2.
Assessment
of
the
adequacy
and
effectiveness
of
the
company’s
system
of
internal
control,
risk
management,
compliance
with
standards or applicable practices and internal audit
The
Bank’s
risk
management
system
and
internal
control
system
are
organised
on
three independent levels – lines of defence.
The
internal
control
system
supports
the
management
of
the
Bank
by
contributing
to
ensuring
the
effectiveness
and
efficiency
of
the
Bank’s
operations,
the
reliability
of
financial
reporting,
compliance
with
risk
management
principles,
and
the
Bank’s
compliance with laws and internal regulations.
The internal control system includes:
1.
The
control
function
which
aims
to
ensure
compliance
with
control
mechanisms
relating
in
particular
to
risk
management
in
the
Bank,
which
includes
positions,
groups
of
people
or
organisational
units
responsible
for
the
performance
of
tasks
assigned
to
this
function.
The
function
is
carried
out
in
a
systematic manner by employees at all organisational levels by means of:
■
continuous
monitoring,
consisting
of
the
examination
of
selected
operations
or activities performed at the Bank,
■
periodic
verification,
consisting
of
an
examination
of
selected
operations
or
activities
already
completed
in
order
to
check
the
adequacy
and
effectiveness of the continuous monitoring.
2.
The
compliance
function
which
is
responsible
for
identifying,
assessing,
controlling
and
monitoring
the
risk
of
non-compliance
of
the
Bank’s
operations
with
the
law,
internal
regulations
and
market
standards,
as
well
as
for
presenting
reports
in
this
respect.
The
tasks
of
the
compliance
function
are
performed by the Compliance Department.
3.
An
independent
internal
audit
function
which
aims
to
examine
and
assess,
in
an
independent
and
objective
manner,
the
adequacy
and
effectiveness
of
the
risk
management
system
and
the
internal
control
system.
The
tasks
of
the
independent
internal
audit
function
are
performed
by
the
Internal
Audit
Department.
The
Audit
Committee
provides
the
Supervisory
Board
with
its
opinion
on
the
assessment
of
the
internal
control
system
based
on
information
from
the
Bank’s
Management
Board
on
the
functioning
of
the
internal
control
system,
reports
on
the
effectiveness
of
the
control
function,
significant
and
critical
irregularities
and
the
status
of
recovery
plans,
reports
on
compliance
risk
management,
the
assessment
from
an
internal
audit
perspective,
as
well
as
the
results
of
audits.
The
Committee
takes
into
account
in
its
opinion
information
from
the
parent
company,
subsidiaries,
the
auditor,
supervisory
institutions
(e.g.,
the
Polish
Financial
Supervision
Authority),
as
well
as
from
other
third
parties.
The
Committee
assesses
the
performance
of
the
Compliance
Department
and
the
Internal
Audit
Department
on
the
basis
of
annual
activity
reports
presented
directly
by
the
Directors of the Compliance and Internal Audit Departments.
The
Internal
Audit
Department
included
sustainability
issues
in
its
audit
testing
and
assessment of the internal control system.