GK_ING_AR_07-03-2024_2023-12-31

Independent Statutory Auditor’s Report on the Audit

of Consolidated Annual Financial Statements of the

ING Bank Śląski S.A. Group

for the financial year ended

31 December 2023

Mazars Audyt Sp. z o.o.

ul. Piękna 18

00-549 Warsaw

Mazars Audyt Sp. z o.o.

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

NIP: 5260215409, REGON: 011110970

INDEPENDENT STATUTORY AUDITOR’S REPORT

ON THE AUDIT OF CONSOLIDATED ANNUAL FINANCIAL

STATEMENTS

Translation of the document originally issued in Polish

To the General Meeting and the Supervisory Board of ING Bank Śląski S.A.

Report on the Audit of Consolidated Annual Financial Statements

Opinion

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

undertaking of which is ING Bank Śląski S.A. (“the Parent Undertaking”, “the Bank”) (“Group”),

which comprise the consolidated statement of financial position as at 31 December 2023,

the consolidated income statement, the consolidated statement of comprehensive income,

the consolidated statement of changes in equity, the consolidated cash flow statement for

the financial year from 1 January to 31 December 2023 and notes to consolidated financial

statements, including accounting policy and additional notes (“the consolidated financial

statements”).

In our opinion, the accompanying consolidated financial statements:

• give a true and fair view of the Group’s consolidated property and financial position as

at 31 December 2023, and of its consolidated financial result and its consolidated cash

flow for the financial year then ended in accordance with the applicable International

Financial Reporting Standards approved by the European Union and the adopted

accounting principles (policy);

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

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

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

issued on 7 March 2024.

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Basis for Opinion

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

International Standards on Auditing adopted by resolution of the National Council of Statutory

Auditors No. 3430/52a/2019 of 21 March 2019 regarding national standards on auditing and

other documents, as amended, and resolution of the Council of the Polish Agency for Audit

Oversight No. 38/I/2022 of 15 November 2022 on national standards on quality control and

National Standard on Auditing 220 (Revised)

(“NSA”), as well as according to the Act on

Statutory Auditors, Audit Firms and Public Supervision of 11 May 2017 (“the Act on Statutory

Auditors” - Journal of Laws of 2023, item 1015 as amended) and Regulation (EU) No 537/2014

of 16 April 2014 on specific requirements regarding statutory audit of public-interest entities

and repealing Commission Decision 2005/909/EC (“EU Regulation” - Official Journal of the

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

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

the Consolidated Financial Statements” section of our report.

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

Ethics for Professional Accountants (including International Independence Standards) issued

by the International Ethics Standards Board for Accountants (“the IESBA Code”), adopted by

resolution of the National Council of Statutory Auditors No. 3431/52a/2019 of 25 March 2019

on the principles of professional ethics for statutory auditors, as amended and other ethical

requirements which are applicable to the audit of financial statements in Poland. We have

fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA

Code. During the audit the key statutory auditor and the audit firm remained independent of

the Group Companies in accordance with the Act on Statutory Auditors and with the EU

Regulation.

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

provide a basis for our audit opinion.

Key Audit Matters

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

significance in the audit of the consolidated financial statements of the current reporting

period. These include the most significant assessed risks of material misstatement, including

the assessed risks of material misstatement due to fraud. These matters were addressed in

the context of our audit of the consolidated financial statements as a whole and in forming

our opinion thereon, and we summarized our responses to these risks, and, where deemed

appropriate, presented the most important observations related to these risks. We do not

provide a separate opinion on these matters.

Key audit matter

How our audit responded to this matter

Impairment for expected credit losses

on loans and other receivables to

customers

In accordance with the International

Financial Reporting Standard Financial

We critically analyzed the design and implementation

of the process for assessing credit risk and estimating

expected credit losses and verified the effectiveness of

the controls implemented by the Group for identifying

and estimating expected credit losses.

