TRANSLATORS’ EXPLANATORY NOTE
The English content of this report is a free translation of the registered auditor’s report of the below- mentioned Polish Company. In Poland statutory accounts as well as the auditor’s report should be prepared and presented in Polish and in accordance with Polish legislation and the accounting principles and practices generally adopted in Poland.
The accompanying translation has not been reclassified or adjusted in any way to conform to the accounting principles generally accepted in countries other than Poland, but certain terminology current in Anglo-Saxon countries has been adopted to the extent practicable. In the event of any discrepancies in interpreting the terminology, the Polish language version is binding.
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp. k. , ul. Polna 11, 00-633 Warsaw, Poland, T: +48 (22) 746 4000, F:+48 (22) 742 4040 ,
www.pwc.pl
PricewaterhouseCoopers Polska Spółka z ograniczoną odpowiedzialnością Audyt sp. k. is entered into the National Court Register maintained by the District Court for the Capital City of Warsaw, under KRS number 0000750050, NIP 526-021-02-28. The seat of the Company is in Warsaw at Polna 11 str.
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Independent Registered Auditor’s Report
To the General Shareholders’ Meeting and the Supervisory Board of Powszechna Kasa Oszczędności Bank Polski S.A.
Report on the audit of separate financial statements
Our opinion
In our opinion the accompanying annual separate financial statements:
give a true and fair view of the separate financial position of Powszechna Kasa Oszczędności
Bank Polski S.A. (the “Bank”) as at 31 December 2023 and the Bank’s separate financial
performance and the separate cash flows for the year then ended in accordance with the
applicable International Financial Reporting Standards as adopted by the European Union and the
adopted accounting policies;
comply in terms of form and content with the laws applicable to the Bank and the Bank’s Articles
of Association;
have been prepared on the basis of properly maintained books of account in accordance with
the provisions of Chapter 2 of the Accounting Law of 29 September 1994 (the “Accounting Act”).
Our opinion is consistent with our additional report to the Audit Committee issued on the date of this
report.
What we have audited
We hav e audited the annual separate financial statements of Powszechna Kasa Oszczędności Bank
Polski S.A. which comprise:
the separate statement of financial position as at 31 December 2023;
and the following prepared for the financial year then ended:
the separate income statement;
the separate statement of comprehensive income;
the separate statement of changes in equity;
the separate statement of cash flows, and
the additional notes to the separate financial statements, comprising significant accounting policy
information and other explanatory information.
Basis for opinion
We conducted our audit in accordance with the National Standards on Auditing as adopted by the resolution of the National Council of Statutory Auditors and the resolution of the Council of the Polish Audit Supervision Agency (“NSA”) and pursuant to the Law of 11 May 2017 on Registered Auditors,
Registered Audit Companies and Public Oversi ght (the “Law on Registered Auditors”) and the
Regulation (EU) No. 537/2014 of 16 April 2014 on specific requirements regarding the statutory audit
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of public-interest entities (the “EU Regulation”). Our responsibilities under NSA are further described in
the Auditor’s responsibilities for the audit of the separate financia l statements section of our report.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Independence
We are independent of the Bank in accordance with the International Code of Ethics for Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants (IESBA Code) as adopted by resolution of the National Council of
Statutory Auditors and other ethical requirements that are relevant to our audit of th e separate
financial statements in Poland. We have fulfilled our other ethical responsibilities in accordance with
these requirements and the IESBA Code. During the audit, the key registered auditor and the
registered audit firm remained independent of the Bank in accordance with the independence
requirements set out in the Act on Registered Auditors and in the EU Regulation.
Our audit approach
Overview
As part of designing our audit, we determined materiality and assessed the risks of material
misstatement in the separate f inancial statements. In particular, we considered where the Bank’s Management Board made subjective judgements; for example, in respect of significant accounting estimates that involved making assumptions and considering future events that are inherently
The overall materiality threshold adopted for the purposes of our audit was set at PLN 441 million. We adopted overall materiality based on the value of 5% of the profit before tax adjusted for tax on financial institutions. For reasons of prudence, we have adjusted the overall materiality so that it does not exceed approximately 1% of the Bank's net assets.
