hol
Management Board Report on
the activity of Bank Millennium
S.A. and Capital Group of Bank
Millennium S.A. in 2024
This document is a translation from the original Polish version. In case of any discrepancies between the Polish and English versions, the Polish version shall
prevail.
Some data and statistics presented in this document are based on management data and may differ from values presented in Annual Consolidated Financial
Report of the Bank Millennium S.A. Capital Group for 12-month period ending 31
st
December 2024.
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
TABLE OF CONTENTS
I. MANAGEMENT BOARD REPORT ON ACTIVITY ......................................................................... 9
1. BRIEF DESCRIPTION OF BANK MILLENNIUM AND BANK MILLENNIUM GROUP ........................................ 9
2. SUMMARY OF CONSOLIDATED BM GROUP RESULTS IN 2024 .......................................................... 12
3. INFORMATION FOR INVESTORS .......................................................................................... 26
3.1. SHARE PRICE PERFORMANCE ........................................................................................ 26
3.2. BANK MILLENNIUM’S RATINGS ...................................................................................... 27
3.3. INVESTOR RELATIONS ................................................................................................ 28
3.4. DIVIDEND POLICY ..................................................................................................... 28
4. MARKET CONDITIONS AND MACRO RISK FACTORS .................................................................... 29
4.1. MACROECONOMIC ENVIRONMENT .................................................................................. 29
4.2. FACTORS OF UNCERTAINTY FOR THE ECONOMY AND BANK MILLENNIUM GROUP ............................. 31
5. OTHER IMPORTANT CONSIDERATIONS ................................................................................. 32
5.1. RECOVERY PLAN AND CAPITAL PROTECTION PLAN ............................................................... 32
5.2. CREDIT HOLIDAYS .................................................................................................... 32
5.3. FX-MORTGAGE LEGAL RISK .......................................................................................... 32
6. POLISH BANKING SECTOR AND BM/BM GROUP’S POSITION .......................................................... 37
6.1. POLISH BANKING SECTOR IN 2024 .................................................................................. 37
6.2. THE BANK’S AND BM GROUP’ POSITION ON THE MARKET ........................................................ 38
7. STRATEGY AND BUSINESS DEVELOPMENT PROSPECTS ............................................................... 39
7.1. 2022 – 2024 STRATEGY AND ITS DELIVERY ......................................................................... 39
7.2. NEW STRATEGY CYCLE - STRATEGIC OBJECTIVES FOR 2025-2028 .............................................. 40
7.3. BUSINESS OUTLOOK FOR 2025 ...................................................................................... 42
8. FINANCIAL SITUATION ................................................................................................... 43
8.1. PROFIT AND LOSS ACCOUNT ........................................................................................ 43
8.2. RESULTS OF BUSINESS SEGMENTS .................................................................................. 48
8.3. BALANCE SHEET AND OFF-BALANCE SHEET ITEMS ................................................................ 52
9. PRESENTATION OF BUSINESS ACTIVITY ................................................................................ 60
9.1. INNOVATION AND HIGHEST QUALITY OF POSITIVE CUSTOMER EXPERIENCE ................................... 60
9.2. RETAIL BANKING ..................................................................................................... 61
9.3. CORPORATE BANKING ............................................................................................... 71
9.4. SUBSIDIARIES’ ACTIVITY ............................................................................................. 77
10. MAIN AWARDS AND ACHIEVEMENTS IN 2024 ............................................................................ 81
11. RISK MANAGEMENT ....................................................................................................... 84
11.1. RISK MANAGEMENT OVERVIEW ..................................................................................... 84
11.2. CAPITAL MANAGEMENT .............................................................................................. 88
11.3. CREDIT RISK ........................................................................................................... 94
11.4. OTHER RISKS ........................................................................................................ 107
12. HUMAN RESOURCES MANAGEMENT ................................................................................... 113
12.1. HUMAN RESOURCES (HR) POLICY ................................................................................. 113
12.2. EMPLOYMENT AND PERSONNEL COSTS ........................................................................... 117
12.3. REMUNERATION POLICY ........................................................................................... 118
13. PRINCIPLES OF CORPORATE GOVERNANCE AT BANK MILLENNIUM ................................................ 122
13.1. STATEMENT ON THE PRINCIPLES OF CORPORATE GOVERNANCE APPLIED IN 2023 .......................... 122
13.2. SHAREHOLDERS AND GENERAL MEETING OF SHAREHOLDERS ................................................. 123
13.3. SUPERVISORY BOARD .............................................................................................. 125
13.4. MANAGEMENT BOARD .............................................................................................. 137
13.5. INTERNAL CONTROL SYSTEM AND EXTERNAL AUDITOR ........................................................ 143
14. ADDITIONAL INFORMATION ............................................................................................ 148
II. SUSTAINABILITY REPORTING ........................................................................................ 149
15. GENERAL DISCLOSURES (ESRS 2) ...................................................................................... 149
15.1. BASIS OF PREPARATION............................................................................................ 149
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
15.2. CORPORATE GOVERNANCE ........................................................................................ 150
15.2.1. BUSINESS MODEL AND VALUE CHAIN ................................................................... 151
15.2.2. SUSTAINABILITY STRATEGY ............................................................................. 153
15.3. SUSTAINABILITY MANAGEMENT ................................................................................... 155
15.3.1. GOVERNANCE STRUCTURE .............................................................................. 155
15.3.2. INTEGRATION OF SUSTAINABILITY-RELATED PERFORMANCE IN INCENTIVE SCHEMES ............ 161
15.3.3. SUSTAINABILITY REPORTING ........................................................................... 162
15.4. DOUBLE MATERIALITY ASSESSMENT .............................................................................. 164
15.4.1. DESCRIPTION OF THE PROCESS FOR IDENTIFYING AND ASSESSING MATERIAL IMPACTS, RISKS AND
OPPORTUNITIES ......................................................................................................... 164
15.4.2. KEY STAKEHOLDERS ..................................................................................... 166
15.4.3. IDENTIFIED IMPACTS, RISKS AND OPPORTUNITIES .................................................... 168
15.4.4. LIST OF REQUIREMENTS ................................................................................. 180
16. CLIMATE CHANGE (ESRS E1) ........................................................................................... 181
16.1. STRATEGY ........................................................................................................... 181
16.2. MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES....................................................... 182
16.3. METRICS AND TARGETS ............................................................................................ 188
16.3.1. CLIMATE-RELATED TARGETS ........................................................................... 188
16.3.2. ENERGY CONSUMPTION AND MIX ...................................................................... 189
16.3.3. GROSS SCOPES 1, 2, 3 AND TOTAL GHG EMISSIONS .................................................. 190
16.3.4. GHG REMOVALS AND GHG MITIGATION PROJECTS FINANCED THROUGH CARBON CREDITS ..... 204
16.3.5. INTERNAL CARBON PRICING ............................................................................ 204
17. BANK MILLENNIUM GROUP EMPLOYEES (ESRS S1) ................................................................... 205
17.1. STRATEGY FOR THE WORKFORCE AREA ......................................................................... 205
17.1.1. INTERESTS AND VIEWS OF STAKEHOLDERS ............................................................ 205
17.1.2. MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH STRATEGY AND
BUSINESS MODEL ........................................................................................................ 205
17.1.3. POLICIES RELATED TO OWN WORKFORCE ............................................................. 208
17.1.4. PROCEDURES FOR COOPERATION WITH OWN WORKFORCE AND EMPLOYEE REPRESENTATIVES
REGARDING IMPACTS ................................................................................................... 213
17.2. WORKFORCE CHARACTERISTICS .................................................................................. 215
17.2.1. CHARACTERISTICS OF THE ENTITY’S WORKFORCE ................................................... 215
17.2.2. CHARACTERISTICS OF NON-EMPLOYEES CONSTITUTING OWN EMPLOYEE RESOURCES ........... 217
17.3. EMPLOYMENT SECURITY, FRIENDLY PLACE TO WORK .......................................................... 218
17.3.1. POLICIES RELATED TO EMPLOYMENT SECURITY ...................................................... 218
17.3.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES ................................................ 218
17.3.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 220
17.3.4. WORK-LIFE BALANCE METRICS ......................................................................... 220
17.4. EMPLOYEE COMPENSATION ....................................................................................... 222
17.4.1. POLICIES RELATED TO EMPLOYEE COMPENSATION ................................................... 222
17.4.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES ................................................ 223
17.4.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 223
17.4.4. ADEQUATE WAGES ....................................................................................... 224
17.4.5. COMPENSATION METRICS ............................................................................... 224
17.5. WORKING TIME ..................................................................................................... 225
17.5.1. POLICIES RELATED TO WORKING TIME ................................................................. 225
17.5.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES ................................................ 225
17.5.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 226
17.6. EMPLOYEE HEALTH AND SAFETY ................................................................................. 226
17.6.1. POLICIES RELATED TO EMPLOYEE HEALTH AND SAFETY ............................................. 226
17.6.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES ................................................ 226
17.6.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 228
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
17.6.4. OCCUPATIONAL HEALTH AND SAFETY METRICS ...................................................... 229
17.7. PROMOTING DIVERSITY AND EQUAL EMPLOYEE COMPENSATION ............................................. 229
17.7.1. POLICIES RELATED TO EMPLOYEE COMPENSATION AND DIVERSITY ................................ 230
17.7.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES ................................................ 230
17.7.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 231
17.7.4. DIVERSITY METRICS ...................................................................................... 231
17.8. TRAINING AND DEVELOPMENT .................................................................................... 233
17.8.1. POLICIES RELATED TO TRAINING AND DEVELOPMENT ............................................... 233
17.8.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES ................................................ 234
17.8.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 236
17.8.4. TRAINING AND SKILLS DEVELOPMENT METRICS ....................................................... 237
17.9. COUNTERING VIOLATIONS IN THE WORKPLACE ................................................................. 237
17.9.1. POLICIES RELATED TO COUNTERING VIOLATIONS .................................................... 237
17.9.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES ................................................ 238
17.9.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 238
17.9.4. PROCESSES FOR REMEDIATION OF NEGATIVE IMPACTS AND CHANNELS FOR REPORTING VIOLATIONS
239
17.10. PRIVACY ........................................................................................................... 240
17.10.1. POLICIES RELATED TO PRIVACY ........................................................................ 240
17.10.2. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES ACTIONS TAKEN TO
IMPLEMENT POLICY OBJECTIVES ....................................................................................... 240
17.10.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND ACTIVITIES .................. 241
18. WORKERS OF THE BANK MILLENNIUM GROUP’S VALUE CHAIN (ESRS S2) ......................................... 242
18.1. STRATEGY ........................................................................................................... 242
18.2. MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES....................................................... 243
18.3. BENCHMARKS AND OBJECTIVES ................................................................................... 245
19. BANK MILLENNIUM CUSTOMERS (ESRS S4) ........................................................................... 246
19.1. CUSTOMER STRATEGY ............................................................................................. 246
19.1.1. INTERESTS AND VIEWS OF STAKEHOLDERS ............................................................ 246
19.1.2. MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH STRATEGY AND
BUSINESS MODEL ........................................................................................................ 246
19.2. GENERAL CUSTOMER ENGAGEMENT PROCESSES ................................................................ 248
19.3. RESPECT FOR HUMAN RIGHTS IN CUSTOMER RELATIONS ...................................................... 249
19.4. SAFETY OF DEPOSITED FUNDS .................................................................................... 250
19.4.1. POLICIES RELATED TO THE SAFETY OF DEPOSITED FUNDS .......................................... 250
19.4.2. GENERAL CUSTOMER ENGAGEMENT PROCESSES IN TERMS OF THE SAFETY OF DEPOSITED FUNDS
251
19.4.3. MEASURES TO ENSURE THE SAFETY OF DEPOSITED FUNDS .......................................... 252
19.4.4. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES ............................. 254
19.5. PRIVACY ............................................................................................................. 255
19.5.1. POLICIES RELATED TO PRIVACY ........................................................................ 255
19.5.2. CUSTOMER ENGAGEMENT PROCESSES IN TERMS OF PRIVACY ....................................... 256
19.5.3. MEASURES RELATED TO PRIVACY....................................................................... 257
19.5.4. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES ............................. 258
19.6. ACCESS TO (HIGH-QUALITY) INFORMATION ..................................................................... 258
19.6.1. POLICIES RELATED TO ACCESS TO (HIGH-QUALITY) INFORMATION ................................ 258
19.6.2. CUSTOMER ENGAGEMENT PROCESSES IN TERMS OF ACCESS TO INFORMATION ................... 260
19.6.3. MEASURES RELATED TO ACCESS TO INFORMATION ................................................... 260
19.6.4. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES ............................. 262
19.7. RESPONSIBLE MARKETING PRACTICES ........................................................................... 262
19.7.1. POLICIES RELATED TO RESPONSIBLE MARKETING PRACTICES ....................................... 262
19.7.2. MEASURES RELATED TO RESPONSIBLE MARKETING PRACTICES ..................................... 263
19.7.3. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES ............................. 264
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
19.8. NON-DISCRIMINATION (INCLUSIVE BANKING) ................................................................... 265
19.8.1. POLICIES RELATED TO NON-DISCRIMINATION ......................................................... 265
19.8.2. MEASURES RELATED TO NON-DISCRIMINATION ....................................................... 265
19.8.3. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES ............................. 267
19.9. REMEDIATION OF NEGATIVE IMPACTS ............................................................................ 268
20. BUSINESS CONDUCT (ESRS G1) ........................................................................................ 270
20.1. CORPORATE CULTURE AND BUSINESS ETHICS ................................................................... 270
20.2. ANTI-CORRUPTION ................................................................................................. 271
20.3. WHISTLEBLOWER REPORTING AND PROTECTION .............................................................. 273
21. DISCLOSURE OF INFORMATION IN ACCORDANCE WITH THE EU TAXONOMY (ART. 8 REGULATION (EU)
2020/852) ............................................................................................................... 276
22. APPENDICES ............................................................................................................. 306
III. STATEMENTS OF MANAGEMENT BOARD ............................................................................ 319
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
Dear Ladies and Gentlemen,
Bank Millennium is entering a new strategic cycle. In October 2024, we presented our action plan for
the next 4 years: "Strategy 2028 - Value and Growth". We plan further dynamic growth, as clearly
illustrated by the targets of doubling the loan portfolio in the corporate banking segment to over PLN
25 billion and increasing the number of active retail clients to 3.7 million.
We are approaching the implementation of the goals of the new strategy from a strong business,
capital, and liquidity position. In 2024, we commemorated the 35th anniversary of our establishment,
marking the strategic achievement of reaching 150 thousand active customers in the micro-enterprise
segment. The year concluded with a net profit of PLN 719 million, representing a 25% year-over-year
increase. This commendable outcome was achieved despite facing significant challenges impacting
our business, particularly the high costs associated with the portfolio of mortgage loans in foreign
currencies. Nevertheless, the resolution of the Swiss franc issue is anticipated within the next year
and a half, barring any unforeseen developments. According to our base scenario, the expected
improvement in profitability over the coming years should enable us, contingent upon achieving the
targets, to plan for the resumption of dividend payments in 2027, derived from the profits of 2026.
The Bank has made a refreshed mobile application available to retail customers. We have launched a
Currency Exchange Desk, which is the possibility of exchanging currencies directly in our mobile
application. We have implemented the BLIK Pay Later deferred payment service. For corporate clients
operating in the e-commerce industry, we have launched the Millennium PAY payment gateway. We
have introduced the prestigious Visa Global credit card, which is part of a refreshed offer for affluent
clients and the new Millennium 360 Prestige account, which was launched at the beginning of 2025.
In 2024, the Bank also implemented generative artificial intelligence (genAI) solutions. The latest
technology supports document analysis, complaints, and transcription of phone calls and chats. We
are also starting to use it in the software development and testing process. We see great potential in
the use of genAI in marketing and communication with customers, especially in the field of service
personalisation.
In 2024, we focused strongly on the implementation of activities in the area of sustainable
development, which is an integral part of our processes, an important part of the organisational
culture and one of the pillars of the Bank's strategy. We continued our efforts to reduce Scope 1 and
Scope 2 emissions, and for the first time we calculated emissions from our loan and lease portfolio,
which forms the basis for planning further decarbonisation efforts. We have devoted a lot of attention
to the development of ESG risk management and improving our approach to the impact of this risk on
the financed entities and projects. To support companies in the implementation of pro-environmental
projects, we have been developing our green loan portfolio, providing an offer tailored to the needs
of customers and helping them obtain support from public programmes. Last year, we also completed
our first issue of green bonds under the green bond framework of our EMTN Program, which ensure
the flow of money towards environmentally friendly initiatives. We have further ambitious goals ahead
of us, building commitment to the sustainable transformation of business and the economy.