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Instruments 9 ("IFRS 9"), the Group’s

management should determine the

value of expected credit losses that may

occur during the 12-month period or the

remaining life of the financial asset,

depending on classification of individual

assets into risk categories ("stages")

taking into account the impact of future

macroeconomic conditions on the level

of expected credit losses.

Determining the amount and timing of

recognition of expected credit losses

requires the use of significant judgment

and significant and complex estimates,

including primarily in terms of the

parameters of credit risk in the models

for calculating expected credit losses.

The estimate of the impairment for

expected credit losses takes into

account the issue of the impact of

changing macroeconomic conditions of

the economy. This estimate required the

application by the Group’s Management

Board additional assumptions and

expert adjustments, which take into

account the uncertainties associated

with the current and future

macroeconomic environment and reflect

risk factors that were not included in the

Group's models.

We considered this area to be a key

audit matter because the estimation of

the impairment for expected credit

losses involves significant inherent risks

of misstatements as well as uncertainty

in the estimates made and requires the

Group's management to exercise

significant judgment and, given the size

of the loan portfolio, has a material

impact on the financial statements.

Note III.3.1.1 Estimation of expected

credit losses for financial assets and

Note II.2 Credit risk provide details on

the methods and models used and the

We performed a reconciliation of the base of loans and

other receivables to customers with the Group's

general ledger to confirm the completeness of the

recognition of loans and other receivables to customers

that are the basis for the impairment for expected credit

losses, as well as the value of these allowances.

We performed analytical procedures for the coverage

of the loan portfolio with expected credit losses and

their changes, as well as the transfer of exposures

between stages.

We evaluated the Group's impairment methodology for

compliance with the requirements of IFRS 9, in

particular with regard to the application of the criteria

for identifying a significant increase in credit risk, the

definition of default, the credit risk parameters adopted

and the consideration of the impact of future

macroeconomic conditions (forward looking

information) on the level of expected credit losses.

For the portfolio of loans and other receivables to

customers assessed using the collective method:

• we conducted an analysis of the methodology

used to calculate the impairment for expected

credit losses for exposures evaluated using the

collective method, including the adequacy of

the risk parameters used by the Group,

• we conducted an independent verification of

the calculation of impairment for expected

credit losses for the entire population of loans,

• we conducted an assessment of the

verification of models based on historical data

(so-called back-tests),

• we verified the approach and assumptions

used to create adjustments not included in the

models created to reflect the impact of

uncertain economic conditions on the valuation

of the impairment for expected credit losses.

For the portfolio of loans and other receivables to

customers assessed using the individual method:

• we conducted an analysis of the correctness of

the impairment identification process and

classification into stages,

Mazars Audyt Sp. z o.o. 5

level of impairment for expected credit

losses on loans and other receivables to

customers.

• on a selected sample of credit exposures, we

reviewed documents on the borrower's

financial situation and verified the correctness

of the assignment to the appropriate stage,

• for selected impaired loans and advances

(stage 3), we tested the assumptions used in

calculating expected credit losses, in particular

the expected scenarios and the probabilities

assigned to them, as well as the timing and

amounts of expected cash flows, including

cash flows from repayments and realization of

collateral.

We also assessed the adequacy and completeness of

disclosures regarding the impairment for expected

credit losses in the consolidated financial statements.

Impact of the legal risk of CHF-

indexed mortgage loans

The estimate of the impact of the legal

risk of CHF-indexed mortgage loans

resulting in the recognition of

adjustments to the gross carrying value

of these loans or related litigation

provisions is complex and requires a

significant degree of judgment in

determining the possible scenarios, as

well as with respect to the assumptions

made regarding the number of expected

lawsuits, the likelihood of their resolution

with consideration of the possibility of a

court settlement, and the amount of loss

if the Group loses a lawsuit or enters

into a court settlement.

The Group's estimates in this regard are

based on historical observations

indicating considerable uncertainty

about the number of lawsuits that will be

filed in court in the future, as well as the

lack of a consistent line of existing court

rulings.