All material items included in the separate financial statements were subject to our audit procedures.
Estimating the cost of legal risk related to the portfolio of mortgage loans in Swiss francs (CHF)
Estimating the value of expected credit losses in the portfolio of loans and advances to customers
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Materiality
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Group scoping
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Key audit matters
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uncertain. As in all of our audits we also addressed the risk of management override of internal controls, including among other matters, consideration of whether there was evidence of bias that represented a risk of material misstatement due to fraud.
Materiality
The scope of our audit was influenced by our application of materiality. An audit is designed to obtain
reasonable assurance whether the separate financial statements are free from material misstatement.
Misstatements may arise due to fraud or error. They are considered material if, individually or in
aggregate, they could reasonably be expected to influence the economic decisions of users taken on
the basis of the separate financial statements.
Based on our professional judgement, we determined certain quantitative thresholds for materiality,
including the overall materiality for the separate financial statements as a whole, as set out in the table
below. These, together with qualitative considerations, helped us to determine the scope of our audit
and the nature, timing and extent of our audit procedures and to evaluate the effect of misstatements,
if any, both individually and in aggregate on the separate fi nancial statements as a whole.
Overall Bank materiality
PLN 441 million
How we determined it
5% of the profit before tax adjusted for the tax on financial institutions. For reasons of prudence, we adjusted the overall materiality so that it does not exceed approximately 1% of the Bank's net assets.
Rationale for the materiality benchmark applied
We chose profit before tax as the benchmark because, in our view, it is the benchmark against which the performance of the Group is most commonly measured by users, and is a generally accepted benchmark. We adjusted this value by the tax on financial institutions, which has the nature of a special tax burden.
In order to calculate the materiality as above, we adopted the levels of 5% (of profit before tax adjusted for tax on financial institutions) and 1% (of net assets), respectively, because based on our professional judgement they are within the range of acceptable quantitative materiality thresholds.
We agreed with the Audit Committee of the Bank that we would report to them misstatements of the
separate financial statements identified during our audit above PLN 22 million, as well as
misstatements below that amount that, in our view, warranted reporting for qualitative reasons.
Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in
our audit of the separate financial statements of the current period. They include the most significant
identified risks of material misstatements, including the identified risks of material misstatement
resulting from fraud. These matters were addressed in the context of our audit of the separate
financial statements as a whole, and in forming our opinion thereon. We do not provide a separate
opinion on these matters.
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Key audit matter
How our audit addressed the key audit matter
Estimating the costs of legal risk related to the portfolio of mortgage loans in Swiss francs (CHF)
As at the balance sheet date, the Bank had a portfolio of mortgage loans denominated in and indexed to CHF in the total amount of PLN 13,096 million before the adjustment to contractual cash flows due to the legal risk. As described in Note 25 Cost of legal risks of mortgage loans in convertible currencies to the separate financial statements, the contracts on the basis of which these loans were granted, contain clauses questioned by customers in courts due to abusiveness. At the moment, the jurisprudence of courts is not uniform, but a negative trend for banks is observed in relation to court judgments, which affects both the increase in the level of the estimated probability of unfavourable settlements of disputes and the increase in the number of court cases brought by the banks’ clients. As described in Note 25, from 4 October 2021 the Bank concludes voluntary settlements with customers and by 31 December 2023, 36,822 settlements were signed. Settlements concluded with customers result in the cancellation of the customers' debt under the CHF loan as if their loans from the beginning were loans in PLN at the WIBOR reference rate increased by a negotiated margin based on the margin level used historically for such loans.