We are closely following the development of our Our People'24: Save the Planet campaign. As part of
the sports challenge, employees of the Bank Millennium Group exercise and cover kilometres, which
are converted into PLN. The money goes to the Bank Millennium Foundation's account. This year, the
initiative attracted over 1400 employees, who covered over 530 thousand kilometres on legs and
wheels and performed almost 19 thousand various types of exercises. The amount of PLN 250 thousand
was used for the implementation of almost 50 projects as part of employee eco-volunteering. Over
200 volunteers used one and a half thousand hours to, among other things, help those affected by the
flood in southern Poland. The Bank also provided support, among others by allocating a subsidy to the
Polish Red Cross and Caritas Poland and by providing customers with the opportunity to provide help
as part of the Pomagam Transfer in our mobile application.
In 2024, Bank Millennium achieved many successes that strengthened its position on the market. We
won the title of the best digital Bank in Poland by the Global Finance magazine. For the second year
in a row, we won the "Newsweek's Friendly Bank" ranking in both categories: "Traditional Banking" and
"Remote Banking". We triumphed in the TOP 3 list of the best banks for companies in Poland according
to Forbes magazine. We have also received the title of "Top Employer Polska 2024", confirming high
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
standards in human resources management. Millennium Docs Against Gravity, festival supported by
Bank Millennium, appeared on the list of festivals qualifying for the Oscars®.
Before concluding, I would like to express my deep thanks to Bogusław Kott for years of leadership,
inspiration and chairmanship. Mr. Kott, that was one of the founders of the Bank and served as its
CEO and then Chairman of the Supervisory Board during 36 years, has now decided to limit his
professional activity.
Our Bank is made up of exceptional people who are able to implement valuable and groundbreaking
projects. It is thanks to the commitment of each of the Group's employees that Bank Millennium not
only achieves such good financial results, but also strengthens its competitive advantage. We are a
trusted partner to our customers and shareholders. We are constantly implementing innovations and
raising market standards. I believe that we can look with optimism at the next challenges that we are
facing. Enjoy reading the Report.
João Bras Jorge
Chairman of the Management Board
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
(*) Adjusted
OUR EMPLOYEESOUR CLIENTS
3.1mn active retail clients
10k active corpo. clients
6,714 FTEs
TRANSACTIONSONLINE USERS
2.9mn active digital
users
Digital share:
84% in cash loans
95% in term deposits
Key operating statistics
Mobile banking
Key financial Indicators
COST-TO-INCOMEREVENUES
PLN6.0bn
37.6% / 30.8%*
CAPITAL RATIOSTOTAL ASSETS
PLN139bn
+11% y/y
T1 14.8%
TCR 17.2%
Basic facts for investors
SHARE PRICEMARKET CAP.
PLN10.8bn
(EUR2.5bn)
(@YE24)
PLN8.90 / +7%
(YE24 / % change in
2024)
RATINGSINDICES
WIG
mWIG40
WIG Banks
Moodys: Ba2
(adjusted BCA: ba2)
positive outlook
Fitch: BB+ (VR: bb+)
positive outlook
MSCI: A (average
ESG rating)
+35% BLIK transactions: e-commerce, P2P, contactless, BNPL
+62% BLIK contactless transactions
+37% P2P BLIK transfer to mobile
+36% BLIK contactless users
Digital share:
84% in cash loan sales in 2H24
42% in current account acquisition in 2H24
95% in term deposit sales in 2H24
54% in junior account acquisition in 2H24
BANK MILLENNIUM GROUP IN 2024
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
I. MANAGEMENT BOARD REPORT ON ACTIVITY
1. BRIEF DESCRIPTION OF BANK MILLENNIUM AND BANK MILLENNIUM
GROUP
Bank Millennium S.A. (‘Bank Millennium’, ‘Bank’) was established in 1989 as one of the first Polish
commercial banks. It is now one of the top 7 commercial banks in Poland in terms of assets and offers
its services to all market segments via a network of 606 branches (including 363 own branches and
243 franchise branches), a network of personal advisors as well as electronic and mobile banking.
Ever since the start of its activity it has been a trendsetter in Polish banking. For example it was the
first Bank to be listed on the Warsaw Stock Exchange and issued the first payment card on the Polish
market. The bank satisfies most stringent standards of corporate governance; it implements social
programmes to support culture development as well as education of the youth.
Bank Millennium is a market leader in the area of innovations understood to mean state-of-the-art
technology and process improvements. Innovation in Bank Millennium is part of its business strategy.
Bank Millennium, together with its subsidiaries, forms Bank Millennium Group (‘BM Group’, ‘Group’)
- one of the most innovative and comprehensively developing financial groups in Poland – employing
in total 6,714 persons (FTE).
Bank Millennium Group’s structure (31.12.2024)
Subsidiaries and associates
The most important companies of the Group are: Millennium Leasing (leasing activities), Millennium
TFI (investment funds) and Millennium Bank Hipoteczny (obtaining long-term financing through
issuance of covered bonds). Since 2016, Millennium Goodie together with the Bank has been running
an innovative smartshopping platform based on advanced technology. The offer of the above-
mentioned companies complements the services and products offered by the Bank. The Bank remains
a 20% shareholder of Europa Millennium Financial Services sp. z o.o. together with Towarzystwo
Ubezpieczeń na Życie Europa S.A. and Towarzystwo Ubezpieczeń Europa S.A. and continues long-term
cooperation in the area of bancassurance under agreements concluded with the company's
shareholders regarding the insurance distribution model.
Millennium
Consulting S.A.
Millennium Leasing
sp. z o.o.
Millennium Bank
Hipoteczny S.A.
Millennium Services
sp. z o.o.
Millennium Goodie
sp. z o.o.
Millennium TFI S.A.
Millennium
Telecommunication
Services sp. z o.o.
PIAST EXPERT sp. z
o.o. w likwidacji
Lubuskie Fabryki
Mebli S.A. w
likwidacji
100%
100%
98%
2%
100%
Europa Millennium
Financial Services
sp. z o.o.
100%
100%
100%
20%
50% 100%
subsidiaries
associates
entities consolidated applying the full method
entities valuated applying equity method
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
Business model
Bank Millennium operates with the strong ambition of embracing innovation, digitally delivering top-
quality services, to be the primary bank for individuals and companies in Poland. The core pillars of
business model are defined by segments and operating model enablers.
Key segments, where Bank Millennium competes, are:
in retail banking:
• Mass individual clients – we are building primary relationship based on daily banking,
customer assets and selective lending with keeping top-quality and digital first approach
• Affluent clients – we are upselling from mass individual clients market, offering a digital
affluent service with remote Relationship Managers focused on savings and investments
• SOHO clients – we are acquiring private entrepreneurs (Sole Traders with annual revenues up
to 10M PLN) and building primary relationships mainly through digital offer with remote
support and sales
and in corporate banking:
• Small Business clients – we are acquiring small businesses (companies with annual revenues
up to 20M PLN) and building primary relationships with small companies with digital-enabled,
standardised credit and daily banking proposition supported by remote Relationship Managers
1. Mid corporate clients – we are the challenger player, significantly driving portfolio growth
with focus on investment loans and leasing
Key enablers supporting effective business model are:
• People management and culture development to ensure market leading offer for talents
and continue building a top work environment
• Technology & resilience to implement innovative technological solutions, incl. AI, addressing
customers` needs and ensuring highest cybersecurity standards
• Digital & operational efficiency to continue digitalisation of clients relation and foster
balanced organisation with proper resources allocation to sustain value creation
• Compliance & risk management to maintain sound risk management and understanding of
regulatory environment, with capital generation and allocation sustaining business growth
• Sustainability: to continue enacting sustainability initiatives and explore business
opportunities from ESG and sustainable transition.
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Management Board Report on activity of Bank Millennium S.A. and
Capital Group of Bank Millennium S.A. for 2024
Bank Millennium’s business model
The business model is founded on key values: building relationships based on trust, a passion for
quality and innovation, people development and promoting cooperation as well as the ambition to
always aim higher.
The Bank Millennium Group’s Values
Financial
Capital
Intellectual
Capital
Social
Capital
Natural
Capital
Human
Capital
Value
for Stakeholders
Value
For Employees
Value
for Society
Value
for Customers
Mission & Vision
Management
Mass
Individual
Affluent SOHO
Retail
Mid Corporate
Small Business
Corporate
Enablers
People and culture development
Technology & resilience
Digital & operational efficiency
Compliance & risk management
Sustainability
Strategy & Business Model
Input
Results
12
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
2. SUMMARY OF CONSOLIDATED BM GROUP RESULTS IN 2024
2024 in brief
While 2023 was a breakthrough year for Bank Millennium S.A. (‘Bank’) and Bank Millennium S.A.
Capital Group’s (‘BM Group’, ‘Group’) with all quarters in the black and a positive full-year net result,
2024 was no less eventful and successful. It brought continued solid performance of the core business,
further solidifying profitability. Reported FY2024 net profit grew 25% to PLN719 million. The capital
position remained stable and solid with capital surplus exceeding 5 percentage points over minimum
regulatory requirements.
A number of new or revamped products was introduced during the year, numerous business initiatives
yielded significant results while most KPIs from the 2022-2024 strategy were delivered ahead of plan.
Furthermore, many prestigious awards received in 2024 proved continued focus on quality, innovation
and client centricity.
In May and June respectively, the Capital Protection and Recovery plans were formally completed.
Also in June, Millennium Bank Hipoteczny, the mortgage subsidiary, successfully placed its inaugural
issue of covered bonds, while in September the Bank issued its first green bonds (MREL SNPs of a total
value of EUR500 million), significantly strengthening the surplus over MREL requirements.
A new strategy (“Strategy 2028 – Value & Growth”) was adopted in October following a period of
intense work. Apart setting ambitious financial and business targets, the strategic plan includes an
ambition to return to dividend payments in 2027.
Last but not least, while costs related to the legacy portfolio of FX-mortgage loans remained a heavy
burden on 2024 results, the continued efforts to reduce this risk took decreased the portfolio below
the materiality threshold. In early 2025 the progress of FX-mortgage risk reduction was acknowledged
by the regulator who revoked the P2R buffer.
2024 results in brief
BM Group reported profit of PLN719 million (up 25% y/y) in 2024 overall, translating into reported
ROE of 9.8% (9.1% in 2023). This solid result was achieved despite persistent elevated costs related
to FX-mortgage portfolio (PLN2,558 million after tax) and cost of credit holidays (PLN91 million after
tax), and the return to the payment of asset tax (banking tax) since June.
2024 net profit without FX-mortgage related costs and without positive (e.g. capital gains on
bancassurance transaction in 2023, lack of banking tax in 2023 and part of 2024) and negative items
(e.g. credit holidays) would amount to a record level of PLN3,202 million (up 7% y/y) translating into
an adjusted ROE of 18.5% (2023: 21.7%).
Net result (reported and adjusted) (PLNmn)
23
-1,332
-1,015
576
719
695
1,098
2,239
2,993
3,202
-1,800
-800
200
1,200
2,200
3,200
4,200
2020 2021 2022 2023 2024
Net result reported
Net result w/o FX-mortgage related costs and w/o credit holidays cost in 2022-24 but with
hypothetical bank tax between July'22 and May'24
13
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Major items used for adjustments of results*
#
2024
2023
(PLNmn)
FX-mortgage related costs (pre-tax)
(3,219)
(3,540)
FX-mortgage related costs (after-tax)
1
(2,558)
(3,338)
Credit holidays (after tax)
2
(91)
(7)
Capital gain on bancassurance transaction (after tax)
3
0
528
Hypothetical banking tax (before=after tax)
4
(167)
(400)
Reported net profit
5
719
576
Adjusted net profit (5+1+2-3-4)**
3,202
2,993
(*) value sign denotes actual impact on reported result
(**) formulae for adjustments is using an absolute value of each item
Solid growth of operating performance, implementation of 2021-24 strategy completed
2024 was a year of solid performance from the operating perspective. Loan growth remained
moderate (impact of fast contracting FX-mortgage portfolio) but corporate book showed early signs
of recovery (up 5% y/y). Liquidity surplus increased further (deposits up 9% y/y) while L/D ratio
reached a new low of 64%. Combined with lowered deposit pricing this translated into further growth
of NII (reported up 5% y/y, adjusted for credit holidays up 7% y/y). Additionally, volume of investment
products grew 35% y/y to PLN11.1 billion.
Profit & Loss in brief
2024
2023
y/y
(PLN million)
Net interest income
5 530
5 253
5%
Net commission income
777
782
-1%
Core income
6 307
6 036
4%
Other non-interest income
(311)
687
-
Total operating income
5 996
6 723
-11%
Personnel costs
(1 197)
(1 035)
16%
Other administrative costs
(1 056)
(958)
10%
Total operating costs
(2 253)
(1 993)
13%
Impairment provisions and other cost of risk *
(310)
(299)
4%
Other modification
(147)
(52)
181%
FX legal risk related provision
(2 179)
(3 065)
-29%
Banking tax
(232)
0
-
Pre-income tax profit
875
1 312
-33%
Income tax
(156)
(737)
-79%
Net profit – reported
719
576
25%
Net profit – adjusted **
3 202
2 993
7%
NIM
4.4%
4.6%
-0.2 p.p.
Cost/income reported
37.6%
29.6%
7.9 p.p.
Cost/income adjusted ***
30.8%
29.5%
1.2 p.p.
Cost of risk (bp)
40
39
1 b.p.
ROE
9.8%
9.1%
0.7 p.p.
ROE adjusted **
18.5%
21.7%
-3.2 p.p.
14
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
(*) Impairment provisions for financial and non-financial assets including also fair value adjustment of credit portfolio (2-
2024: PLN0.7mn. 2023: PLN-1.0mn) and loans modification effect not related to amicable settlements with FX mortgage
borrowers (2024: PLN35.7mn, 2023: PLN36.0mn); (**) Without extraordinary items, i.e. cost of credit holidays (2024: PLN91mn;
2023: PLN7mn), financial impact of insurance transaction (total after-tax income of PLN528mn in 2023) and FX mortgage loan
related costs/incomes (in legal risk provisions, FX position, operating cost and other operating income/cost including
indemnity from Societe Generale as well as tax effects) and hypothetical banking tax until the end of May 2024; ROE: Equity
adjusted by all FX mortgage related costs incurred since 2020; (***) Without extraordinary income or cost
Some of strategic targets initially set for 2024 had been already achieved in 2023, but it did not stop
the solid momentum in 2024 and either the most of the remaining KPIs were met as planned or YE24
target were exceeded further (see further pages for details on progress of the implementation of
2022-2024 strategy). Of the latter, key to highlight are the number of active customers retail clients
which remained in a steady uptrend and reached 3.148 million (up 5% y/y) at YE24, further exceeding
the initial target of 3 million, and the share of digitally active customers which increased further to
92% above the 90% target.
Key balance sheet indicators
31.12.2024
31.12.2023
y/y
(PLN million)
Loans to households
56 935
56 386
1%
Loans to companies and public sector
18 046
17 257
5%
Total net loans to clients
74 981
73 643
2%
Total assets
139 152
125 520
11%
Deposits of individuals
87 567
76 600
14%
Deposits of companies and public sector
29 690
30 647
-3%
Total deposits
117 257
107 246
9%
Impaired loan ratio *
4.5%
4.6%
-0.1 p.p.
CET1 = T1
14.8%
14.7%
0.1 p.p.
TCR
17.2%
18.1%
-0.8 p.p.
(*) Impaired loan ratio = impaired loans / total gross loans
Stable capital position
Capital position of the Bank/Group was broadly stable and some capital ratios actually improved in
2024. YE24 Group’s T1 capital ratio stood at 14.8%
1
compared to 14.7% at YE23, while Bank’s solo T1
capital ratio stood at 15.3%/15.4% respectively. At YE24 the respective surpluses over the required
minimums stood at 497 bps (Group) and 546 bps (Bank solo). Consolidated TCR stood at 17.2% (YE23:
18.1%), while this of the Bank solo at 18.0% (YE23: 19.0%).
The 9 basis points improvement of the Group’s T1 capital ratio in 2024 was a result of offsetting
impact of positive factors (recognition of 1H24 net profit into regulatory capital and lowering negative
impact of the revaluation reserve) with higher capital use resulting from increasing RWAs. Recognition
of 2H24 net profit in capital ratios (see comment on Management Board’s intention with regard to
2024 net profit distribution in the “Dividend policy” section) would, ceteris paribus, add around 90
basis points to capital ratios further widening the capital surplus. The impact of the securitisation
transaction completed in December 2024 would add 31 bps to consolidated YE24 T1 capital ratio and
35 bps to YE24 consolidated TCR.
1
This ratio does not include the impact of the synthetic loan securitisation completed in December 2024. The Bank is waiting
for confirmation of regulatory non-objection to the use of the transaction in the calculation of risk-weighted assets.