Note III.3.6 Write-downs and portfolio

provisions related to the portfolio of

mortgage loans indexed to the CHF

exchange rate details the assumptions

In terms of estimating the amount of the impact of the

legal risk of CHF-indexed mortgage loans, our

examination procedures were mainly directed at

evaluating the model and the various assumptions

made by the Bank’s Management Board that have a

significant impact on the level of estimated legal risk

costs. In particular, we carried out the procedures

described below:

• we carried out a critical evaluation of the model

for estimating the impact of legal risk on CHF-

indexed mortgage loans and the various

assumptions,

• we held discussions with the Bank’s

Management Board and specialists, including

the Bank's lawyers, on the assumptions made,

taking into account historical observations,

including information and events subsequent to

the balance sheet date, past and possible legal

settlements, in particular settlements of the

Court of Justice of the European Union

(CJEU),

• we analyzed the Group's documentation for the

purpose of estimating the statistical probability

of realization of the various scenarios of

possible settlements,

• we verified the assumptions adopted by the

Group based on historical data for estimating

Mazars Audyt Sp. z o.o. 6

used to calculate the adjustment to the

gross carrying value of CHF-indexed

mortgages and related provisions for

litigation, as well as possible alternative

results presented as part of the

sensitivity analysis of the estimate.

the probability of future settlements and the

level of losses realized because of them,

• we analyzed the calculation of the value of

potential losses under the various scenarios

adopted by the Group based on historical data,

• we verified the model used by the Group to

estimate the impact of legal risk, verified the

correctness and completeness of the data

underlying the calculations, and confirmed the

mathematical correctness of the calculations,

• we analyzed events after the balance sheet

date and their impact on the estimate of

provisions,

• we analyzed the register of customer

complaints, with a particular focus on issues

related to and mortgage loans indexed to CHF.

We also assessed the adequacy and completeness of

the disclosures regarding the impact of legal risk on

CHF-indexed mortgage loans in the consolidated

financial statements.

Other Matters

The Group’s consolidated financial statements for the year ended 31 December 2022 have

been audited by an auditor acting on behalf of another audit firm. This auditor expressed an

unqualified opinion on these financial statements on 17 March 2023.

Responsibilities of the Parent Undertaking’s Management Board and

Supervisory Board for the Consolidated Financial Statements

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

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

and its financial performance in accordance with International Financial Reporting Standards

as adopted by the European Union and adopted accounting principles (policy), as well as with

the relevant legislation and with the provisions of the Parent Undertaking’s Articles of

Association. The Parent Undertaking’s Management Board is also responsible for such

internal control as the Management Board determines is necessary to enable the preparation

of consolidated financial statements that are free of material misstatement, whether due to

fraud or error.

In preparing the consolidated financial statements, the Parent Undertaking’s Management

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

as for disclosing, if applicable, matters related to going concern and for adopting the going

concern assumption as an accounting basis, unless the Management Board either intends to

liquidate the Group or to cease operations, or has no realistic alternative but to do so.

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

to ensure that the consolidated financial statements meet the requirements set out in the

Accounting Act the of 29 September 1994 (“Accounting Act” - Journal of Laws of 2023, item

120 as amended). Members of the Parent Undertaking’s Supervisory Board are responsible

for supervising the financial reporting process.

Statutory Auditor’s Responsibilities for the Audit of the Consolidated Financial

Statements

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

statements as a whole are free from material misstatement, whether due to fraud or error, and

to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of

assurance but is not a guarantee that an audit conducted in accordance with the 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 the aggregate, they could reasonably be

expected to influence the economic decisions of users taken on the basis of these

consolidated financial statements.

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

effectiveness or efficiency of running the Group’s affairs by the Parent Undertaking’s

Management Board at present or in the future.