As at the balance sheet date, the Bank estimated the costs to cover the above-mentioned legal risk, both for the active portfolio and for loans repaid before the balance sheet date. In the separate financial statements the Bank recognised these costs, for the active portfolio pursuant to paragraph B5.4.6 of IFRS 9 Financial Instruments (“IFRS 9”), by adjusting the gross carrying amount of the portfolio by reducing contractual cash flows from CHF-denominated or indexed mortgage loans, and in cases where expected loss is higher than gross carrying amount of the loan for repaid loans and for statutory interest by recognising provisions in accordance with the requirements of IAS 37 Provisions, Contingent Liabilities and Contingent Assets (“IAS 37”).
The level of reduction in the gross carrying value of the active portfolio estimated as at December
As part of our audit, we assessed whether the accounting approach applied by the Bank complies with IFRS 9 and IAS 37. We focused on assessing the Bank's approach to estimating the cost of legal risk of CHF mortgage loans, as well as the scope of disclosures included in the separate financial statements.
Our procedures were aimed mainly at a critical assessment of the model and individual assumptions adopted by the Bank’s Management that had a significant impact on the level of the gross book value adjustment of the portfolio and recognized provisions. In particular, we have carried out the procedures listed below:
we assessed the design and implementation of monitoring and internal controls as part of legal risk management and in the process of estimating the adjustments to the gross book value of the portfolio and the provisions recognized
we interviewed the Bank’s Management and
specialists involved in the estimation of the
adjustments and provisions, including the
Bank's lawyers, on the assumptions made
based on historical observations, as well as
information and events after the balance sheet
date;
in cooperation with our legal experts, we
analysed the documentation and opinions of
external law firms obtained by the Bank for the
purposes of assessing the risk of considering
clauses in the Bank's agreements as abusive
and the likelihood of the individual scenarios of
possible outcomes of lawsuits;
in cooperation with our legal experts and
statistical modelling experts, we analysed the
documentation of the model;
we analysed the results of the backtest of the
model for estimating the costs of legal risk of
mortgage loans in CHF;
substantive procedures:
o we analysed the results of settlements
program by the Bank including update the
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31, 2023 was PLN 8,306 million, while the level of provisions created was PLN 3,001 million.
The costs of legal risk of mortgage loans in CHF were estimated using a statistical method that takes into account the impact of customer characteristics, as the sum of the products of:
the likelihood of the client accepting the
settlement and the amount of the Bank's loss
under the settlement, and
the probabilities of certain court settlements
and the amount of loss for various scenarios
of such settlements, taking into account the
current and forecast number of court cases in
the horizon in which the Bank is exposed to
such risk .
Estimation of the costs of legal risk of mortgage loans in CHF is complex and requires a considerable degree of judgement with respect to the key assumptions:
the expected level of future settlements is
based on the number of settlements
concluded with clients so far and is
characterised by a significant level of
uncertainty due to the short observation
period as well as changing external factors,
which may affect future decisions of clients
on joining the settlement program as well as
future decisions of the Bank to continue with
the settlements program;
the forecast number of future lawsuits is
based on historical observations regarding
court cases and is characterised by
considerable uncertainty due to the high
dynamics of the number of cases brought to
court by the Bank's clients, both active and
repaid loans, constituting the basis for
estimation, as well as the uncertainty as to
the forecast of clients' inclination to file a
case in court in the future;
the probabilities of resolutions in current and
future court cases affecting the level of loss
are subject to significant changes due to the
lack of a uniform line of jurisprudence in previous court judgments;
the estimated period for charging statutory interest may change due to the uncertainty as to the date from which courts will award statutory interest due to customers.
economic assumptions for the settlement
proposals adopted in the model ;
o we obtained directly from the Bank’s
external legal experts their assessment of
the expected scenarios of the resolutions of
court cases together with an assessment of
the probability of these resolutions;
o we verified the method of calculating the
value of potential losses for the scenarios
assumed by the Bank;
o we checked the correctness and
completeness of the input data being the
basis for calculations in the Bank’s model
(by performing tests of details on the
completeness and accuracy of the input
data);
o we verified the mathematical accuracy of
the model calculation;
o we verified on a sample the correctness of
the settlement with the clients and final
judgments ;
o we verified the recognition of the settlement
result and final judgments in the books for the entire population.
