

GRI 103-2

The management

approach and its

components

Full 106 Yes

GRI 103-3

Evaluation of the

management approach

Full 106 Yes

GRI 403. Occupational

health and safety 2018

GRI 403-1

Occupational health and

safety management

system

Full

106

GRI 403-2

Hazard identification,

risk assessment, and

incident investigation

Full

106

GRI 403-3

Occupational health

services

Full

107

GRI 403-4

Worker participation,

consultation, and

communication on

occupational health and

safety

Full

107

GRI 403-5

Worker training on

occupational health and

safety

Full

107

GRI 403-6

Promotion of worker

health

Full

104, 106

GRI 403-7

Prevention and

mitigation of

occupational health and

safety impacts directly

linked by business

relationships

Full

107

GRI 403-9 Work-related injuries Full 107

The reporting aspect: Training and education

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 100

GRI 103-2

The management

approach and its

components

Full 100 Yes

GRI 103-3

Evaluation of the

management approach

Full 100 Yes

GRI 404. Training and

education 2016

GRI 404-1

Average hours of

training per year per

employee

Full 102 Yes

GRI 404-2

Programs for upgrading

employee skills and

transition assistance

programs

Full 102 Yes

144

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

GRI 404-3

Percentage of

employees receiving

regular performance and

career development

reviews

Full 98 Yes

Reporting aspect: Diversity and equal opportunities

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 114

GRI 103-2

The management

approach and its

components

Full 114 Yes

GRI 103-3

Evaluation of the

management approach

Full 114 Yes

GRI 405. Diversity and equal

opportunity 2016

GRI 405-1

Diversity of governance

bodies and employees

Full 90, 95, 117 Yes

GRI 405-2

Ratio of basic salary and

remuneration of women

to men

Full 96, 97 Yes

Reporting aspect: Counteracting discrimination

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 94, 123

GRI 103-2

The management

approach and its

components

Full 94, 123 Yes

GRI 103-3

Evaluation of the

management approach

Full 94, 123 Yes

GRI 406. Non-discrimination

2016

GRI 406-1

Incidents of

discrimination and

corrective actions taken

Full 95 Yes

Reporting aspect: Assessment of human rights issues

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 123

GRI 103-2

The management

approach and its

components

Full 123 Yes

GRI 103-3

Evaluation of the

management approach

Full 123 Yes

GRI 412. Human rights

assessment2016

GRI 412-2

Employee training on

human rights policies or

procedures

Full 94, 122

Reporting aspect: Local community

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 112

GRI 103-2

The management

approach and its

components

Full 112 Yes

GRI 103-3

Evaluation of the

management approach

Full 112 Yes

GRI 413. Local communities

2016

GRI 413-1

Operations with local

community engagement,

impact assessments, and

development programs

Full 110, 112 Yes

Reporting aspect: Social assessment of suppliers

145

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 125

GRI 103-2

The management

approach and its

components

Full 125 Yes

GRI 103-3

Evaluation of the

management approach

Full 125 Yes

GRI 414. Supplier social

assessment 2016

GRI 414-1

New suppliers that were

screened using social

criteria

Partial 126

Reporting aspect: Marketing and labelling of products and services

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 80

GRI 103-2

The management

approach and its

components

Full 80 Yes

GRI 103-3

Evaluation of the

management approach

Full 80 Yes

GRI 417. Marketing and

labelling2016

GRI 417-1

Requirements for

product and service

information and

labelling

Full 80, 83

GRI 417-3

Incidents of non-

compliance concerning

marketing

communications

Full 81

Reporting aspect: Client privacy

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 129, 130

GRI 103-2

The management

approach and its

components

Full 129, 130 Yes

GRI 103-3

Evaluation of the

management approach

Full 129, 130 Yes

GRI 418. Customerprivacy

2016

GRI 418-1

Substantiated

complaints concerning

breaches of customer

privacy and losses of

customer data

Full 130 Yes

Reporting aspect: Compliance with socio-economic regulations

GRI 103. Management

approach 2016

GRI 103-1

Explanations of the

material topic and its

boundary

Full 134, 135

GRI 103-2

The management

approach and its

components

Full 134, 135 Yes

GRI 103-3

Evaluation of the

management approach

Full 134, 135 Yes

GRI 419. Socioeconomic

compliance2016

GRI 419-1

Non-compliance with the

laws and regulations in

the social and economic

area

Full

81, 82, 83,

84, 135

Specific standard disclosures for the sector

Sector topic: Product portfolio

FS5

Interactions with

clients/ investees/

business partners

Full 126, 127

146

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

regarding environmental

and social risks and

opportunities

Sector topic: Local communities

FS13

Access points in low-

populated or

economically

disadvantaged areas by

type

Full 70 Yes

FS14

Initiatives to improve

access to financial

services for

disadvantaged people

Full 68 Yes

Sector topic: Product and service labelling

FS15

Policies for the fair

design and sale of

financial products and

services

Full 84

FS16

Initiatives to enhance

financial literacy by type

of beneficiary

Full

78, 111

5.4. CONTACT DATA

[GRI 102-53] Thank you for reviewing the ESG Report of Bank Millennium and the Bank Millennium

Group for 2021. Please send your comments and questions about it to:

Iwona Jarzębska, iwona.jarzebska@bankmillennium.pl

Dorota Hołownia, dorota.holownia@bankmillennium.pl

147

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

5.5. CERTIFICATION LETTER

148

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

149

ESG Report of Bank Millennium

and the Bank Millennium Group for 2021

SIGNED BY:

Date

First and last name

Position/Function

Signature

21.02.2022 Joao Bras Jorge

Chairman of the Management

Board

Signed with a qualified

electronic signature

21.02.2022 Fernando Bicho

Vice-Chairman of the

Management Board

Signed with a qualified

electronic signature

21.02.2022 Wojciech Haase Management Board Member

Signed with a qualified

electronic signature

21.02.2022 Andrzej Gliński Management Board Member

Signed with a qualified

electronic signature

21.02.2022 Wojciech Rybak Management Board Member

Signed with a qualified

electronic signature

21.02.2022

António Ferreira Pinto

Júnior

Management Board Member

Signed with a qualified

electronic signature

21.02.2022 Jarosław Hermann Management Board Member

Signed with a qualified

electronic signature