According to NSA, we exercise professional judgement and maintain professional scepticism

throughout the audit, as well as:

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

statements, whether due to fraud or error, we design and perform audit procedures in

response to this risk and we obtain audit evidence which is sufficient and appropriate

to provide a basis for our audit opinion. The risk of not detecting a material

misstatement resulting from fraud is higher than for one resulting from error, as fraud

may involve collusion, forgery, intentional omissions, misrepresentations, or the

override of internal control;

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

to design audit procedures that are appropriate in the circumstances, but not for the

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

Group;

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

reasonableness of the accounting estimates and related disclosures, provided by the

Management Board of the Parent Undertaking;

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

of the going concern principle as a basis of accounting and, based on the audit

evidence obtained, whether a significant uncertainty related to events or conditions

exists and if that may cast significant doubt on the Group’s ability to continue as a

going concern. If we come to the conclusion that a material uncertainty exists, we are

required to pay attention in our auditor’s report on related disclosures in the

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

opinion. Our conclusions are based on the audit evidence obtained up to the date of

Mazars Audyt Sp. z o.o. 8

the auditor’s report. However, future events or conditions may cause the Group to

cease to continue as a going concern;

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

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

statements represent the underlying transactions and events in a manner that

achieves fair presentation.

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

of entities and to the economic activities within the Group, in order to express the

opinion on the consolidated financial statements. We are responsible for directing,

supervising, and conducting the Group’s audit and we remain exclusively responsible

for our audit opinion.

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

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

significant deficiencies in internal control identified by the auditor during the audit.

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

complied with relevant ethical requirements regarding independence and that we will

communicate all relationships and other matters that may reasonably be thought to bear on

our independence, and, where applicable, related safeguards.

From the matters communicated to the Parent Undertaking’s Audit Committee, we determine

those matters that were of most significance in the audit of the consolidated 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 or when, in

exceptional circumstances, we determine that a matter should not be communicated in our

report because the adverse consequences of doing so would reasonably be expected to

outweigh the public interest benefits of such communication.

Other Information, including the Management Report

Other information includes:

• the Management Report on Operations of the ING Bank Śląski S.A. Group in 2023

(“the Management report”) with the Letter from the CEO and corporate governance

statement, which is a separate parts of this Management report,

• a separate report on non-financial information specified in Article 55 (2c) of the

Accounting Act,

• Letter from the Supervisory Board Charmain,

• Representation of the Supervisory Board concerning the Audit Committee,

• Assessment of the annual financial statements of ING Bank Śląski S.A. for 2023

prepared by the Supervisory Board,

• Assessment of the ING Bank Śląski S.A. Group’s Operations in 2023 prepared by the

Supervisory Board.

(together “Other Information”).

Mazars Audyt Sp. z o.o. 9

Under Article 55 (2a) of the Accounting Act the Management report of the Group and of the

Parent Undertaking for 2023 were prepared jointly.

Responsibilities of the Management Board and Supervisory Board of the Parent

Undertaking

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

Information in accordance with the applicable regulations.

The Parent Undertaking’s Management Board and members of the Parent Undertaking’s

Supervisory Board are obliged to ensure that the Management report along with the corporate

governance statement, which is a separate part of this Management report, and a separate

non-financial report specified in Article 55 (2c) of the Accounting Act, meet the requirements

set out in the Accounting Act.

Statutory Auditor’s Responsibility

Our opinion on the audit of the consolidated financial statements does not cover the Other

information. In connection with our audit of the consolidated financial statements, our

responsibility is to read the Other information and, in doing so, consider whether the Other

Information is materially inconsistent with the consolidated financial statements, or our

knowledge obtained in the audit or otherwise appears to be materially misstated. If, based on

the work we have performed, we conclude that there is a material misstatement of this Other

Information, we are required to report that fact. In accordance with the Act on Statutory

Auditors, our responsibility is also to give an opinion whether the Management Report has

been prepared in accordance with applicable regulations and whether it complies with

information contained in the consolidated financial statements. In addition, in accordance with

requirements of Article 111a (3) of the Act of 29 August 1997 Banking Law (“Banking Law” -

Journal of Laws of 2023, item 2488 as amended), our responsibility is to audit information

specified in Article 111a (2) of the Banking Law contained in the Management Report.