We also verified the adequacy and completeness of disclosures in the separate financial statements in accordance with applicable accounting standards
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Due to the significant impact on the Bank’s result, the complexity and uncertainty of the assumptions adopted to estimate the legal risk costs of CHF mortgage loans, as well as the significant value of the portfolio constituting the basis for estimating potential settlements as well as current and potential future claims against the Bank, we considered this area a key audit matter.
Note 25 Cost of legal risk of mortgage loans in convertible currencies , Note 3 4 Loans and advances to customers , Note 4 6 Legal claims and Note 6 0 Management of currency risk associated with mortgage loans for individuals in separate financial statements contain detailed information on the assumptions used to calculate the adjustment of the gross carrying amount of the portfolio of mortgage loans in CHF and provisions created, as well as the possible alternative results presented as part of the estimate sensitivity analysis.
Estimating the expected credit losses for loans and advances to customers
In accordance with the provisions of IFRS 9 the Bank’s Management is required to determine expected credit loss (“ECL”) that may occur over either a 12 month period or the remaining life of a financial asset, depending on the classification of individual assets into risk categories ("stages"), taking into account the impact of future macroeconomic conditions on the level of credit risk allowances.
The Bank’s loan portfolio consists of exposures assessed for expected credit losses:
on an individual basis for individually
significant credit exposures; and
on a portfolio basis with the use of statistical
models which estimate allowances for credit
losses for each of the homogenous portfolios identified by the Bank.
Estimating the level of allowances for expected credit losses requires the application of a significant degree of judgement with regard to the identification of impaired loans and significant increase in credit risk (“SICR”), the assessment of the customer's credit quality, the value of collaterals and expected recoveries.
As part of our procedures we updated our understanding of the internal control environment in terms of recognizing and calculating expected credit losses, and we also checked the effectiveness of selected key control mechanisms implemented by the Bank, in particular:
procedures in the area of entering customer
data used for the calculation of expected credit
losses;
the process of data flow between the Bank's
key IT systems and the ECL calculation tool;
proc edures for timely and complete identification of significant increases in credit risk (stage 2) and impairment (stage 3).
We also assessed whether the methodology used by the Bank for estimating allowances for expected credit losses complies with the requirements of IFRS 9. In particular, we assessed the Bank's approach to the application of the SICR criteria, default definition, probability of default ("PD"), loss given default (“LGD”) parameters and considering forward-looking information when calculating expected credit losses.
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The Bank’s Management monitors the correctness of performance of the models, by comparing the estimated results of the models to actual credit losses (‘back-testing procedures’) to ensure that the level of allowances for the expected credit losses for loans and advances to customers is adequate.
In the models of expected credit losses the Bank uses large volumes of data, therefore the completeness and reliability of data can significantly impact accuracy of the allowances for credit losses.
Due to the dynamic changes taking place in the macroeconomic environment, the Bank’s Management, as described in Note 23 Net allowances for expected credit losses to separate financial statements, recognised additional write- offs for the forecasted deterioration in quality of the loan portfolio in industries particularly affected by these changes.
We determined that the level of allowance for expected credit losses in the portfolio of loans and advances is a key audit matter due to:
the significant judgement applied by the
Bank’s Management when designing future
macroeconomic scenarios and forecasting
macroeconomic variables, adopting
probability-weighting scenarios and applying
expert judgement to reflect characteristics not
already considered in the models;
a high degree of uncertainty in the estimates
of expected credit losses;
complexity of audit procedures and audit
evidence obtained due to the complexity of
the calculations and the volume of data used
to estimate the allowances for expected
credit losses .