15
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Consolidated T1 ratio evolution in 2024
In December 2024 the regulator decided on non-imposing of P2G buffer, while in January and February
the Bank received decisions from the regulator on revoking P2R buffers (so far 1.47 percentage points
on solo basis and 1.46 percentage points at consolidated basis ). These further widen the capital
surplus over the minimum required levels.
Additionally, the Bank meet its YE24 MREL targets with a significant surplus. At the end of December
2024, BM’s MREL trea stood at 28.1% while MREL tem at 8.7% vs. respective required levels of 20.8%
and 5.9%. Ceteris paribus, the surplus is expected to widen further once updated MREL requirements
will reflect the revoked P2R ratios.
MREL ratios (Dec 31, 2024) P2R buffer (YE levels, TCR, consolidated)
Good momentum in settlements with FX-mortgage borrowers
2024 saw the number of signed settlements with FX-mortgage borrowers accelerating to 4.5 thousand
from 3.7 thousand in 2023. While in 2024 overall, the number of new settlements was below the
number of new cases filed against the Bank, 4Q24 brought a change of the proportion. In 4Q24 nearly
1.3 thousand such settlements were signed, above the number of new cases. Nearly 26,000
settlements have been reached since early 2020 when a more intensive effort started. These
represent over 42% of the number of active FX-mortgage agreements at the start of the effort.
28.1%
20.8%
8.71%
5.91%
0%
5%
10%
15%
20%
25%
30%
35%
MREL trea
actual
MREL trea
req.
MREL tem
actual
MREL tem
req.
+7.3 p.p.
+2.8 p.p.
3.35%
2.79%
1.94%
1.46% 1.46%
0%
0.0%
0.5%
1.0%
1.5%
2.0%
2.5%
3.0%
3.5%
4.0%
YE20 YE21 YE22 YE23 YE24 Current
16
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Settlements signed (#) Settlements to date as % of # of 'Day-1* contracts
(*) D-1 is a quarter preceding the quarter when settlements started to be offered on a large scale
Significant reduction of the size and share of legacy FX-mortgage book
As a result of settlements, final court verdicts and other natural drivers, in 2024 the number of active
FX-mortgage loans decreased by 7,852 to 24,573, following the 5,586 drop in 2003. As a result of
these trends, the pace of BM’s FX-mortgage portfolio’s contraction accelerated and in 4Q24 it
decreased 9% (in CHF terms, gross, w/o impact of allocated legal risk provisions) while the y/y
contraction rate accelerated to 26%. The share of total FX-mortgage book (gross loans less allocated
legal risk provisions) in total Group’s gross loans dropped to 1.8% at the end of December ‘24, while
the share of FX-mortgage loans originated by BM dropped to 1.5%. Without the adjustment for
allocated provisions, the share of FX-mortgage loans dropped below the 10% regulatory threshold
during 2024. As commented earlier, this was acknowledged by the regulator which in January and
February 2025 revoked the P2R buffer.
CHF mortgage portfolio (CHFmn) pre-provision*
(*) Originated by Bank Millennium and without the deduction of allocated legal risk provision
1,362
8,450
7,943
3,670
4,458
0
2,000
4,000
6,000
8,000
10,000
2020 2021 2022 2023 2024
42.1%
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
1 2 3 4 5 6 7 8 9 1011121314151617181920
# of quarters since the start of settlement
effort
4,698
1,878
1,534
1,395
0
500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
4,500
5,000
-26%
-9%
17
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
FX mortgage book as % of total consolidated gross loans
Note: the share of total gross FX-mortgages in loans to non-financial entities not deducting allocated legal risk provisions was
9.6% at the end of December’24
Other key developments in 2024
• in 2024, NII adjusted for credit holidays grew 7% y/y while the reported one was up 5% y/y; the
growth was driven by higher interest earning assets (IEAs), improving profitability of the bond
portfolio and lower cost of deposits; these offset higher costs related to issuance of MREL bonds
(EUR500mn issues in September’23 and September’24);
NII excluding cost of credit holidays (PLNmn)
• NIM remained broadly stable through 2024 with 4Q24 NIM of 4.37% comparing against 4.24% in 4Q23;
full year NIM narrowed to 4.36% from 4.60% in 2023, reflecting interest rate cuts in late 2023 (average
3M WIBOR in 2024 was 5.86% vs. 6.53% in 2023); higher IEAs and changing asset mix had the most
pronounced impact on NIM, offsetting the steadily decreasing cost of deposits;
20.4%
18.3%
12.4%
8.9%
4.1%
1.8%
19.1%
17.0%
11.4%
8.1%
3.6%
1.5%
4Q19 2Q20 4Q20 2Q21 4Q21 2Q22 4Q22 2Q23 4Q23 2Q24 4Q24
Total Excl. f.EB
620
655
669
767
961
1,179
1,271
1,250
1,262
1,336
1,372
1,293
1,354
1,383
1,445
1,460
0
200
400
600
800
1,000
1,200
1,400
1,600
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
18
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Net interest margin (NIM)
• cost inflation was sticky for most of 2024 with reported opex up 13% y/y; legal costs and higher
wages were the main factors behind the y/y growth; headcount remained broadly stable (number
of active employees up 36 in the last twelve months), optimisation of the physical distribution
network continued (own branches down by 11 units or 3% in the last twelve months)
complementing the increasing share of digital services (digital customers: 2.91mn, up 8% y/y,
number of active mobile customers: 2.65mn, up 7% y/y);
Staff and own branches (#)
• loan portfolio was marginally up (net/gross loans were up +1%/+2% at YE24); downward trend in
FX-mortgage portfolio remained the key decisive factor as net/gross loan book w/o FX-mortgages
was up 4% y/y; FX-mortgages continued to shrink fast (on a reported basis down 56% y/y) on a
combination of FX movements, repayments, provisioning (in line with IFRS9 part of legal risk
provisions are booked against gross value of loans under court proceedings), write-downs and
settlements;
• non-FX mortgage portfolio was up 4% y/y with non-mortgage retail loans up 7% y/y; origination
of cash loans (PLN7.0bn in 2024, up 11% y/y) contributed the most; BM’s market share in
origination of cash loans in 2024 stood at 10.8%, close to the 10.5% in 2023; origination
(disbursements) of PLN mortgages increased 22% y/y to PLN5.9bn (market share of 7.0% vs. 8.2%
in 2023);
4.85%
4.24%
4.37%
7.29%
5.77%
5.85%
0.0%
1.0%
2.0%
3.0%
4.0%
5.0%
6.0%
7.0%
8.0%
1Q212Q21 3Q21 4Q211Q222Q22 3Q22 4Q221Q232Q23 3Q23 4Q231Q242Q24 3Q24 4Q24
NIM WIBOR3M
6,450
6,454
6,366
6,245
6,211
6,139
6,219
6,325
6,306
6,241
6,306
6,320
6,3…
6,313
6,338
6,355
453
452
443
440
428
415
409
406
391
387
378
374
373
372
368
363
340
360
380
400
420
440
460
5,000
5,200
5,400
5,600
5,800
6,000
6,200
6,400
6,600
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
Active employees (lhs) BM's branches (rhs)
19
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Mortgages: disbursements and market share in originations
Cash loans: originations and market share
• loan book quality marginally improved in 2024 with total NPL ratio at the end of December 2024
at 4.5% vs. 4.6% at YE23; trends in the retail and corporate segments diverged with retail segment
enjoying significant improvement of the NPL ratio (4.4% from 4.8%), chiefly to much lower NPL
ratio in the non-mortgage part of the portfolio NPL (supported by NPL sales among others) while
the corporate one saw an uptick to 4.7% from 3.8% on a combination of few isolated cases
reclassified to Stage 3 in 3Q24 and generally low growth of the portfolio; NPL coverage ratio
marginally increased to 73% from 72% at YE23; annual cost of risk remained practically unchanged
(40bps in 2024 vs. 39 bps in 2023) reflecting, inter alia, significant contribution from NPL sales
and annual update of parameters in the retail risk model in 4Q24;
• customer deposits were up 9% y/y with retail deposits up 1% q/q (chiefly due to growth in current
accounts as term deposits were down again as a result of tighter price management); the share
of total term deposits was broadly stable at 35%; liquidity of the Bank remained very comfortable
with L/D ratio decreasing to a new all-time low of 64% at YE24;
• AuM of Millennium TFI and third-party funds combined grew at a healthy rate of 16% y/y taking
total AuM to nearly PLN11.1bn.
2,203
2,640
2,249
2,799
1,985
2,219
1,417
933
925
993
1,259
1,665
1,644
1,682
1,430
1,133
14.6%
12.0%
10.4%
13.30%
10.5%
17.0%
10.7%
11.7%
11.9%
8.9%
8.7%
6.7%
6.7%
9.3%
6.7%
5.4%
0.0%
2.0%
4.0%
6.0%
8.0%
10.0%
12.0%
14.0%
16.0%
18.0%
0
500
1,000
1,500
2,000
2,500
3,000
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
Disbursements (PLNmn) Mkt. share (% of originations)
1,274
1,439
1,579
1,301
1,120
1,413
1,522
1,382
1,516
1,644
1,659
1,510
1,489
1,977
1,954
1,592
10.5%
9.7%
10.7%
10.0%
9.4%
10.2%
11.3%
10.8%
11.1%
10.6%
10.40%
9.9%
9.0%
11.5%
10.8%
9.7%
0.0%
2.0%
4.0%
6.0%
8.0%
10.0%
12.0%
14.0%
0
500
1,000
1,500
2,000
2,500
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
Originations (PLNmn) Mkt. share (%)
20
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
FX-mortgage portfolio and related costs remained a significant burden on core business results
Costs related to FX-mortgage portfolio originated by BM (legal risk provisions, costs of settlements
as well as legal and court costs) remained a material drag on the core business of the Group. In 2024
overall, FX-mortgage costs burdening P&L totalled PLN3,219 million before tax (PLN2,558 million after
tax) and were 9% lower than in the previous year. While the cost of new legal risk provisions dropped
30% y/y, other elements – namely settlements and legal and court costs – grew significantly.
FX-mortgage related costs (PLNmn pre-tax)*
(*) Costs impacting P&L in the given period and without costs related to FX-mortgages originated by former Euro Bank
Total cost of provisions against legal risk related to FX-mortgage portfolio (‘FX-mortgage provisions’)
amounted to PLN2,179 million before tax with PLN1,979 (2023: PLN2,828) attributable to FX-
mortgages originated by Bank Millennium. The downtrend in quarterly legal risk charge lasts almost
uninterruptedly since 1Q23. Post-tax cost of FX-mortgage related provisions attributable to portfolio
originated by Bank Millennium totalled PLN 1,554 million in 2024 vs. PLN2,762 million in 2023.
In 2024, provisions for statutory interest accounted for over 40% of the overall legal risk provision cost
while the updated estimations for new court cases for approximately 25%.
223
677
2,086
1,844
2,828
1,979
47
357
484
326
540
25
74
131
269
545
116
155
223
750
2,517
2,459
3,540
3,219
0
500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
2019 2020 2021 2022 2023 2024
Legal risk provisions Amicable settlements Legal costs Other
-30%
+70%
-9%
21
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Quarterly provisions against legal risk of FX-mortgage book (PLNmn)
At the end of December 2024, provisions for the portfolio originated by Bank Millennium were at the
level of PLN7,724 million (an equivalent of 122% of the grossed-up active FX-mortgage book) and at
PLN740 million for the portfolio originated by former Euro Bank. The y/y growth of PLN455 million of
balance of provisions for loans originated by Bank Millennium was much lower than the respective
annual P&L charge of PLN1,979 million. This was mainly due to the much increased use of these
provisions (PLN1,323 million in 2024 overall) and to a lesser extent an outcome of changes of PLNCHF
exchange rate. Allocated provisions, i.e. decreasing gross balance sheet value of the respective loan
books, stood at PLN5,163 million for portfolio originated by Bank Millennium and PLN502 million for
portfolio originated by former Euro Bank.
Provisions against legal risk of FX-mortgage book (BM portfolio, PLNmn)
(*) actual outstanding B/S provisions not equal to the sum of P&L charges
21
54
74
70
48 48
51
26
43
42
71
82
41
57
62
39
512
460
452
662
451
467
447
478
821
715
673
620
507
518
470
483
533
514
526
732
499
515
498
505
864
757
743
702
549
575
533
523
0
100
200
300
400
500
600
700
800
900
1,000
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
f. EB BM
512
460
452
662
451
467
447
478
821
715
673
620
507
518
470
483
1,432
1,869
2,375
3,079
3,572
4,155
4,881
4,986
5,630
6,088
6,980
7,269
7,226
7,534
7,702
7,724
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
Quarterly P&L charge Balance sheet provision*
22
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Outstanding legal risk provision as % outstanding active gross loans
Note: legal risk provisions/active gross FX mortgage book (post IFRS9 adjustments where necessary); excl. f.Euro Bank
portfolio in case of BM
On December 31, 2024, the Bank had 21,854 loan agreements and additionally 2,223 loan agreements
from former Euro Bank under individual ongoing litigations (excluding claims submitted by the Bank
against clients i.e. debt collection cases) concerning indexation clauses of FX mortgage loans
submitted to the court. A relatively small proportion of these (~16.0%) was filed by borrowers who
had repaid their FX-mortgages entirely or converted them into PLN mortgages at the date of
submitting the court case (~21% according to their current status), although they represent a higher
share of recently filed cases.
4Q24 was the first quarter when the number (stock) of outstanding claims against the Bank dropped
q/q, reflecting slowing inflow of new cases, higher number of final verdicts and last but not least
impact of settlements of cases which were already during dispute in court. It is also worth noting that
the quarterly number of new claims against the Bank averaged below 1,500 in 2024, below the 1,700+
in 2023. Moreover, since 3Q23 (quarterly peak with nearly 1,900 claims filed) the number of newly
filed claims has been in a steady decline, similarly to trends observed on the market overall and
among some peer banks. However, more time is required to confirm the trend.
New lawsuits against Bank Millennium* (#)
(*) without claims related to FX-mortgages originated by former Euro Bank
122.0%
98.8%
123.8%
0%
20%
40%
60%
80%
100%
120%
140%
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
BM Peer's average (total FX-book) Peer's average (CHF-book)
1,227
1,646
1,770
1,513
1,571
1,558
1,336
1,292
1,716
1,535
1,869
1,759
1,594
1,630
1,487
1,191
0
200
400
600
800
1,000
1,200
1,400
1,600
1,800
2,000
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
23
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Outstanding individual lawsuits against BM Group (FX-mortgages)
The Bank is highly focused on reduction of its FX-mortgage portfolio and the related risk and therefore
continues to actively offer its customers amicable solutions (i.a. conversions to Polish zloty, pre-
payments, early repayments or collectively ‘settlements’) regarding FX-mortgages on negotiated
terms. The number of all settlements reached 4,458 in 2024, significantly more than in the preceding
year. Nearly 26,000 settlements were reached since early 2020 when a more intensive effort started.
These represent over 42% of the number of active FX-mortgage agreements at the start of the effort.
As a result of these negotiations, final court verdicts and other natural drivers, in 2024 the number
of active FX-mortgage loans decreased by 7,852 to 24,573, following the 5,586 reduction in 2003
overall.
In 2024, costs related to settlements with borrowers who were not in legal dispute with the Bank
(“out-of-court settlements”) totalled PLN540 million pre-tax and were booked in FX-result and in
result on modifications. The cost of the settlements was higher, both in total value and per case, than
in 2023, reflecting, among others, an increasing number of settlements and changes to the terms
offered.
Additionally, 1,567 settlements with borrowers who were in legal dispute with the Bank (“in-court
settlements”) were reached in 2024 (35% of total) compared to 536 (15%) in 2023. Costs of these
settlements were booked against earlier created legal risk provision.
6,258
7,902
9,664
11,070
12,528
13,904
15,044
16,008
17,353
18,441
19,849
20,914
21,725
22,141
22,260
21,854
558
672
786
913
1,010
1,103
1,178
1,272
1,404
1,482
1,635
1,780
1,917
2,070
2,172
2,223
0
5,000
10,000
15,000
20,000
25,000
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
BM f.EB
24
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
New settlements signed (in- and out-of-court)(#)
Costs of out-of-court settlements (PLNmn, pre-tax)
Note: some items might have been adjusted from the previously reported values
Legal and court costs, booked in admin costs and other operating costs, were significantly higher in
2024 totalling PLN545 million vs. PLN269 million in 2023.
More information about the risk related to the FX mortgage portfolio is presented further down in this
report and in Annual Consolidated Financial Report of the Bank Millennium S.A. Capital Group for the
12-month period ending 31st December 2024.
Substantial and extraordinary P&L items in 2024
In 1Q24, the BM Group recognised annual cost of BFG resolution fund fee in the amount of PLN61
million.