Moreover, we are obliged to communicate whether the Group prepared a non-financial

statement and issue an opinion whether the Group included the required information in the

corporate governance statement.

Opinion on the Management Report

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

• has been prepared according to Article 49 of the Accounting Act and paragraph 71 of

the Regulation of the Minister of Finance of 29 March 2018 on Current and Periodic

Information Provided by Issuers of Securities and Conditions of Recognition of

Information Required under the Regulations of the non-EU Member State as

Equivalent (“Regulation on Current Information” - Journal of Laws of 2018, item 757

as amended) and Article 111a (2) of the Banking Law,

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

Mazars Audyt Sp. z o.o. 10

Opinion on Corporate Governance Statement

In our opinion, the Group included in the corporate governance statement information

specified in paragraph 70 (6) item 5 of the Regulation on Current Information. Moreover, in

our opinion, information specified in paragraph 70 (6) item 5 c-f, h and i of this Regulation

comprised in the corporate governance statement is compliant with the applicable provisions

and information contained in the consolidated financial statements.

Information on Non-financial Information

In accordance with requirements of the Act on Statutory Auditors we inform that the Group

prepared a non-financial statement referred to in Article 55 (2b) of the Accounting Act as a

separate part of the Group Management Report.

We have not conducted any assurance activities regarding the non-financial statement, and

we do not express any assurance about it.

Other Information Statement

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

audit, we declare that we have not identified any material misstatement in the Group

Management Report and the Other Information.

Report on Other Legal and Regulatory Requirements

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

Statements Prepared in the Single Electronic Reporting Format with the

Requirements of the Regulation on Technical Standards on the Specification of

a Single Electronic Reporting Format

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

to perform an assurance engagement to obtain reasonable assurance in order to express an

opinion on whether the consolidated financial statements of the Group as at 31 December

2023 prepared in the single electronic reporting format (“consolidated financial statements in

ESEF format”) were marked up in accordance with the requirements specified in the

Commission Delegated Regulation (EU) 2019/815 of 17 December 2018 supplementing

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

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

Identification of Criteria and Description of the Subject of the Engagement

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

Undertaking’s Management Board in order to fulfil the criteria regarding the marking up and

technical requirements concerning the specification of single electronic reporting formal which

are specified in the ESEF Regulation.

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

consolidated financial statements in ESEF format with the requirements of the ESEF

Regulation, and the requirements specified in these regulations form, in our opinion,

Mazars Audyt Sp. z o.o. 11

adequate criteria to express our opinion.

Responsibilities of the Management Board and Supervisory Board of the Parent

Undertaking

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

statements in ESEF format in accordance with the requirements regarding the marking up

and technical requirements concerning the specification of single electronic reporting formal

which are specified in the ESEF Regulation. Such responsibility includes the selection and

application of appropriate XBRL markups using the taxonomy specified in these regulations.

The responsibility of the Management Board also includes the design, implementation, and

maintenance of such internal control as determined to be necessary to enable the preparation

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

incompliance with the ESEF Regulation.

Members of the Parent Undertaking’s Supervisory Board are responsible for supervising the

financial reporting process, also including the preparation of the financial statements

according to the format prescribed by applicable laws.

Statutory Auditor’s Responsibility

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

providing reasonable assurance that the consolidated financial statements in ESEF format

were marked up in accordance with the requirements of the ESEF Regulation.

We have performed our engagement in accordance with the National Standard on Assurance

Engagements for the audit of financial statements prepared in a single electronic format

3001PL (“NSAE 3001PL”), and where applicable, National Standard on Assurance

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

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

Audits or Reviews of Historical Financial Information (“NSAE 3000 (R)”).