Note 23 Net allowances for expected credit losses , Note 3 4 Loans and advances to customers and Note 5 2 the Credit risk management Note 5 3 Credit risk – financial information section of separate financial statements provide detailed information on the methods and models used and on the level of allowances for the expected credit losses for loans and advances to customers.
In the case of individually insignificant loans and advances, which are assessed for impairment at the portfolio basis, we have performed among others the following procedures:
assessment of the Bank's assumptions and
expert adjustments used in the model;
critical analysis of key judgments and
assumptions, including macroeconomic
scenarios and assumed probabilities of
occurrence of individual scenarios;
analysis of the model stability and its
adaptation to the current conditions;
independent tests of credit risk parameters;
for selected loans and advances, we checked the classification into stages as at the balance sheet date.
We have engaged our in-house credit risk modelling specialists to carry out the above- mentioned procedures.
As part of the work on individually analysed exposures, we performed the following procedures:
we applied our professional judgement in
selecting the sample taking into account
various risk criteria;
for selected loans and advances we checked
the classification into stages;for selected
impaired loans and advances (stage 3), we
tested the assumptions used in the calculation
of the impairment allowances, in particular the
forecasted scenarios and associated
probabilities, as well as the timings and
amounts of the expected cash flows, including cash flows from repayments and collateral realisation.
In addition, we performed the following procedures:
we reconciled selected inputs used to
determine default parameters and to estimate
expected credit losses;
we verified the assumptions adopted for the
calculation of additional adjustments not
included in the model, created to reflect the
impact of macroeconomic factors on projected
deterioration in the quality of the loan portfolio
in selected industries;
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we recalculated expected credit losses on a
sample of credit exposures;
we performed analytical procedures for the
coverage of the loan portfolio with expected
credit losses and their changes and the
transfer of exposure between stages;
we analysed the events after the balance sheet
date to verify the need for adjustments to be
made to the expected credit losses as at the
balance sheet date;
we analysed the results of the Bank’s
Management sensitivity analysis of the level of
allowances for expected credit losses due to
deterioration or improvement of risk parameters.
We also verified the adequacy and completeness of disclosures in the separate financial statements in accordance with the applicable accounting standards .
Responsibility of the Management and Supervisory Board for the separate financial
statements
The Management Board of the Bank is responsible for the preparation, based on the properly
maintained books of account of the annual separate financial statements that give a true and fair view
of the Bank’s financial position and results of operations, in accordance with International Financial
Reporting Standards as adopted by the European Union, the adopted accounting policies, the
applicable laws and the Bank’s Articles of Association, and for such internal control as the
Management Board determines is necessary to enable the preparation of separate financial
statements that are free from material misstatement, whether due to fraud or error.
In preparing the separate financial statements, the Bank’s Management Board is responsible for
assessing the Bank’s ability to continue as a going concern, disclosing, as applicable, matters related
to going concern and using the going concern basis of accounting unless the Management Board
either intends to liquidate the Bank or to cease operations, or has no realistic alternative but to do so.
The Bank’s Management Board and members of the Supervisory Board are obliged to ensure that the
separate financial statements comply with the requirements specified in the Accounting Act. Members
of the Supervisory Board are responsible for overseeing the financial reporting process.
Auditor’s responsibility for the audit of the separate financial statements
Our objectives are to obtain reasonable assurance about whether the separate financial statements as
a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s
report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a
guarantee that an audit conducted in accordance with the NSA will always detect a material
misstatement when it exists. Misstatements can arise from fraud or error and are considered material
if, individually or in aggregate, they could reasonably be expected to influence economic decisions of
users taken on the basis of these separate financial statements.
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The scope of the audit does not include an assurance on the Bank’s future profitability nor the
efficiency and effectiveness of the Bank’s Management Board conducting its affairs, now or in future.