In 2Q24, results (interest income line) were impacted by PLN201mn estimated costs of credit holidays
for PLN mortgage borrowers. The amount was at the lower end of the preliminary estimated range of
PLN201–PLN247 million (details in current report no 17/2024 of May 5, 2024), indicating a relatively
911
2,283
2,641
2,615
2,281
2,176
2,174
1,312
805
925
869
1,071
1,104
1,009
1,084
1,261
0
500
1 000
1 500
2 000
2 500
3 000
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
17
55
146
140
124
110
143
108
72
78
87
89
118
124
122
176
0
20
40
60
80
100
120
140
160
180
200
1Q21 2Q21 3Q21 4Q21 1Q22 2Q22 3Q22 4Q22 1Q23 2Q23 3Q23 4Q23 1Q24 2Q24 3Q24 4Q24
25
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
low borrowers’ interest in the scheme. Indeed, this was reflected in both 3Q24 and 4Q24 when
respectively PLN44 million and PLN45 million of the estimated cost was reversed. The final pre-tax
cost for the full year 2024 settled at PLN113 million.
1H24 tax line brought a positive value owing to number of items, including a recognition of DTA
totalling PLN223 million (1Q24: PLN52 million, 2Q24: PLN171 million) as well as 2022-23 CIT refunds
and reductions of current CIT liabilities. The DTA was, among others, related to future adjustments
of interest income earned on mortgage loans indexed to CHF and FX differences on these loans which
are the subject of court disputes for their cancellation. 3Q24 brought practically no change in the
amount of the earlier created DTA, while 4Q24 brought a PLN35 million decrease.
Results of BM Group are occasionally impacted by sale of NPLs. These are a part of ordinary conduct
of the business and management of the NPL portfolio and in recent years typically took place in 2Q
and 4Q. While 2Q24 saw PLN45 million pre-tax profit on the transaction (presented in credit risk line),
4Q24 brought a relatively higher than usual PLN74 million result on the NPL sale.
Legal and court costs related to FX-mortgage portfolio continued to burden BM Group’s through the
entire year 2024, but 4Q24 saw a cumulation of these costs (PLN166 million or 30% of full year
amount), as described in more details above in this report.
Lastly, the Bank returned to paying banking tax in 2Q24 (PLN35 million charge in June), and 3Q24 as
well as 4Q24 saw full quarterly charges of PLN99 million each in contrast to no charge in respective
quarters of the preceding year and full 2023.
26
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
3. INFORMATION FOR INVESTORS
3.1. SHARE PRICE PERFORMANCE
2024 proved to be volatile for the stock markets. The year started on a negative note, with market
sentiment weighed down by profit-taking after the strong rally in late 2023. However, the market
found its footing and rallied significantly, driven by optimistic projections of interest rate cuts by
major central banks and strong performance of banking sector stocks. In the middle of the year, the
global financial landscape faced turbulence due to Japan's unexpected interest rate hike. The
resulting a sharp appreciation of the yen and a subsequent unwinding of yen carry trades also had a
spillover effect on global equities, including Polish indices. In the latter part of the year, geopolitical
tensions, notably the ongoing conflict in Ukraine, outcomes of elections and other events continued
to influence market dynamics.
During the 12 months ending 31 December 2024, WIG broad market index grew slightly 1%, WIG20
index of largest companies fell 6%, while WIG Banks outperformed the market, gaining 12%. In the
same period, share price of Bank Millennium grew 7%.
Annual change of Bank Millennium share price vs. WIG Banks index
In 2024, the average daily trading volume of Bank Millennium shares amounted to PLN7.7 million,
which was 6% higher compared to the previous year.
Market ratios
30.12.2024*
29.12.2023*
Change y/y
Number of Bank’s shares (‘000)
1 213 117
1 213 117
0.00%
Average daily turnover in annual terms
(in PLN’000)
7 725
7 273
6.2%
Bank’s share price (PLN)*
8.90
8.35
6.5%
Market capitalisation of the Bank (PLNmn)
10 797
10 136
6.5%
WIG Banki
12 346
11 062
11.6%
WIG20
2 192
2 343
-6.4%
WIG - main index
79 577
78 460
1.4%
(*) last day of listing in 2024 and 2023
Bank Millennium’s shares are included, among others, in following indices on the Warsaw Stock
Exchange: WIG, WIG Banks, mWIG 40 and WIG Poland.
+7%
+12%
-10%
-5%
0%
5%
10%
15%
20%
25%
30%
29-Dec 29-Jan 29-Feb 31-Mar 30-Apr 31-May 30-Jun 31-Jul 31-Aug 30-Sep 31-Oct 30-Nov
MIL WIG-Banks
27
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
3.2. BANK MILLENNIUM’S RATINGS
Ratings of Bank Millennium
On April 26, 2024 Moody’s rating agency confirmed Bank’s long- and short-term deposit ratings at
Baa3/P-3 and changed the outlook on the long-term deposit ratings to positive from negative.
Additionally, Moody’s affirmed Bank’s BCA at ba3, Adjusted BCA at ba2, its (P)Ba2 rating for junior
senior unsecured MTN program and Ba2 rating for junior senior unsecured bonds of the Bank.
On June 28, 2024, Fitch Ratings upgraded the Bank’s Long-Term Foreign-Currency Issuer Default
Rating (LT IDR) and Long -Term Local Currency IDR (LC LT IDR) to 'BB+' and maintained outlooks for
these rating at ‘Positive’. Additionally, Fitch upgraded to ‘bb+’ the Viability Rating (VR) for the Bank
and upgraded to ‘BB+’ rating for the senior non-preferred bonds issued by the Bank.
According to Fitch ‘The upgrade reflects strong improvement in the bank's capital position resulting
in the completion of its recovery plan and our (Fitch) expectation that risks related to its legacy
foreign-currency (FC) mortgage loans will gradually abate. It also reflects our (Fitch) expectations
that the bank's improved core profitability will cushion the remaining impact of legal costs and credit
holidays, leading to a further recovery of the bank's capitalisation. The Positive Outlook reflects
Fitch's view that the ratings could be upgraded if continued reduction of risks related to FC mortgage
loans translates into a stronger business profile as underlined by steadily improving operating
profitability and a record of adequate capital buffers.’
At the date of publishing this Report, the Bank’s corporate ratings, were as follows:
Rating
MOODY’S
Long-term deposit
Baa3
Short-term deposit
Prime-3
Baseline Credit Assessment (BCA)/Adj. BCA
ba3/ba2
LT Counterparty Risk Assessment (CRA)/ST CRA
Baa2(cr)/Prime-2(cr)
Rating outlook
Positive
SNP MREL bonds
Ba2
Rating
FITCH
Long-term deposit Issuer Default (IDR)
BB+
National Long-term
A-(pol)
Short-term Issuer Default Rating (IDR)
B
Viability (VR)
bb+
Shareholder Support Rating (SSR)
b+
Rating Outlook
Positive
SNP MREL bonds
BB+
28
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
3.3. INVESTOR RELATIONS
Communicating with the investors’ community the Bank assures a high level of transparency and
proper access to information for all its recipients. Accurate and up-to-date information is provided in
keeping with relevant legal regulations. The list of information published by the Bank, defining the
frequency and place of publication, is available on the Bank’s website in the Investor Relations section
– in section of Information Policy Information policy of Bank Millennium - Bank Millennium
The investor relations website Investor relations - About the Bank - Bank Millennium always provides
up-to-date information, including Bank Millennium share prices on the WSE, shareholding structure,
details of General Meetings, dividend payment history or credit ratings. There are also current and
periodic reports, financial results presentations, Excel sheets 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.
The Bank makes use of diverse communication channels to reach current and potential Shareholders,
primarily such channels as:
▪ Periodic conferences with the Management Board about quarterly results of the Bank’s Capital
Group (four during 2023),
▪ Participation in conferences organised for Investors in Poland and abroad (8),
▪ One-on-one and group meetings with capital market participants (407 participants),
▪ Current reports (33) and press releases,
▪ Dedicated website in the Bank’s portal on investor relations,
▪ Encouraging participation in annual General Meetings of the Bank,
▪ Day-to-day contacts with market participants (via e-mail, phone or internet communicators).
In keeping with best practice on equal access to information from 2006 the Bank has been assuring
unrestricted access to results conferences online with the Management Board (video streaming in
Polish and in English) and by phone. A recording of each conference is available on the Bank’s website.
The Bank also provides video streaming of General Meetings. A recording of the deliberations and the
resolutions adopted are also available on the website.
Bank Millennium is covered by 11 analysts representing local and international brokerage houses who
publish their reports and recommendations for Bank Millennium shares. The full list can be found on
the Bank's website Analysts - Investor relations - Bank Millennium
As at 31 December 2024, the structure of recommendations (not older than 6 months) was as follows:
Buy
Hold
Sell
4
1
0
3.4. DIVIDEND POLICY
Bank Millennium’s dividend policy assumes distribution of between 35% to 50% of its net profit,
provided that recommendations of the PFSA regarding the payment of dividends are met.
Bank Millennium Bank posted a net profit in 2024. The Management Board of the Bank intends,
following the necessary corporate approvals, to recommend shareholders at 2025 AGM a retention in
own funds of the Bank 100% of the net profit made in 2024.
29
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
4. MARKET CONDITIONS AND MACRO RISK FACTORS
4.1. MACROECONOMIC ENVIRONMENT
The year 2024 was a time of stable global GDP growth, albeit slower than before the pandemic,
weaker inflationary pressure and the beginning of monetary policy easing. However, the situation
varied across economies. The eurozone's GDP grew by only about 0.7% after growing by 0.4% a year
earlier. Germany, which was in recession for the second year in a row, contributed to the weakness.
The United States turned out to be a positive surprise, where GDP grew by 2.8% vs. 2.9% in 2023, i.e.
faster than the long-term average. Global inflation continued its downward trend in 2024, which,
together with less tight labour market in many economies, opened the door to interest rate cuts. The
external environment, especially low demand from the eurozone, Poland's most important trading
partner, did not help the growth of the Polish economy in 2024.
Poland: GDP and its forecasts (% y/y)
Macrobond, Bank Millennium, E - estimate, F - forecast
According to the International Monetary Fund's forecasts, the growth of the global economy in 2025
is expected to be stable, although trends, as in 2024, are likely to remain mixed. The IMF expects
growth to accelerate to 1.3% in the eurozone and to 0.8% in Germany. The rebound in activity in the
eurozone is expected to be accompanied by growth in the US of 2.2%, which is only slightly slower
than the long-term average. Weaker growth is also expected for China: 4.5% vs. 5.0% in 2024, although
plans of the Chinese government to loosen fiscal and monetary policy may allow the for growth rate
of 2024 to be sustained. Year 2025 should be a period of further declines in interest rates in many
economies, albeit at different scales and pace. The higher tariffs on imported goods implemented by
the U.S. administration significantly increase uncertainty about the situation in the global economy
in 2025.
Preliminary data indicate that GDP in Poland grew by 2.9% in 2024 after growing by 0.1% in 2023,
which turned out to be in line with the Bank's expectations from the year before. The main driver of
growth was household consumption, which increased by 3.1% after a decline of 0.3% a year earlier. It
was supported by a very good situation on the labour market. The registered unemployment rate
stood at 5.1% at the end of the year, the same as at the end of 2023, and wage growth accelerated
to ca. 13.5% y/y from 13.1% y/y, helped by a strong increase in the minimum wage. Rising wages and
increased social transfers (i.a. the 800 plus programme) significantly improved the income situation
of households, although consumption growth in 2024 turned out to be weaker than expected. Positive
real interest rates and uncertainty related to inflation and the economic environment have increased
the savings rate. Investments in fixed assets only slightly supported the economy, growing by 1.3%
y/y after an increase of 12.6% y/y a year earlier. Their strong slowdown is due to the initial phase of
absorption of European Union funds under the cohesion policy and the National Recovery Plan, as well
1.0
2.1
3.2
2.7
3.2
0.1
2.9
3.7
4Q23 2Q24 4Q24E 2023 2024 2025F
30
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
as due to high interest rates. On the other hand, the net exports had a negative impact on the GDP
growth, which resulted from weak foreign demand.
The global disinflation trend in 2024 has not bypassed Poland. The average annual CPI inflation
dropped to 3.6% y/y from 11.4% y/y a year earlier, and during the year it was temporarily within the
range of acceptable deviations from the inflation target. This was supported by fading of shocks in
food and energy prices. Core inflation also decreased - to 4.3% y/y (on average in a year) from 10.1%
y/y a year earlier. Inflation in the prices of services turned out to be more persistent, as it slowed
down only to 6.6% y/y from 11.4% y/y a year ago. High inflation in the services’ prices is mainly
related to strong demand that allows rising labour costs to be passed onto consumers. In such
conditions, the Monetary Policy Council kept interest rates unchanged. The base interest rate stood
at 5.75% throughout 2024.
CPI and its forecasts (% y/y, period average)
Source: Macrobond, Bank Millennium, F - forecast
High interest rates were conducive to the recovery of savings after the period of the highest inflation
in years. The total value of deposits in the banking sector increased by PLN170bn in 2024, of which
PLN121bn was an increase in household deposits. Deposits of non-financial corporations went up by
PLN20bn, i.e. weaker than a year ago, which can be attributed to more difficult conditions in some
sectors for protecting margins by companies. At the same time, deposits of local governments
increased by PLN33bn. In 2024 credit creation in the banking sector increased. The total value of
newly granted loans in 2024 was 15.5% higher than a year earlier. This was mainly due loans to
households – for consumption purposes and for housing. In particular, the largest credit creation was
recorded in 4Q24.
In the Bank's opinion, economic growth in 2025 will be faster than in 2024, although this outlook is
subject to higher than usual uncertainty. According to the Bank, GDP will grow by 3.7%, and the main
driver of the economy will continue to be household spending supported by strong wage growth.
However, it will probably not be as quick as in 2024, partly due to the smaller scale of the minimum
wage increase (by 8.5% after an increase of 20% a year earlier). In addition, the expected cuts in NBP
interest rates, in the conditions of still low unemployment, would be conducive to reducing the
propensity of consumers to save. In 2025, investment demand should join the growth drivers, along
with the implementation of projects co-financed from EU funds. On the other hand, a weak recovery
in the eurozone, as in 2024, is likely to limit the potential for domestic GDP growth.
According to the Bank's basic macroeconomic scenario, the average annual CPI inflation will increase
to 4.7% y/y in 2025 from 3.6% y/y in 2024, due to the gradual phasing out of protective measures
related to electricity prices for households. From Jul’25, the fixed capacity fee on electricity bills
will be reinstated. Additionally, from Oct’25, electricity prices will probably be unfrozen. In the case
of core inflation, the Bank assumes a slight decrease to 4.0% y/y from 4.3% y/y a year earlier, mainly
due to forecasts of slightly lower cost pressure resulting from the labour market. According to the
6.4
2.8
2.5
4.5
4.8
11.4
3.6
4.7
4Q23 2Q24 4Q24 2023 2024 2025F
31
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Bank, still high inflation, improved domestic demand and uncertainty about energy prices as well as
still expansionary fiscal policy support expectations of stable interest rates in the first months of
2025. However, the entry of inflation into a downward trend along with slower wage growth and
further reductions in interest rates of the European Central Bank and a strong zloty, should open up
in the second half of the year a room for interest rate cuts. According to the Bank, that space will be
only limited amounting to 100 bp, which is in line with the valuation of interest rates by financial
markets. 2025 will be another year with high uncertainty related to economic factors (inflation,
exchange rates, commodity prices, interest rates), but also geopolitical ones, such as tariffs, fiscal
and migration policy in the world, armed conflicts, or stability and the rule of law in some economies.
4.2. FACTORS OF UNCERTAINTY FOR THE ECONOMY AND BANK
MILLENNIUM GROUP
Factors of uncertainty for the economy and the Bank Millennium Group
The summary list below presents the most important negative risk factors, in the Bank’s opinion, for
the Bank Millennium Group, regarding the macroeconomic and international situation in 2025.
• Global political situation. It includes the possibility of intensification of hostilities between
Russia and Ukraine, escalating tensions in the Middle East and Asia, but also the impact of
elections in some economies. A worsening geopolitical situation would potentially result in
increased uncertainty and risk aversion, as well as a possible increase in public and private
debt. One of the key risk factors is also the trade policy of the world's largest economies.
Significantly stronger protectionism could lead to disruptions in production and supply chains
and, consequently, to an increase in the prices of in the world, including agricultural and
energy raw materials. This would translate into increased uncertainty, higher than forecast
interest rates and potential correction in asset valuations on financial markets. As a result of
increased risk aversion and supply shocks, the zloty would weaken, inflation in Poland as well
as debt service costs would rise. This would limit economic activity and demand for labour,
increasing the credit risk and weakening demand for Bank’s offer.