This standard imposes an obligation on the auditor to plan and execute procedures in order

to obtain reasonable assurance that the consolidated financial statements in ESEF format

were prepared in accordance with specified criteria.

Reasonable assurance is a high level of assurance but is not a guarantee that an engagement

conducted in accordance with the NSAE 3001PL, and where applicable NSAE 3000(R), will

always detect a material misstatement when it exists.

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

risk of material misstatements due to fraud or error. When performing risk assessment and

in order to design procedures to be performed the auditor takes into consideration the internal

controls related to the preparation of the consolidated financial statements in ESEF format,

which can provide the auditor with sufficient and appropriate evidence. The assessment of

the internal controls was not performed for the purpose of expressing an opinion on the

effectiveness of the internal control.

Summary of the Work Performed

Procedures planned and performed by us included:

Mazars Audyt Sp. z o.o. 12

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

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

markups by the Company and ensuring compliance with the ESEF Regulation, in

which the understanding of internal controls related to this process;

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

statements in ESEF format to the audited consolidated financial statements;

• using a specialized IT tool evaluating the compliance with technical standards

concerning the specification of single electronic format, evaluating the completeness

of marking up information in the consolidated financial statements in ESEF format

using XBRL markups;

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

specified in the ESEF Regulation and the creation of extension markups where no

suitable element in the core taxonomy specified in the ESEF Regulation has been

identified;

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

core taxonomy specified by the ESEF Regulation;

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

using XBRL markups.

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

basis for our opinion on the compliance of the marking up with requirements of the ESEF

Regulation.

Ethical Requirements, Including Independence

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

independence requirements and other ethical requirements as specified by the IESBA Code.

The IESBA Code is based on the fundamental principles related to integrity, objectivity,

professional competence and due care, confidentiality, and professional behaviour. We have

also complied with other independence and ethical requirements which are applicable to such

assurance engagement in Poland.

Quality Control Requirements

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

Council of the Polish Agency for Audit Oversight No. 38/I/2022 of 15 November 2022.

National Standard on Quality Control 1 as per International Standard on Quality Management

(PL) 1 requires the audit firm to design, implement and operate a system of quality

management, including policies or procedures relating to compliance with ethical

requirements, professional standards and applicable legal and regulatory requirements.

Opinion on Compliance with ESEF Regulation Requirements

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

opinion should be read in conjunction with these matters.

In our opinion, the consolidated financial statements in ESEF format were marked up in all

material respects in accordance with the requirements of the ESEF Regulation.

Mazars Audyt Sp. z o.o. 13

Information on Observing Applicable Prudential Regulations

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

the Group’s operations with prudential regulations, in which for the correct determination of

capital ratios.

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

applicable prudential regulations, defined in separate provisions, and in particular whether the

Group correctly determined the capital ratios presented in note I.3.4. “Capital Adequacy”.

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

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

such an opinion.

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

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

1 January 2023 to 31 December 2023, defined by separate provisions, in particular with

respect to the correctness of the determination of capital ratios by the Group as at 31

December 2023, which could have a significant impact on the consolidated financial

statements.

Declaration on Non-audit Services

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

provided to the Group comply with laws and regulations applicable in Poland and that we have

not provided any non-audit services that are prohibited pursuant to Article 5 (1) of the EU

Regulation and Article 136 of the Act on Statutory Auditors. Non-audit services that we

provided to the Group during the audited period were specified in section “Selection of an

entity authorized to audit financial statements” of the Group Management Report.

Appointment of an Audit Firm

We were appointed to conduct the audit of the consolidated financial statements of the Group

based on the resolution of the Parent Company’s Supervisory Board of 9 December 2022. We

have been auditing the consolidated financial statements of the Group for the first time.

Mazars Audyt Sp. z o.o. 14

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

independent statutory auditor’s report is Małgorzata Pek.

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

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

audited the consolidated financial statements.

Małgorzata Pek

Key Statutory Auditor

No 13070

Warsaw, 7 March 2024