As part of an audit in accordance with NSA, we exercise professional judgement and maintain
professional scepticism throughout the audit. We also:
identify and assess the risks of material misstatement of t he separate financial statements,
whether due to fraud or error, design and perform audit procedures responsive to those risks, and
obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk
of not detecting a material misstatement resulting from fraud is higher than for one resulting from
error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the
override of internal control;
obtain an understanding of internal control relevant to the audit in order to design audit procedures
that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the
effectiveness of the Bank’s internal control;
evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by the Bank’s Management Board;
conclude on the appropriateness of the Bank’s Management Board’s use of the going concern
basis of accounting and, based on the audit evidence o btained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Bank’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to
draw attention in our auditor’s report to the related disclosures in the separate financial statements
or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the
audit evidence obtained up to the date of our auditor’s report. However, future events or conditions
may cause the Bank to cease to continue as a going concern;
evaluate the overall presentation, structure and content of the separate financial statements,
including the disclosures, and whether the separate financial statements represent the underlying
transactions and events in a manner that achieves fair presentation.
We communicate with the Audit Committee regarding, among other matters, the planned scope and
timing of the audit and significant audit findings, including any significant deficiencies in internal control
that we identify during our audit.
We also provide the Audit Committee with a statement that we have complied with relevant ethical
requirements regarding independence, and to communicate with them all relationships and other
matters that may reasonably be thought to bear on our independence, and where applicable, actions
taken to eliminate threats or safeguards applied.
From the matters communicated to the Audit Committee, we determine those matters that were of
most significance in the audit of the separate financial statements of the current period and are
therefore the key audit matters. We describe these matters in our auditor’s report unless law or
regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we
determine that a matter should not be communicated in our report because the adverse
consequences of doing so would reasonably be expected to outweigh the public interest benefits of
such communication.
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Other information, including the report on the operations
Other information
Other information comprises:
a PKO Bank Polski S.A. Group Directors’ Report for 2023 prepared jointly with the PKO Bank
Polski S.A. Directors’ Report (“the Report on the operations”) and the corporate governance
statement and the statement on non-financial information referred to in Article 49b(1) of the
Accounting Act which are separate parts of the Report on the operations,
other documents comprising the Annual Report for the financial year ended 31 December 2023
(“the Annual Report”),
(together “Other Information”).
Other information does not include the separate financial statements and our auditor’s report thereon.
Responsibility of the Management and Supervisory Board
The Management Board of the Bank is responsible for the preparation of the Other Information in
accordance with the law.
The Bank’s Management Board and the members of the Supervisory Board are obliged to ensure that
the Report on the operations including its separate parts complies with the requirements of the
Accounting Law.
Registered auditor’s responsibility
Our opinion on the separate financial statements does not cover the Other Information.
In connection with our audit of the separate financial statements, our responsibility under NSA is to
read the Other Information and, in doing so, consider whether the Other Information is materially
inconsistent with the information in the separate financial statements, our knowledge obtained in our
audit, or otherwise appears to be materially misstated. If, based on the work performed, we identified
a material misstatement in the Other Information, we are obliged to inform about it in our audit report.
In accordance with the requirements of the Law on the Registered Auditors, we are also obliged to
issue an opinion on whether the Report on the operations has been prepared in accordance with the
law and is consistent with information included in annual separate financial statements.
Moreover, we are obliged to issue an opinion on whether the Bank provided the required information
in its corporate governance statement and to inform whether the Bank prepared a statement on non-
financial information.
In addition, we are required to audit the financial information included in item 5 of the Report on the
operations in accordance with the scope described in this audit report and the requirements of the
Banking Law of 29 August 1997 (“the Banking Law”).
Statement on the Other information
We declare, based on the knowledge of the Bank and its environment obtained during our audit, that
we have not identified any material misstatements in the Report on the operations and the remaining
Other information.