• Worse-than-expected economic situation in Poland's trading partners, in particular in the
eurozone. This would have a negative impact on the financial performance of Polish
companies, potentially resulting in a decrease in demand for labour and an increase in
unemployment. The possibility of a weaker standing of exporters is also associated with the
risk of a faster-than-expected easing of the monetary policy in the world, increasing the
disparity in interest rates between foreign countries and Poland. This could exert strong
pressure on the appreciation of the zloty and thus worsen the profitability of companies.
• Increased political and institutional risks in Poland, which could result in disruptions to
government economic policy, including slower implementation of programmes co-financed by
EU funds. This could cause deterioration of the fiscal situation and ratings, an increase in risk
premiums, a weakening of the zloty, a repricing of government bonds and increased volatility
in financial markets.
There is also a possibility of better economic results in Poland than in the Bank's baseline scenario,
which could result, among others, from abatement of military operations in Ukraine, decreased risk
associated with protectionism in world trade, improved economic sentiment and reduced saving
propensity, as well as faster absorption of EU funds. The economic recovery would also be supported
by political stability of the most important trading partners and a stronger than expected economic
recovery abroad.
32
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
5. OTHER IMPORTANT CONSIDERATIONS
5.1. RECOVERY PLAN AND CAPITAL PROTECTION PLAN
In July 2022, due to costs stemming from the 2022-23 credit holiday scheme for PLN borrowers and
resultant negative implications for capital ratios, the Bank launched Recovery Plan and Capital
Protection Plan (details in current report of July 15, 2022 Information on expected negative impact
of credit holidays on 3rd quarter 2022 results of Bank Millennium S.A. Capital Group and on launching
of the Recovery Plan and in subsequent periodical financial reports issued).
Following the completion of implementation of the Capital Protection Plan in May 2024, on June 19,
2024 the Management Board of the Bank took a decision to complete the implementation of the
Recovery Plan, notifying of the fact Polish Financial Supervision Authority and Bank Guarantee Fund
(details in: Information on completion of implementation of the Recovery Plan).
In the Bank’s Management Board’s opinion, all key assumptions of the Recovery Plan have been
achieved. In particular, all indicators defined in the Plan have reached safe levels, profitability and
financial results of Bank Millennium S.A. Capital Group improved sustainably, capital ratios were
restored to levels well above required regulatory minimums while the Bank and the Group meet MREL
requirements, including the combined buffer requirements. The Bank’s Management Board also does
not identify future circumstances that would justify further continuation of the Recovery Plan.
5.2. CREDIT HOLIDAYS
The Act of April 12, 2024 amending the Act on support for borrowers who have taken out a mortgage
loan and are in a difficult financial situation and the Act on crowdfunding for business ventures and
assistance to borrowers (the "Act") extended credit holidays for PLN mortgage borrowers originally
introduced in 2022.
The terms were altered compared to the original scheme and under the updated conditions a borrower
could defer four monthly payments until the end of 2024 for one loan not exceeding PLN1.2mn and
provided its Instalment to Income Ratio (IIR) for the period of the last three months preceding the
Application submission date exceeded 30% or on the day of submitting the Application, a borrower
had at least 3 dependent children. Two instalments could be deferred during the 1 June 2024 to 31
August 2024 period and two during the 1 September 2024 to 31 December 2024 period.
A borrower could specify all deferral periods in one application or submit separate applications for
each deferral period.
The Bank initially assumed circa 26% participation of total PLN mortgage client base (i.e. loans granted
before July 1, 2022, and loans below PLN1.2 million) which translated into PLN201 million cost
provision booked in 2Q24, a lower end of the preliminary estimation communicated to the market on
May 7, 2024. As a result of lower than assumed eligible borrowers’ participation in the scheme,
following positive adjustments of the above mentioned cost in 3Q24 and 4Q24, final cost of the 2024
credit holidays scheme settled at PLN113 million before tax (PLN91 million after tax).
5.3. FX-MORTGAGE LEGAL RISK
On December 31, 2024, the Bank had 21,854 loan agreements and additionally 2,223 loan agreements
from former Euro Bank under individual ongoing litigations (excluding claims submitted by the Bank
against clients i.e. debt collection cases) concerning indexation clauses of FX mortgage loans
submitted to the courts (52% loans agreements before the courts of first instance and 48% loans
agreements before the courts of second instance) with the total value of claims filed by the plaintiffs
amounting to PLN 4,576.0 million and CHF 331.1 million (Bank Millennium portfolio: PLN 4,111.2
million and CHF 320.1 million and former Euro Bank portfolio: PLN 464.7 million and CHF 11.0 million).
The original value of the portfolio of CHF agreements granted (the sum of tranches paid to customers),
33
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
taking into account the exchange rate as at the date of disbursement of loan tranches, amounted to
PLN 19.4 billion for 109.0 thousand loan agreements (Bank Millennium portfolio: PLN 18.3 billion for
103.8 and former Euro Bank portfolio: PLN 1.1 billion for 5.2 thousand loan agreements). Out of 21,854
BM loan agreements in ongoing individual cases 431 are also part of class action. From the total
number of individual litigations against the Bank approximately 3,600 or 16% were submitted by
borrowers that had already naturally or early fully repaid the loan or were converted to polish zloty
at the moment of submission and had not a settlement agreement. Approximately another 880 cases
correspond to loans that were fully repaid during the proceedings (as court proceedings are lengthy).
The claims formulated by the clients in individual proceedings primarily concern the declaration of
invalidity of the contract and payment for reimbursement of paid principal and interest instalments
as undue performance, due to the abusive nature of indexation clauses, or maintenance of the
agreement in PLN with interest rate indexed to CHF Libor.
In addition, the Bank is a party to the group proceedings (class action) subject matter of which is to
determine the Bank's liability towards the group members based on unjust enrichment (undue benefit)
ground in connection with the foreign currency mortgage loans concluded. It is not a payment dispute.
The judgment in these proceedings will not directly grant any amounts to the group members. The
number of credit agreements covered by these proceedings is 3,273. Out of 3,273 loan agreements in
class action 431 are also part of ongoing individual cases, 1,563 concluded settlements and 29 received
final verdicts (invalidation of loan agreement). On 24 May 2022 the court issued a judgment on the
merits, dismissing the claim in full. On 13 December 2022 the claimant filed an appeal against the
judgment of 24 May 2022. On 25 June 2024 an appeal hearing was held, at which the Bank filed a
motion to amend the composition of the group and exclude those group members who had entered
into an amicable settlement. The court required the plaintiffs' attorneys to take a written position on
the current composition of the group. The date of the hearing will be set by the court ex officio.
The intense advertising campaign observed in the public domain affects the number of court disputes.
Until the end of 2019, 1,984 individual claims were filed against the Bank (in addition, 236 against
former Euro Bank), in 2020 the number increased by 3,005 (265), in 2021 the number increased by
6,157 (423), in 2022 the number increased by 5,758 (408), in 2023 the number increased by 6,879
(646), while in 2024 the number increased by 5,902 (672).
Based on ZBP (the Polish Banking Association) data gathered from all banks having FX mortgage loans,
vast majority of disputes were finally resolved against the banks. As far as Bank Millennium (incl.
former Euro Bank portfolio) is concerned, from 2015 until the end of 2024, 8,557 cases were finally
resolved (8,450 in claims submitted by clients against the Bank and 107 in claims submitted by the
Bank against clients i.e. debt collection cases) out of which 2,561 were settlements, 88 were
remissions, 75 rulings were favourable for the Bank and 5,833 were unfavourable including both
invalidation of loan agreements as well as conversions into PLN+LIBOR. The Bank undertakes proper
legal actions in order to secure repayment of initially disbursed capital of the loan.
The outstanding gross balance of the loan agreements under individual court cases and class action
against the Bank (incl. former Euro Bank portfolio) on 31 December 2024 was CHF 1,189 million (of
which the outstanding amount of the loan agreements under the class action proceeding was CHF 86
million).
If all Bank Millennium’s originated loan agreements currently under individual and class action court
proceedings would be declared invalid without any compensation for the use of capital, the pre-tax
cost could reach PLN 7,087 million. Overall losses would be higher or lower depending on the final
court jurisprudence in this regard and the consideration of additional costs in the court verdicts.
In the 12 months of 2024, the Bank created PLN 1 979,2 million of provisions for Bank Millennium
originated portfolio and PLN 199,9 million for the former Euro Bank originated portfolio. The balance
34
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
sheet value of provisions for the Bank Millennium portfolio at the end of December 2024 was PLN 7
724,1 million, and for the former Euro Bank portfolio - PLN 739,6 million.
The methodology developed by the Bank of calculating provisions for legal risk involved with indexed
loans is based on the following main parameters resulting from historical observations or expert
assumptions:
(i) the number of ongoing cases (including class action agreements) and potential future lawsuits;
(ii) As regards the number of future court cases, the Bank monitors customer behaviors, analyzes
their willingness to sue the Bank, including due to economic factors and applies the following
assumptions:
a. regarding active loans (i.e., loans with an outstanding balance), the Bank estimates
the percentage of customers covered by methodology in this group of clients at 88%
of the total number of active loans (including expected number of amicable
settlements).
b. regarding loans already fully repaid or converted to polish zloty, the Bank attributes
a much lower probability of becoming the subject of a court case (the Bank assumes
that approximately 24% of the repaid loans that had an economic justification for
suing the Bank but were not covered by a prior settlement have sued or will decide
to sue the Bank in the future);
(iii) the amount of the Bank's potential loss in the event of a specific court judgment (including
statutory interest estimation);
(iv) the probability of obtaining a specific court judgement calculated on the basis of statistics of
judgments in cases where the Bank is a party;
(v) estimates involved with amicable settlements with clients, concluded in court or out of court:
a. the bank assumes a 12% probability of success in concluding a settlement as part of
negotiations conducted with clients in the course of court proceedings,
b. negotiations are conducted on a case-by-case basis and can be stopped at any time by
the Bank,
c. due to significant negotiation efforts already made in the past, the probability of success
in these negotiations in the future is decreasing, and at the same time most customers
have already contacted the Bank regarding the possible conversion of loans into PLN, so
at the moment the Bank adopts a conservative approach when taking into account the
potential impact of this factor.
The Bank is open to negotiate case by case favorable conditions for early repayment or conversion of
loans to PLN. As a result of these negotiations, the number of active FX mortgage loans originated by
Bank Millennium decreased by 25,883. As of the end of 2024, the Bank had 24,573 active FX mortgage
loans. Cost incurred in conjunctions with these negotiations totaled PLN 2 217,0 million. This cost is
presented mainly in ‘Result on exchange differences’ and also in ‘Result on modification’ in the profit
and loss statement (the values of costs charged to particular items of the Income Statement due to
settlements are presented in Note 14 in Chapter 14 ‘Notes to Consolidated Financial Data’ of the
Annual Consolidated Financial Report of the Bank Millennium S.A. Capital Group for the 12-month
period ending 31st December 2024).
Taking into consideration the above-mentioned information regarding court cases (active and already
closed after verdicts), realized settlements and assumptions regarding future number of court cases
and settlements, as well as the historical number and original amount of loans granted, it can be said
that the already materialized risk (reflected in the provisions and in the losses already booked through
the P&L) accounts for 60% of the historical number of loans granted and for 73% of the original
disbursed capital.
35
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Legal risk from former Euro Bank portfolio is fully covered by Indemnity Agreement with Société
Générale S.A.
The bank analyzed the sensitivity of the amount of the provision to changes in specific methodology
parameters:
Parameter
Scenario
Impact on loss
Change in the number of court
cases adopted in the assumptions
In addition, 1,000 new customers file a
lawsuit against the Bank
PLN 188 million
Change in costs incurred in
connection with the judgment or
settlement
Change in cost levels by 1% compared to
the assumed
PLN 77 million
On December 8, 2020, Mr. Jacek Jastrzębski, the Chairman of the Polish Financial Supervision
Authority (“PFSA”) proposed a “sector” solution to address the sector risks related to FX mortgages.
The solution would consist in offering banks’ clients a voluntary possibility of concluding arrangements
based on which a client would settle a CHF Mortgage Loan as if it was a PLN loan bearing interest at
an appropriate WIBOR rate increased by the margin historically employed for such loans. The decision
to generally implement this solution could imply the need of creating upfront provisions for the losses
resulting from the conversion of CHF Mortgage Loans. The Bank in practice has been using elements
of the proposal of above system solution on many individual negotiations with FX mortgage borrowers,
including in the course of court proceedings.
Due to the circumstances stemming from the CJEU which excludes demanding by the Bank amounts
exceeding the return of disbursed capital, the possibility of successful implementation of a general
offer of KNF solution is low.
It can reasonably be assumed that the legal issues relating to foreign currency mortgage loans will be
further examined by the domestic courts and the European Court of Justice which could potentially
result in the further interpretations, that are relevant for the assessing of the risks associated with
proceedings.
The issues related to the statute of limitations for the Bank's and the customer's restitutionary claims
following the invalidation of a loan agreement remain an area that may be subject to further analysis
in the jurisprudence of Polish courts. Legal interpretations in this subject may have an impact for
the amount of provisions in the future.
There is a need for constant analysis of these matters. The Bank will have to regularly review and
may need to continue to create additional provisions for FX mortgage legal risk, taking into
consideration not only the above mentioned developments, but also the negative verdicts in the courts
regarding FX mortgage loans and important parameters, such as the number of new customer claims,
including those relating to repaid loan agreements.
The assumptions for the draft act on special solutions for the examination of cases related to loan
agreements denominated in or indexed to the Swiss franc concluded with consumers have been
published on the website of the Chancellery of the Prime Minister (link: Draft act on special solutions
for the examination of cases concerning loan agreements denominated or indexed to the Swiss franc
concluded with consumers - Chancellery of the President of the Republic of Poland) of the Council of
Ministers - Portal Gov.pl).
According to the information provided, Q2 2025 was indicated as the planned date of adoption of the
draft by the Council of Ministers. Pursuant to the legislative procedure, after its adoption, the draft
should be referred to the Polish Parliament, and then, if it is passed, it should be sent to the President
for his signature and then published in the Journal of Laws.
The adoption of the act in the form implementing the announced assumptions may significantly
accelerate the case adjudication time for cases regarding the validity of housing loan agreements
indexed to CHF.
36
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
More details on this risk are available in Annual Consolidated Financial Report of the Bank Millennium
S.A. Capital Group for the 12-month period ending 31st December 2024.
More details on other risk factors are available in the risk section of this report and in the Annual
Consolidated Financial Report of the Bank Millennium S.A. Capital Group for the 12-month period
ending 31st December 2024.
37
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
6. POLISH BANKING SECTOR AND BM/BM GROUP’S POSITION
6.1. POLISH BANKING SECTOR IN 2024
Following a relatively calm, yet economically challenging 2023, the year 2024 proved to be
significantly more prosperous for Polish banks. A combination of economic recovery, stable interest
rates, and contained credit risk, along with relatively low regulatory costs and limited government
interference, translated into markedly improved profitability within the banking sector. According to
data from the National Bank of Poland, the net result of the sector totalled PLN 42 billion, an increase
of 52% year-over-year.
Similar to 2023, net interest income (NII) was the primary driver behind the robust results. Although
the year-over-year growth of NII slowed to 12% from 32% in the preceding year, it generated a
substantial increase in core income and total income, resulting in a 22% year-over-year growth of
total income. The growth of NII was due to a combination of stable and relatively high interest rates,
alongside an 11% year-over-year growth in the balance sheet, mainly driven by continued abundant
liquidity. The loan-to-deposit ratio dropped to a new record low of 67% at the end of the year,
compared to 70% at the end of the previous year, due to a 10% growth in deposits and a 5% growth in
loans. In 2024, the net interest margin (NIM) increased year-over-year to 3.8% from 3.7% in 2023.
Although the share of NII in total income remained high at 81%, it was lower than the 88% recorded
in 2023. Net fees grew by 5% year-over-year following a 1% growth in 2023, while their share in total
income stood at 15% compared to 17% in 2023.
At the same time, underlying cost growth remained elevated due to high inflation and wage pressure.
However, once adjusted for charges related to the Bank Guarantee Fund, the cost growth began to
slow compared to the dynamics observed in 2023. Reported costs increased by 11%, with HR costs up
by 12% after a 22% growth in 2023. The reported cost-to-income ratio improved to 43% from 47% in
the previous year.
Positive operating jaws (total income up 22% year-over-year versus operating expenses growth of 11%)
resulted in an operating surplus, or effectively pre-provision profit, amounting to PLN 74 billion
compared to PLN 56 billion in 2023.
The digitalization of the sector, which was accelerated by the pandemic, continued. This was
manifested among other things by continued branch closures and staff reductions. At the end of
November 2024 (the latest available data point), the number of banking branches was 2% lower than
at the end of 2023 (a 3% reduction in 2023 overall), while the number of branch staff was down by 3%
(down by 4% in 2023). The number of employees at headquarters increased by 3% in the same period
following a 5% growth in 2023.