Opinion on the Report on the operations
Based on the work we carried out during our audit, in our opinion, the Report on the operations:
has been prepared in accordance with the requirements of Article 49 of the Accounting Act and
para. 70 of the Regulation of the Minister of Finance dated 29 March 2018 on current and
periodical information submitted by issuers of securities and conditions for considering as
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equivalent the information required under the legislation of a non-Member State (“Regulation on
current information”) and Article 111(1–2) of the Banking Law;
is consistent with the information in the separate financial statements.
Opinion on the corporate governance statement
In our opinion, in its corporate governance statement, the Bank included information set out in para.
70.6 (5) of the Regulation on current information. In addition, in our opinion, information specified in
paragraph 70.6 (5)(c)–(f), (h) and (i) of the said Regulation included in the corporate governance
statement are consistent with the applicable provisions of the law and with information included in the
separate financial statements.
Information on non-financial information
In accordance with the requirements of the Act on the Registered Auditors, we confirm that the Bank
has prepared a statement on non-financial information referred to in Article 49b(1) of the Accounting
Act as a separate section of the Report on the operations.
We have not performed any assurance work relating to the statement on non-financial information and
we do not provide any assurance with regard to it.
Report on other legal and regulatory requirements
Information on compliance with prudential regulations
The Management Board of the Bank is responsible for complying with the applicable prudential regulations set out in separate legislation, and in particular, for correct determination of the capital ratios.
The capital ratios as at 31 December 2023 have been presented in Note 66 o f the separate financial
statements and include Tier 1 common capital ratio, Tier 1 capital ratio and the total capital ratio.
We are obliged to inform in our report on the audit of the separate financial statements whether the
Bank has complied with the applicable prudential regulations set out in separate legislation, and in
particular, whether the Bank has correctly determined its capital ratios. For the purposes of the said
information, the following legal acts are understood as separate legislation: Regulation (EU) no.
575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements
for credit institutions and investment firms and amending Regulation (EU) No 648/2012, as amended
(“CRR”), the Banking Law and the Act of 5 August 2015 on macro-prudential supervision over the
financial system and on crisis management in the financial system (“the Act on macro-prudential
supervision”).
It is not the purpose of an audit of the separate financial statements to present an opinion on
compliance with the applicable prudential regulations specified in the separate legislation specified
above, and in particular, on the correct determination of the capital ratios, and therefore, we do not
express such an opinion.
Based on the work performed by us, we inform you that we have not identified:
any cases of non-compliance by the Bank with the applicable prudential regulations set out in
separate legislation referred to above, in the period from 1 January to 31 December 2023;
any irregularities in the determination by the Bank of the capital ratios as at 31 December 2023 in
accordance with the separate legislation referred to above;
which would have a material impact on the separate financial statements.
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Statement on the provision of non-audit services
To the best of our knowledge and belief, we declare that the non-audit services we have provided to
the Bank, its parent company and its controlled entities within the European Union are in accordance
with the applicable laws and regul ations in Poland and that we have not provided any non-audit services prohibited under Article 5(1) of the EU regulation and Article 136 of the Law on Registered Auditors.
The non-audit services which we have provided to the Bank and its controlled entities within the
European Union during the audited period are dis closed in Note 74 of the separate financial statements.
Appointment
We were first appointed to audit the annual separate financial statements of the Bank by resolution of the Supervisory Board dated 3 December 2018 and re-appointed by resolution dated 23 September
2021 . We have been auditing the Bank’s separate financial statements without interruption since the
financial year ended 31 December 2020, i.e. for four consecutive years.
The Key Registered Auditor responsible for the audit on behalf of PricewaterhouseCoopers Polska
spółka z ograniczoną odpowiedzialnością Audyt sp. k., a company entered on the list of Registered
Audit Companies with the number 144, is Agnieszka Accordi.
Agnieszka Accordi
Key Registered Auditor
No. in the registry 11665
Warsaw, 6 March 2024