Credit risk charges were down by 31% year-over-year in nominal terms. In 2024 overall, they were
equivalent to 7% of operating profit compared to nearly 14% in the previous year. At the end of
November 2024, the share of stage 3 loans decreased marginally to 5.2% from 5.4% at the end of 2023,
while the coverage ratio of this portfolio decreased to 57% from 62% respectively. The large
companies’ portfolio bucked the trend with the NPL (non-performing loan) ratio increasing to 7.4%
from 3.5% at the end of 2023, and the coverage ratio dropping to 39% from 56%.
The sector’s return on equity (ROE) for the 12 months to November 2024 stood at 15.3% compared to
12.3% in 2023. The return on assets (ROA) averaged 1.3% compared to less than 1% in 2023.
Banking balance sheets grew by 11%, a similar pace to that in 2023 (10%) and the inflow of deposits
remained the key driver. The latter grew by 6% year-over-year (deposits of the non-financial sector),
while the gap between the growth of corporate deposits (flat year-over-year) and retail ones (8%)
widened significantly. The over-liquidity of the sector increased further, as evidenced by a further
drop in the loan-to-deposit ratio to 67% from 70% at the end of 2023, or an increase in the Net Stable
Funding Ratio (NSFR) to 167% (end of September 2024 data) from 162% at the end of 2023. The trend
of change in deposit mix continued, with the share of term deposits increasing to 33% of total deposits
from 32% at the end of 2023.
38
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The Polish banking sector maintained a very strong capital position, with most metrics remaining flat
year-over-year despite generous dividend payouts in 2024. At the end of September 2024, the
regulatory capital of Polish commercial banks reached PLN254 billion (end of 2023: PLN245 billion),
while capital ratios remained broadly stable compared to end-of-2023 levels. The Total Capital Ratio
(TCR) stood at 21.3% at the end of September 2024 versus 20.5% at the end of 2023, while the Tier 1
ratio was at 20.0% compared to 20.2% respectively.
The year 2024 brought a continuation of slow concentration in the sector. At the end of 2024, the
share of the top five largest banks in total sector assets was nearly 60% compared to 59% at the end
of 2023 and 50% at the end of 2019. The number of commercial banks remained stable at 29 entities.
6.2. THE BANK’S AND BM GROUP’ POSITION ON THE MARKET
At end of 2024, Bank Millennium ranked 7th among top commercial banks in Poland by total assets
and deposits. The Bank’s market share in total deposits was 5.6% (5.6% at end of 2023) and 5.6% (5.8%)
in total loans. Bank Millennium Group had a relatively stronger position in the household segment
with market share in total loans including FX-mortgages at 8.2% vs. 8.5% at YE23 and market share in
in total deposits at 7.0% vs. 6.8% respectively. The Group enjoyed particularly strong position in PLN
mortgage loans segment (8.7% vs. 9.1%), non-mortgage retail loans (9.0% vs. 9.1%) or transactions
made with cards (8.3% in September ’24 vs. 8.0% in 2023). In the companies’ segment, the Group has
a lower share than in the retail segment with 3.5% in deposits and 3.7% in loans at YE24. The Group
maintains a traditionally above-average position in factoring products with market share of 5.6% in
2024. The Group continues to distribute its products and services via a network of 606 outlets (own
branches and franchise ones), as well as through electronic channels, including cash machines, the
Internet, phone and mobile apps.
BM’s market share in key segments/products
Total loans
Market
shares
Total deposits
Retail deposits
5.6%
5.6%
7.0%
Retail loans
8.2%
5.8%
December
2024
December
2023
8.5%
5.6%
6.8%
Retail term deposits
7.4%
6.8%
39
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
7. STRATEGY AND BUSINESS DEVELOPMENT PROSPECTS
7.1. 2022 – 2024 STRATEGY AND ITS DELIVERY
In 2024, Bank Millennium successfully completed the implementation of its strategy “Inspired by
People”, achieving significant progress in business growth, digital transformation and sustainability.
Millennium bank delivered on 2022-24 most of strategic targets outperforming majority of ambitions
before the strategic cycle and delivered significant increase in both its customer base and profits,
underscoring its strong market presence and operational resilience. Guided by the Bank’s new strategy
for years 2025-2028 “Value & Growth” that was announced on 28th of October 2024, Bank Millennium
is set to leverage its strong foundation to embrace innovation, digitally delivering top-quality services,
to be the primary bank for individuals and companies in Poland.
The Bank was monitoring the execution of accepted strategic targets.
Main KPIs of 2022-24 strategy and their implementation
(1) calculated as an average of digital sales shares in key products volumes; (2) Excluding FX-mortgage book related costs (for
2023 excluding also financial impact of bancassurance transaction); (3) W/o deduction of allocated legal risk provisions,
consolidated
This past year has been remarkable for our Bank – marked by initiatives that delivered tangible
benefits to our clients and stakeholders. Below, we present the most important achievements
accomplished over the past twelve months:
• Recovery Plan successfully closed in June 2024
• Portfolio agreement of the guarantee line under the InvestEU Program concluded with the
Bank Gospodarstwa Krajowego (BGK) to facilitate entrepreneurs' access to working capital
and investment loans
• Completion of the subscription of the first green bonds with a nominal value of 500 million
euros.
• New digital Solutions and products: Electronic signature mSzafir, available fully remotely for
bank's retail customers, currency exchange service, new version of the mobile app, scaling of
BNPL BLIK payments, new maps of branches and ATMs int the mobile app, new Visa Global
credit card for affluent customer.
• Providing customers affected by the recent flood with the opportunity to take advantage of
non-refundable assistance from the Borrowers Support Fund
Number of active
retail customers
3 000
2 694
[# M]
3 149
Share of digital
active clients
>90%
84%
[%]
92.3%
2021
2024
TARGET
4Q24
Client
Share of digital in
sales
1
80%
68.4%
[%]
76.5%
Annual profit
level
2
2.00
1.01
[# M]
3.2
Cost/Income
2
<37%
42.8%
[%]
30.8
Finance
Return on
equity
2
~14%
11.03%
[%]
18.5%
Non-performing
loans
<4.7%
4.4%
[# M]
4.5%
Share of FX
mortgage in bank
loans
3
<10%
14.6%
[%]
8.1%
Risk & CHF
40
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
• A trusted brand: Bank Millennium is on the prestigious list of the world’s most trusted brands
World’s Most Trustworthy Companies 2024 (Statista & Newsweek)
• Best digital bank: Millennium Bank has once again been awarded the title of the best consumer
digital bank in Poland(Best Consumer Digital Bank in Poland – Global Finance magazine)
• Quality recognition: Bank Millennium among the top 10 banks in Europe in terms of customer
experience - „The European Banking CX Index” by Forrester
• EVP (Employee Value Proposition) development recognized with the title of Top Employer
2024 and Reliable Employer 2023
• The Greatest Financial Innovation 2024 for a new application for the business segment (Global
Finance Magazine) and TOP3 in the Forbes ranking of Company-Friendly Bank
7.2. NEW STRATEGY CYCLE - STRATEGIC OBJECTIVES FOR 2025-2028
On October 28, 2024, the Bank announced a new strategy for the Bank and the Bank Millennium Group
for the years 2025-2026. “Strategy 2028 – Value & Growth” - is about continuous innovation and
bold growth. We embrace innovation, by digitally delivering top-quality services, to be the
primary bank for individuals and companies in Poland.
We aim to sustain robust growth in retail banking by leveraging primary relationships with clients,
and to double business scale in corporate banking. With ambitious growth targets, we plan to
maintain strong cost discipline (cost-to-income ratio of approximately 37% in 2028), focus on risk
management (NPL ratio below 4% in 2028) and capital solidity (Tier 1 ratio at approximately 15% in
2028), ensure sustainable profitability (reported ROE of approximately 18% in 2028), generating
value for shareholders and resuming dividend distribution from year 2027, contingent on
regulatory environment.
Corporate Banking priorities
In Corporate Banking, we are pursuing an ambitious strategy to transition from a small-scale player
to a strong market challenger. Our 2028 targets include reaching of over 50 thousand business
clients, doubling corporate loans portfolio to over PLN25 billion and maintaining top 3 position in
corporate NPS. To accelerate business customers acquisition and increase penetration of key
products, we have identified several key initiatives:
• Drive mid-corporate companies’ primacy & acquisition: Acquire targeted clients and aim to
foster primary relationship by leveraging superior customer experience
• Upgrade sales & service model for mid-corporate companies: Re-design sales process with
enhanced SLAs and overall customer experience, introduce a new CRM system and strengthen
salesforce capabilities (more RMs and Business Analysts)
• Push investment loans offensive: Grow investment loans through fast-track loan approval,
targeting specific industries
• Further expand leasing: Leverage cross-sell with existing business clients and expansion of
agent network to accelerate growth of the leasing portfolio
• Revamp service model for small businesses: Introduce differentiated, digital-first service
model and improved value proposition for small-sized companies.
Retail Banking priorities
In Retail Banking, our new strategy sets bold targets to maintain strong growth momentum aiming to
reach 3.7 million active retail customers with approximately 70% share of primary retail
customers and strengthening position within top 3 in retail NPS in 2028. We are committed to
driving robust customer acquisition while enhancing customer loyalty and product penetration. To
achieve these ambitious goals, we will focus on the following initiatives:
• Keep leadership in customer acquisition: Improve end-to-end digital acquisition
• Build primacy in the existing customer base: Enhance daily banking products, value
propositions, and offer personalisation to build primacy among existing customers
41
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
• Further grow customer funds: Expand savings and investment products that reward regular
saving and improve fee and commission income
• Evolve offering and service model for affluent segment: Expand the affluent service model
with advanced tools, improved offers, and better service levels
• Become a bank of first choice for SOHO (Small Office/Home Office) businesses: Provide
market leading offer and improved digital experience for SOHO customers
• Strengthen leadership in customer experience: Strengthen customer experience
governance, monitoring, and quality mindset
• Orchestrate distribution model: Optimise distribution model by improving digitalisation of
customer journeys, omnichannel experience and optimising the physical sales network.
Our 2028 ambitious KPIs in brief
To sum up, our key strategic KPIs for 2028 include:
• Reaching 3.7 million active retail customers
• Boosting share of primary retail customers to approximately 70%
• Strengthening position within top 3 in retail NPS
• Doubling business scale in corporate banking with a targeted loan book over PLN25bn
• Increasing of the number of business clients to above 50 thousand
• Maintaining top 3 position in corporate NPS
• Reaching above 95% share of digital active clients
• Maintaining Top Employer status
• Achieving cost-to-income ratio of approximately 37%
• Delivering ROE (reported) of approximately 18%
• Reducing NPL ratio to below 4%
• Ensuring Tier 1 ratio at approximately 15%.
Main strategic KPIs of 2025-28 strategy
1) Primary individual customers defined as customers (18+) who use Millennium Bank as their main bank and
meet certain transaction, product penetration and portfolio value thresholds
2) Dividend to be paid based on 2026 profits, contingent on regulatory environment
3) Total number of Small Business and Mid Corporate clients segment, excluding SOHO (Sole Traders) companies
reported in retail segment.
We embrace innovation, digitally delivering top-quality services,
to be the primary bank for individuals and companies in Poland.
Ambition
Additional goals
Leader in corporate and retail NPS
Return to dividend payments
from 2027
2
Maintain Top Employer status
Digital business model
>95% digital active clients
People and culture
Technology &
Resilience
Sustainability &
ESG
Digital & operating
efficiency
Compliance & Risk
Management
Number of active
retail customers
3.7
3.1
[# M]
Share of primary retail
customers
1
~70
59
[%]
Cost/Income
(reported)
~37
31.3
4
[%]
Return on equity
(reported)
~18
10.1
[%]
Total corporate
loans
>25
13.6
[PLN B]
Number of active
business clients
3
>50
>30
[# K]
Non-performing
loans
<4
4.5
[%]
Tier 1
~15
14.3
[%]
1H24
2028
Goals
Keep growth in retail banking
leveraging primary relationships…
…and doubling business scale in
corporate banking...
…to ensure sustainable profitability
and generate long-term value for
shareholders…
…while securing a solid risk and
capital position.
42
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
7.3. BUSINESS OUTLOOK FOR 2025
As previously stated in the report, 2025 is expected to bring not only stronger GDP growth (3.7%
anticipated compared to 2.9% in 2024) but also a shift in its driving factors. Investment demand is
anticipated to play a more significant role in this growth. Lower interest rates and inflation are
expected to support demand for retail and corporate borrowing. Additionally, the resurgence of
private investment cycle, particularly projects co-financed by EU funds, is projected to provide
further impetus to corporate borrowing through co-funding requirements. Furthermore, the
combination of these factors, coupled with low unemployment and continued, albeit slower, wage
growth, is likely to result in a relatively low-risk backdrop.
The aforementioned trends should align well with the first year of implementing the new strategy.
The focus will remain on the growth of the core business. In the retail segment, the origination of
non-mortgage lending is expected to grow moderately, while the origination of PLN mortgages should
slow, allowing for margin preservation. Conversely, the corporate segment is anticipated to
accelerate lending growth. The steady collection of deposits should further support liquidity, and
through balance sheet hedging (continued investments in fixed-rate treasuries and partially lending
at fixed rates), feed into relatively resilient net interest income (NII). The implementation of the new
strategy will have influence on operating expenses, that are expected to grow at a low double-digit
rate in percentage terms. New hirings, changing staff structure, and continued wage adjustments will
increase HR costs. Higher non-HR costs are expected to reflect increased spending on IT, new
projects, initiatives, and anticipated much higher BFG charges with the deposit guarantee fee
returning after two and a half years of absence. The cost of risk is expected to increase toward the
range of 50-70 basis points over total gross loans, reflecting a higher share of small- and mid-corporate
loans in origination, as well as a changing mix within the retail portfolio. FX-mortgage related costs
are expected to remain significant but should follow a downward trajectory. Finally, it should be
noted that 2025 will bring a full-year bank tax charge, while the effective tax rate should return to a
normalized level, in contrast to 2024 where the tax line benefitted from the recognition of deferred
tax assets (DTA).
Notwithstanding the positive business outlook, risks, particularly those of a legal and regulatory
nature, will continue to pose potential threats. The Bank is cognizant of the risks associated with
rulings by local courts and the European Court of Justice on consumer loans. A legislative proposal
concerning the overhaul of the handling of FX-mortgage-related claims may necessitate adjustments
to the Bank’s strategy of mitigating legal risk and adjustments in provisioning inputs, depending on
its final form. Furthermore, other potential adverse developments regarding the legal risks related to
this portfolio or the PLN mortgage book may arise.
43
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
8. FINANCIAL SITUATION
8.1. PROFIT AND LOSS ACCOUNT
Operating income
(PLNmn)
2024
2023
y/y
Net interest income
5 530
5 253
5%
Impact of credit holidays on net interest income
(113)
(9)
-
Net interest income adjusted
5 643
5 263
7%
Net commission income
777
782
-1%
Core income
6 307
6 036
4%
Core income without credit holidays
6 419
6 045
6%
Other non-interest income*
(311)
687
-
Total operating income
5 996
6 723
-11%
Total operating income adjusted**
6 873
6 397
7%
(*) Without fair value adjustment of credit portfolio (PLN0.7mn in 2024 and PLN-1.0mn in 2023), which is included in the cost
of risk line
(**) Without extraordinary items, i.e. negative impact of credit holidays (PLN113mn in 2024 and PLN9m in 2023), financial
impact of insurance transaction (total pre-tax income of PLN652mn in 2023) and FX mortgage loan related costs/incomes (in
FX position and other operating income/cost including indemnity from Societe Generale)
Net interest income (NII) in 2024 reached PLN5,530mn on a reported basis and grew 5% y/y. This
moderate growth was a result of credit holidays for PLN mortgage borrowers (PLN113mn booked in
2024). NII without this effect was 7% higher y/y, mostly driven by the higher income from debt
securities and lower cost of clients’ deposits. The factors with negative impact on NII were lower
market interest rates after the 100 bps central bank rates cut in September/October’23, interest
costs on MREL issued bonds (EUR500mn issue in September’23 and EUR500mn in September’24) and
cost of asset securitisations.
Net interest margin (over average interest earning assets) (NIM) averaged 4.36% in 2024 (without
credit holidays impact mentioned above), i.e. 25 bps lower vs. the level of 2023. The above mentioned
factors (interest rate cuts and MREL bonds) as well as growing share of bonds in assets had an adverse
impact on NIM whereas decreasing cost of deposits by 34 bps during 12 months (from 2.55% in 4Q23
to 2.21% in 4Q24) and some improvement in bonds yields had both a positive impact.
Net commission income in 2024 amounted to PLN777mn and decreased by 1% y/y. The subdued
growth was mainly caused by falling fees from bancassurance activity (down 22% y/y as a result of
the bancassurance transaction). Commissions from loans recorded a considerable decline too. On the
other hand commissions from payment cards, brokerage and custody, funds management and
distribution of mutual funds and other investment products increased substantially, offsetting to large
extent the previously mentioned declines.
Reported core income, defined as a combination of net interest and net commission income, reached
PLN6,307mn in 2024 and grew by 4% y/y due to the impact of credit holidays. Core income without
this effect would reach PLN6,419mn, which translates into a growth of 6% y/y and constitutes a key
factor of Group’s recurrent profitability improvement.
Other non-interest income, which comprises FX result, results on financial assets and liabilities
(without fair value adjustment on credit portfolio) and net other operating income and costs, showed
a negative value of PLN311mn in 2024. Costs of amicable settlements negotiated with FX mortgage
borrowers and legal costs related to FX mortgage loans (PLN809mn presented in FX result and other
44
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
operating costs) continued to negatively impact this line. In addition to that, in 2023 this line was
under strong positive impact of the insurance transaction (sale of shares in Millennium Financial
Services Sp. z o.o. to external insurance partner in March’23 and related impacts), with total pre-tax
impact of PLN652mn. The abovementioned factors make the analysis of the annual changes of this
income line difficult.
Total operating income of the Group reached PLN5,996mn in 2024 and decreased 11% y/y. Without
the extraordinary income and costs mentioned above, the adjusted operating income would amount
to PLN6,873mn, up 7% y/y.
Total costs amounted to PLN2,253mn in 2024, translating into an increase by 13% y/y.
Operating costs
(PLNmn)
2024
2023
y/y
Personnel costs
(1 197)
(1 035)
16%
Other administrative costs
(1 056)
(958)
10%
of which Banking Guarantee Fund (BFG) fees
(61)
(60)
1%
Total operating costs
(2 253)
(1 993)
13%
Total costs without BFG
(2 192)
(1 933)
13%
Cost/income – reported
37.6%
29.6%
7.9 p.p.
Cost/income – adjusted *
30.8%
29.5%
1.2 p.p.
(*) without extraordinary income or cost
Personnel costs amounted to PLN1,197mn in 2024 and increased 16% y/y, mainly as a result of wage
inflation feeding through higher base salaries and variable compensation. The Group continued to
adjust the number of its branches and personnel to its needs, reflecting ongoing digitalisation of
banking business and the growing importance of online channels while simultaneously keeping strong
geographical presence through brick-and-mortar outlets. At the end of December 2024, the total
number of outlets stood at 606 and their number was reduced by 6 units vs. the end of December
2023. The number of Group’s employees amounted to 6,714 FTEs at the end of December 2024 and
stayed on similar level as at one year before. Without employees absent due to long leaves (‘active
FTEs’), the headcount was lower at 6,355 staff.
Employment
(FTEs)
31.12.2024
31.12.2023
y/y
Bank Millennium S.A.
6 450
6 460
0%
Subsidiaries
264
287
-8%
Total Bank Millennium Group
6 714
6 747
0%
Total BM Group (active* FTEs)
6 355
6 320
1%
(*) active FTEs denote employees not on long-term leaves
Other administrative costs (including depreciation) reached PLN1,056mn in 2024 and increased by
10% y/y. Among the key groups of costs the higher increase could be witnessed in such items as legal
and advisory costs, marketing spendings and IT and telecommunication costs. Legal costs resulting
from negotiations and litigations with FX mortgage borrowers were a significant burden to this cost
group (PLN138mn in the reporting period).
Cost-to-income ratio for 2024 amounted to 37.6% and was higher by 7.9 percentage points vs. very
low level in 2023 (29.6%), mainly due to the impact of high one-off burden/income in 2024 (cost of
credit holidays) and in 2023 (the income from bancassurance transaction). Cost-to-income ratio
without extraordinary items mentioned above (mainly the bancassurance transaction, cost of credit
45
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
holidays and legal costs and FX losses related to litigations/settlements with FX mortgage borrowers),
reached a low level of 30.8% in 2024 and was slightly higher (by 1.2 percentage points) than in 2023.
Net profit (consolidated)
(PLNmn)
2024
2023
y/y
Operating income
5 996
6 723
-11%
Operating costs
(2 253)
(1 993)
13%
Impairment provisions and other cost of risk*
(310)
(299)
4%
Other modifications**
(147)
(52)
181%
FX legal risk related provision
(2 179)
(3 065)
-29%
Banking tax
(232)
0
-
Pre-tax profit
875
1 312
-33%
Income tax
(156)
(737)
-79%
Net profit – reported
719
576
25%
Net profit – adjusted***
3 202
2 993
7%
(*) Impairment provisions for financial and non-financial assets including also fair value adjustment of credit portfolio
(PLN0.7mn in 2024 and PLN-1.0mn in 2023) and loans modification effect not related to amicable settlements with FX
mortgage borrowers (PLN-35.7mn in 2024 and PLN-36.0mn in 2023)
(**) The value of modification booked in given period resulting from amicable settlements with FX mortgage borrowers and
referring to a specific group of such agreements.
(***) Without extraordinary items, i.e. negative impact of credit holidays (PLN91mn in 2024 and PLN7m in 2023 after tax),
financial impact of insurance transaction (total after-tax income of PLN528mn in 2023) and FX mortgage loan related
costs/incomes (in legal risk provisions, FX position, operating cost and other operating income/cost including indemnity from
Societe Generale as well as tax effects) and hypothetical banking tax until the end of May 2024
Total cost of risk, which comprises net impairment provisions, fair value adjustment related to
specified loan portfolios and a part of result on modifications (excluding the part related to
settlements with FX mortgage borrowers), bore by the Group amounted to PLN310mn in 2024 and was
4% higher versus the comparable period of the previous year due to higher provisions for loans to
companies, especially in 2H24. Risk charges for retail segment (including FX mortgage) amounted to
PLN203mn in 2024. Risk charge for corporate and other segments amounted to PLN107mn. In relative
terms, the cost of risk (i.e. net charges to average gross loans) for 2024 reached 40 basis points and
was similar to the level in 2023 (39 basis points).
In 2024, the Group booked in modifications line a part of costs related to settlements with FX
mortgage borrowers in the amount of PLN147mn (of which PLN138mn refers directly to Bank
Millennium), 181% higher than in the previous year. It was connected with higher number of and more
costly amicable settlements with the FX-mortgage borrowers.
In 2024, the Bank continued to create provisions for legal risk related to FX-mortgage portfolio,
which remained a significant item in the P&L statement and reached PLN2,179mn (PLN1,979mn
excluding loans generated by former Euro Bank as they are subject to indemnity clauses and
guarantees from Societe Generale). The provisions were lower by 29% than these created in 2023 as
the whole 2023 was characterised by higher level of such provisions after the earlier opinion and the
final judgement of the European Court of Justice of June 15, 2023 on case C-520/21, with resultant
elimination from the Bank’s legal risk provisioning methodology of the (low) probability of receiving
remuneration for the use of capital it had provided, while fuelling continuation of the inflow of court
cases. Additionally, the Bank also updated other parameters in its methodology. At the end of
December’24, provisions for the portfolio originated by Bank Millennium were at the level of
46
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
PLN7,724mn (an equivalent of 122% of the grossed-up FX-mortgage book) and at PLN740mn for the
portfolio originated by the former Euro Bank.
Pre-income tax profit in 2024 amounted to PLN875mn and was significantly lower (by 33% y/y) vs the
level of 2023 due to high one-off cost in 2024 and one-off gains in 2023 as mentioned above. Moreover,
the Bank was not due to pay banking tax since July 15, 2022, the date of the Bank’s decision to launch
the Recovery Plan. On 19 June 2024 the Bank took a decision to complete the implementation of the
Recovery Plan, notifying of the fact Polish Financial Supervision Authority and Bank Guarantee Fund
and consequently starting to pay the banking tax. In the Bank’s Management Board’s opinion, all key
assumptions of the Recovery Plan had been achieved by this date. As a result in 2Q24, 3Q24 and in
4Q24 the Group reported banking tax in the total amount of PLN232mn, which was a significant burden
to Group’s pre-tax profit.
In 2024 the Group reported net profit of PLN719mn i.e. which was strongly higher (by 25%) than the
profit of 2023 thanks to much lower level of income tax. The low level of income tax in 2024 resulted
from the impact of CIT and DTA adjustments relating to interest income and FX differences on some
FX mortgage loans declared or expected to be declared invalid by courts’ verdicts. Adjusted for the
abovementioned extraordinary items (i.a. FX-mortgage related costs, tax impacts and credit holidays
in 2024 and the income from sale of shares in bancassurance business in 2023) the Group would
achieve the net profit of PLN3,202mn in 2024, i.e. 7% above the adjusted net profit of PLN2,993mn
for 2023.
Reported 2024 return on equity (ROE) stood at 9.8% but when adjusted for extraordinary items
(including all FX mortgage related costs since 2020 in equity) it reached 18.5%. Reported Return on
Assets (ROA) for 2023 was 0.5%.
The breakdown of Group's Net Profit by the Group's companies is presented in the table below:
Group's profit structure
(PLN million)
2024
Bank Millennium
643.1
Millennium Bank Hipoteczny (mortgage bank)
17.1
Millennium Leasing
17.9
Millennium TFI (mutual funds management)
30.2
Millennium Service
31.5
Other consolidated companies
20.3
Summarised profits
760.1
Consolidation adjustments
-40.9
Consolidated Net Profit of the Group
719.2
47
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Bank's Profit and Loss Account
Changes of particular key items of the Bank’s Profit and Loss Account in 2024 are shown in the table
below.
Bank's operating income
2024
2023
(PLNmn)
y/y
Net interest income
5 421
5 135
6%
Impact of credit holidays on net interest
income
(107)
(11)
-
Net interest income without credit holidays
5 527
5 146
7%
Net commission income
668
684
-2%
Core income
6 089
5 818
5%
Core income without credit holidays
6 196
5 830
6%
Other non-interest income*
(307)
704
-
of which dividends
39
32
21%
Total operating income*
5 782
6 522
-11%
(*) Without fair value adjustment of credit portfolio (PLN0.7mn in 2024 and PLN-1.0mn in 2023), which is included in the cost
of risk line
The Bank’s (non-consolidated) 2024 net interest income amounted to PLN5,421mn and increased by
6% y/y and similar as in the Group’s case, the growth rate was undermined by credit holidays impact,
booked by the Bank in much higher amount in 2024 (PLN107mn). Net interest income without the cost
of credit holidays would grow 7% y/y - at similar scale as for the Group.
Net commission income in 2024 amounted to PLN668mn and decreased -2% y/y. Core income (adjusted
for credit holidays impact) was PLN6,196mn and grew 6% y/y, the same growth scale as in the case
of the Group.
Other non-interest income of the Bank in 2024 was negative and amounted to PLN-307mn while in
2023 it reached PLN704mn. The income line was strongly driven by the impact of similar extraordinary
items as it was described above for the Group (mostly the insurance transaction and the costs related
to FX mortgage loans and settlements with the borrowers). This item includes dividends, largely from
the Capital Group’s subsidiaries (eliminated in reports on the Group level). Dividend income in 2024
reached PLN39mn, which means a decrease by 21% y/y.
As a result of the evolution of the abovementioned items the Bank’s total operating income in 2024
amounted to PLN5,782mn and declined by 11% y/y (similar scale as for the consolidated Group).
48
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Bank's net profit
(PLN million)
2024
2023
y/y
Operating income
5 782
6 522
-11%
Operating costs
(2 177)
(1 921)
13%
Impairment provisions and other cost of risk *
(277)
(259)
7%
Other modifications**
(147)
(52)
181%
Provision for legal risk related to FX mortgage
loans
(2 179)
(3 065)
-29%
Banking tax
(232)
0
-
Pre-income tax profit
771
1 225
-37%
Income tax
(127)
(715)
-82%
Net profit
643
510
26%
(*) Impairment provisions for financial and non-financial assets including also fair value adjustment on loans (PLN0.7mn in
2024 and PLN-1.0mn in 2023) and loans modification effect (PLN-35.6mn in 2024 and PLN-36.0mn in 2023);
(**) The value of modification booked in given period resulting from amicable settlements with FX mortgage borrowers and
referring to a specific group of such agreements.
The Bank’s operating costs reached the total amount of PLN2,177mn in 2024 and was 13% higher vs.
the level for 2023. The reasons for the annual decrease of costs are the same as in case of the
consolidated data for the whole Capital Group. The evolution of personnel costs and other
administrative costs was similar to the corresponding Group’s items and was highly inflation-driven.
Impairment write-offs and other costs of risk of the Bank were PLN277mn in 2024, which means an
increase 7% y/y – the similar scale as in the Group’s case.
Besides provisions for credit risk, in 2024 the Bank created a provision for legal risk related to FX
mortgage loans in the amount of PLN2,179mn, which was explained above in the part referring to the
whole Group.
The Bank reported pre-tax profit for 2024 of PLN771mn which translates into a considerable decrease
of 37% y/y – a very similar scale as in the Group’s case, due to high extraordinary costs in 2024 and
banking tax booked in 2024 and one-off gains in 2023.
In 2024 the Bank reported net profit of PLN643mn, i.e much higher (by 26%) vs. the net profit for
2023, due to much lower income tax value explained earlier in the part referring to the Group’s profit.
Return on the Bank’s assets (ROA) reached 0.5% for 2024.
8.2. RESULTS OF BUSINESS SEGMENTS
Presented below are data regarding the Profit and Loss Account for the Group’s four business
segments: retail segment, corporate segment, FX mortgage loans segment and treasury operations,
assets/liabilities management and other segment. The retail segment comprises services provided to
individual customers on the mass market, affluent customers, sole traders as well as services to small
companies (with annual turnover below PLN5mn). The corporate segment involves services to medium
and large companies as well as public sector entities. The treasury operations, assets/liabilities
management and other business comprises the Group’s treasury investments, interbank market
transactions, taking positions in debt securities, brokerage activity as well as other transactions not
classified in the first three segments.
Bank Millennium recent financial performance is significantly influenced by the costs related to
managing legacy FX mortgage portfolio of loans. To isolate these costs and other financial results
related to this portfolio Bank decided to isolate, commencing from 2021, a new segment from Retail
and present it in financial statements as “FX mortgage”. Such change impacts only results
presentation and is not triggering any organizational changes in the Bank. New segment includes loans
separated based on active FX mortgage contracts for a given period and is applying to portfolios of
retail mortgages originated in Bank Millennium and Eurobank in foreign currencies. This portfolio is
49
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
expected to run-off in line with repayments of FX loans, conversions to PLN loans, realization of court
verdicts and write-offs.
Retail segment
(PLN million)
2024
2023
y/y
Net interest income*
4 790
4 684
2%
Net commission income
596
591
1%
Other income**
127
112
13%
Total operating income
5 512
5 387
2%
Total operating costs
(1 665)
(1 472)
13%
Pre-provision income
3 847
3 915
-2%
Impairment provisions and other cost of risk**
(262)
(314)
-17%
Operating profit
3 585
3 600
0%
(*) Part of interest income generated by this segment (so called liquidity premium) has been recognized in the third segment
of “Treasury, ALM and other” in accordance to Recommendation P of the Polish regulator (KNF)
(**) Fair value adjustment of credit portfolio (PLN0.7mn in 2024 and PLN-1.0mn in 2023) has been moved to pro-forma cost of
risk. Cost of risk includes also result from modification.
Total operating income of the retail segment in 2024 was PLN5,512mn, which represents an increase
by 2% y/y. Net interest income of the retail segment recorded a growth by 2% y/y reflecting the
adverse impact of credit holidays (mentioned above in the comments regarding Group’s net interest
income). Net commission income increased slightly 1% y/y. Low growth of this item mainly resulted
from lower bancassurance commissions. Operating costs of the retail segment grew by 13% y/y, so it
was similar as for the whole Group.
As a result of the abovementioned evolution of operation income and costs, total retail segment pre-
provision income reached PLN3,847mn in 2024 and slightly decreased by 2% vs. the level of 2023. The
cost of risk of the segment presented a material decrease by 17% y/y.
Operating profit of the retail segment for 2024 - after consideration of the provisions – amounted to
PLN3,585mn and stayed on the similar level as in the previous year, with the negative impact of credit
holidays costs, mostly in 2024. The profit was high in absolute terms and signified the key factor of
the whole Group’s profit, allowing to offset substantial loss of FX mortgage segment.
Corporate segment
(PLN million)
2024
2023
y/y
Net interest income *
757
777
-3%
Net commission income
172
176
-2%
Other income
90
93
-3%
Total operating income
1 018
1 045
-3%
Total operating costs
(323)
(296)
9%
Pre-provision income
695
749
-7%
Impairment provisions and other cost of risk**
(100)
(18)
451%
Operating profit
595
731
-18%
(*) Part of the interest income generated by this segment (so called liquidity premium) has been recognized in the segment
of “Treasury, ALM and other” in accordance to Recommendation P of the Polish regulator (KNF)
(**) Cost of risk includes also result from modification.
Total operating income of the corporate segment in 2024 stood at PLN1,018mn and slightly decreased
by 3% compared to the level of 2023. This was first of all the result of lower net interest income due
50
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
to modest growth of loans. Net commission income declined a bit by 2% y/y and other non-interest
income declined 3% y/y. Operating costs of the corporate segment saw a 9% increase y/y.
As a result of the above, pre-provision income decreased by 7% y/y. Value of net impairment write-
offs regarding loans to companies in 2024 presented a much higher value than in the previous year
and amounted to PLN100mn due to some deterioration in the loan portfolio quality. Taking all above
factors together, the operating profit of the corporate segment saw a decrease of 18% y/y to the level
of PLN595mn in 2024.
Treasury, ALM and other segments
(PLN million)
2024
2023
y/y
Net interest income*
(9)
(227)
-
Net commission income
3
4
-34%
Other income
66
658
-90%
Total operating income
60
435
-86%
Total operating costs
(126)
(120)
5%
Pre-provision income
(67)
315
-
Impairment provisions and other cost of risk
(4)
(0)
-
Operating profit
(71)
315
-
(*) Part of the interest income generated by other segments (so called liquidity premium) has been recognized in the segment
of “Treasury, ALM and other” in accordance to Recommendation P of the Polish regulator (KNF)
Total operating income of the Treasury, ALM and other segments in 2024 recorded a positive value of
PLN60mn and it was much lower vs. the value for 2023 due to the insurance transaction reported in
that period, which is mentioned above in the text. Net interest income was negative and amounted
to PLN-9mn due to fund transfer pricing specifics and MREL bonds issue costs. Operating costs
increased by 5% y/y. As a result operating result of the entire segment amounted to (negative) PLN
-71mn for 2024.
51
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
FX Mortgage
(PLN million)
2024
2023
y/y
Net interest income*
(7)
20
-
Net commission income
6
12
-47%
Other income
(593)
(176)
-
Total operating income
(594)
(145)
-
Total operating costs
(138)
(104)
33%
Pre-provision income
(732)
(249)
-
Impairment provisions and other cost of risk**
(2 270)
(3 085)
-26%
Operating result
(3 002)
(3 333)
-
(*) Part of the interest income generated by other segments (so called liquidity premium) has been recognized in the segment
of “Treasury, ALM and other” in accordance to Recommendation P of the Polish regulator (KNF)
(**) Including legal risk provisions for FX mortgage portfolio and result on modification
Following P&L categories are presented as part of financial performance of FX Mortgage segment:
1. Net Interest Income: Margin on FX loans (interest results less Fund Transfer Pricing).
2. FX results related to portfolio (mainly costs of amicable negotiations).
3. Cost of provisions for FX mortgage portfolio legal risk partially offset by valuation of SG
Indemnity in other operating income line regarding ex-EB portfolio.
4. Cost of Credit Risk related to current FX portfolio.
5. Result on modification resulting from settlements with borrowers.
6. Other Costs that are directly related to FX mortgages including, but not limited to:
i. Legal chancellery costs (administrative costs),
ii. Court costs related to FX mortgage cases (other operating costs).
Total operating loss of the FX Mortgage segment in 2024 was PLN3,002mn, due to high provisions for
legal risk related to the loan book and costs of settlements presented in modifications (total cost of
risk amounted to PLN2,270mn). Moreover, the impact of cost of amicable settlements with clients in
FX income and legal costs in operating costs had additional adverse effect on the financial result.
Negative value of other income was much higher than in the previous year and amounted to PLN -594
mn. Also operating costs in 2024 were higher by 33% than in the previous year. However operating
loss for 2024 was lower by PLN331mn vs. the previous year.
More information on business segments of the Group can be found in Chapter 9 "Operational Segments"
of the Annual Financial Statements of Bank Millennium S.A. Capital Group for the period of 12 months
ending on 31 December 2024.
52
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
8.3. BALANCE SHEET AND OFF-BALANCE SHEET ITEMS
Assets
The Group’s assets as at 31 December 2024, amounted to PLN139,152mn, recording a growth of 11%
vs. 31 December 2023. The structure of the Group’s assets as well as changes of their particular
components are presented in the table below:
Group's Assets
(PLN million)
31.12.2024
31.12.2023
y/y
Value
Structure
Value
Structure
(%)
Cash and operations with the Central
Bank
5 179
3.7%
5 095
4.1%
2%
Loans and advances to banks
435
0.3%
793
0.6%
-45%
Loans and advances to clients
74 981
53.9%
73 643
58.7%
2%
Receivables from securities bought with
sell-back clause
194
0.1%
1 163
0.9%
-83%
Debt securities
54 207
39.0%
41 009
32.7%
32%
Derivatives (for hedging and trading)
368
0.3%
572
0.5%
-36%
Shares and other financial instruments*
147
0.1%
148
0.1%
0%
Tangible and intangible fixed assets**
1 146
0.8%
1 047
0.8%
9%
Other assets
2 494
1.8%
2 049
1.6%
22%
Total assets
139 152
100.0%
125 520
100.0%
11%
(*) including investments in associates
(**) excluding fixed assets for sale
The key reason for the growth of total assets in 2024 was the growth of debt securities (+PLN13.2bn)
whereas loans to customers presented lower increase by PLN1.3bn.
Loans and advances to Clients
Total net loans of Bank Millennium Group reached PLN74,981mn as at 31 December 2024 and increased
2% y/y. Loans without FX-mortgage portfolio increased by 4% y/y. FX mortgage loans net of provisions
decreased materially during the last twelve months (down 56%) and the share of FX mortgage loans
(excluding these taken over with Euro Bank) in total gross loans has dropped materially during one
year period to 1.5% from 3.6% a year ago. This was partly due to the fact that most of legal risk
provisions lower the gross value of the loans apart from regular amortisation, earlier repayments,
conversions to PLN and execution of court verdicts.
The net value of loans to households amounted to PLN56,935mn as at 31 December 2024, showing 1%
increase y/y although subdued growth trend results from shrinking book value of FX mortgage
portfolio. Within loans to households line, PLN mortgages reached PLN37,321mn and grew 3% y/y,
with visible rebound in new loans origination: disbursements of those loans in 2024 reached PLN5.9bn
and grew by 22% y/y. Another component of retail portfolio, consumer loans, also presented a very
good performance. The net value of consumer loans reached PLN18,301mn at the end of December
2024 and increased by 7% y/y. The cash loans origination in 2024 reached PLN7bn, which implies 11%
increase compared to the previous year.
Net value of loans to companies amounted to PLN18,046mn as 31 December 2024 and increased by 5%
y/y. The increase of companies’ portfolio was visible in leasing portfolio, as well as in other loans.
The value of new leasing contracts for 2024 grew by 25% y/y reaching PLN3.9bn. The growth of the
loan portfolio was to some extent limited by the necessity of the risk weighted assets (RWA)
optimisation resulting from capital management objectives.
53
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The structure and evolution of loans to clients of the Group is presented in the table below:
Loans and advances to clients
(PLNmn)
31.12.2024
31.12.2023
y/y
Loans to households
56 935
56 386
1%
- PLN mortgage loans
37 321
36 356
3%
- FX mortgage loans
1 314
2 989
-56%
- of which Bank Millennium loans
1 127
2 651
-57%
- of which ex-Euro Bank loans
187
338
-45%
- consumer loans
18 301
17 040
7%
Loans to companies and public sector
18 046
17 257
5%
- leasing
6 948
6 599
5%
- other loans to companies and factoring
11 098
10 658
4%
Net loans & advances to clients
74 981
73 643
2%
Net loans and advances to clients excluding FX
mortgage loans
73 667
70 654
4%
Impairment write-offs
2 514
2 518
0%
Gross* loans and advances to clients
77 496
76 161
2%
(*) Including, besides provisions for credit risk, also fair value adjustment of loan portfolio presented in fair value as well as
modification. Gross loan portfolio in this case presents value of loans and advances before mentioned provisions and
adjustments but after allocating legal risk provisions related to FX mortgage loans.
Average interest rate on the Bank’s loan portfolio in 2024 was 8.0%. This rate includes net interest
income on hedging derivatives (mainly FX and interest rate SWAPs).
Debt securities
Value of debt securities reached PLN54,207mn as at 31 December 2024, which means a significant
increase of 32% y/y.
A dominant part of the debt securities portfolio (95%) were bonds and bills issued by the Polish State
Treasury, other EU governments (equivalent of c.a PLN8.7bn) and National Bank of Poland (Central
Bank). The increase of debt securities portfolio was a consequence of assets/liabilities and interest
margin management policy and was correlated with the much stronger growth of deposits versus
loans. The share of this group of debt securities in the consolidated total assets was at 37% at end of
December 2024 reflecting a strong liquidity position of the Group.
More information on debt securities and liquidity management of the Bank can be found in Chapter
11.4. of this document and in Chapter 8.5. "Liquidity Risk" of the Annual Financial Statements of Bank
Millennium S.A. Capital Group for the period of 12 months ending on 31 December 2024.
Derivative instruments
The value of derivatives (for trading and hedging) totalled PLN368mn at end of December 2024 (a
decrease by 36% y/y), and refers to positive valuation of derivatives whereas negative valuation of
derivative instruments is presented on the liabilities side. The main component of derivatives are FX
swaps and other FX derivatives, cross-currency swaps and interest rate swaps. The valuation of those
instruments depends on changes in FX rates and interest rates level.
54
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The Group manages its FX liquidity using FX-denominated deposits, own issue of EUR bonds as well as
Cross Currency Swap and FX Swap transactions. The importance of swaps has been decreasing because
of the reduction of the FX mortgage loan portfolio and the hedge in foreign currency of most of the
provisions for legal risk. The swaps portfolio is diversified in term of counterparties and maturity
dates.
More information on derivative transactions of the Bank can be found in Note 19E and Note 24 and in
Chapter 8.5. "Liquidity Risk" of the Annual Financial Statements of Bank Millennium S.A. Capital Group
for the period of 12 months ending on 31 December 2024.
Deposits, loans and advances to banks
Deposits, loans and advances to banks (including interbank deposits) stood at PLN435mn at the end
of December 2024, which means a decrease by 45% y/y and it mainly refers to current accounts
balances.
Shares/equities and other financial instruments
Value of equities/shares and other financial instruments amounted to PLN147mn at the end of
December 2024 and stayed on practically the same level as in the previous year.
Tangible fixed assets and intangibles and goodwill (investment outlays)
Tangible fixed assets and intangibles and goodwill of the Group amounted to PLN1,146mn at the end
of December 2024 and increased by 9% y/y mostly due to the growth of intangible assets (+16% y/y)
whereas tangible fixed grew 4% y/y.
Total investment of the Group in 2024 amounted to PLN237mn. Outlays for the Bank’s physical
infrastructure (headquarter modernization, branches, ATMs etc.) amounted to PLN40.5mn and
PLN195.1mn for software and IT infrastructure. Value of other outlays i.e. PLN1.4mn, relates to
Bank’s subsidiaries. The Bank Millennium Group plans investment capital expenditures in 2025 in the
amount of PLN289.5mn, out of which ca. 84% will be allocated to IT projects (i.e. further internet
and mobile banking developments, capacity extensions as well as regulatory & security projects).
55
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Bank’s unconsolidated assets, as on 31 December 2024 reached the value of PLN137,700mn and were
10% higher compared to the level as at the end of 2023. Structure of the Bank’s assets and changes
of individual components are presented in table below:
Bank's Assets
(PLN million)
31.12.2024
31.12.2023
y/y
Value
Structure
Value
Structure
(%)
Cash and operations with the Central
Bank
5 179
3.8%
5 095
4.1%
2%
Loans and advances to banks
2 379
1.7%
1 867
1.5%
27%
Loans and advances to clients
71 937
52.2%
72 405
58.0%
-1%
Receivables from securities bought with
sell-back clause
194
0.1%
1 163
0.9%
-83%
Debt securities
53 654
39.0%
40 527
32.5%
32%
Derivatives (for hedging and trading)
369
0.3%
573
0.5%
-35%
Shares and other financial instruments
621
0.5%
495
0.4%
25%
Tangible and intangible fixed assets*
1 135
0.8%
1 034
0.8%
10%
Other assets
2 232
1.6%
1 728
1.4%
29%
Total assets
137 700
100.0%
124 888
100.0%
10%
* excluding fixed assets for sale
The key difference between the level of assets of Bank standalone and the consolidated Group is the
value of loans to customers. In the first place it relates to mortgage loans transferred to mortgage
bank subsidiary with the total balance as at the end of 2024 of PLN2,892mn and receivables due from
leasing company customers in the amount of PLN7,095mn (although significant part of the said
receivables were financed by the Bank) and relates to elimination of mutual transactions between
the Bank and other companies from the Capital Group in consolidated financial statements.
Total Loans to customers in the Bank amounted to PLN71,937mn as at 31 December 2024 and
decreased by 1% y/y. Alike the Group’s case the dynamics of loans was visibly influenced by significant
decline of FX mortgage loans.
Value of debt securities in the Bank’s assets reached PLN53,654mn at the end of December 2024. Both
the portfolio dynamics and structure remained similar as in the case of the Group (as described above)
although higher balances for the Group (by PLN553mn) resulted from treasury debt securities held by
the Bank’s subsidiaries: Millennium Leasing and Millennium Bank Hipoteczny.
Loans and advances to banks (including interbank deposits) stood at PLN2,379mn at the end of
December 2024, which means an increase by 27% y/y . Different evolution of this item compared to
the Group’s case results from the financing extended by the Bank to its subsidiary Millennium Bank
Hipoteczny.
Equities/shares and other financial instruments presented in the Bank’s financial statements, unlike
in the case of Group reports, incorporated valuation of shares in subsidiaries. The value of this item,
as on 31 December 2024, amounted to PLN621mn, recording an increase by 25% y/y.
The Bank’s fixed assets and intangibles amounted to PLN1,135mn at the end of December 2024 and
increased by 10% vs. the previous year.
Values and annual changes to other asset groups presented in the table above are similar to the
corresponding items of consolidated Group, as described earlier in this document.
56
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Liabilities
The structure of Group’s liabilities and equity and the changes of their particular components are
presented in the table below:
Group's Liabilities and Equity
(PLN million)
31.12.2024
31.12.2023
y/y
Value
Structure
Value
Structure
(%)
Deposits from banks
317
0.2%
564
0.5%
-44%
Deposits from customers
117 257
89.3%
107 246
90.4%
9%
Liabilities from securities sold with
buy-back clause
194
0.1%
0
0.0%
-
Financial liabilities valued at fair
value through P&L and hedging
derivatives
525
0.4%
773
0.7%
-32%
Liabilities from issue of debt
securities
6 125
4.7%
3 318
2.8%
85%
Provisions
2 901
2.2%
1 445
1.2%
101%
Subordinated debt
1 562
1.2%
1 565
1.3%
0%
Other liabilities*
2 499
1.9%
3 714
3.1%
-33%
Total liabilities
131 380
100.0%
118 625
100.0%
11%
Total equity
7 772
6 895
13%
Total liabilities and equity
139 152
125 520
11%
* including tax liabilities
At the end of December 2024 liabilities accounted for 94.4%, while equity of the Group - for 5.6% of
total liabilities and equity.
As on 31 December 2024 Group’s total liabilities amounted to PLN131,380mn and were higher by 11%
relative to their value as on 31 December 2023. The main change to liabilities resulted from strong
increase of deposits by PLN10bn and also the issuance of debt securities (balances higher by PLN2.8bn)
during the 12 month period.
Customers’ deposits
Customer deposits constituted the main line item under the Group’s accounting for, as on 31
December 2024, 89% of total liabilities. Customer deposits constitute the main source of financing of
Group’s activities and incorporate, primarily, customer funds on current and saving accounts
as well as on term deposit accounts.
The evolution of clients deposits is presented in the table below:
Customer deposits
(PLN million)
31.12.2024
31.12.2023
y/y
Deposits of individuals
87 567
76 600
14%
Deposits of companies and public sector
29 690
30 647
-3%
Total deposits
117 257
107 246
9%
Total customer deposits amounted to PLN117,257mn on 31 December 2024 and grew by 9% y/y.
Deposits of individuals reached PLN87,567mn as at 31 December 2024 and posted high growth of 14%
57
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
y/y. Term deposits from retail clients grew by 14% y/y whereas current and saving accounts of
individuals grew by 15% y/y.
Deposits of companies and public sector, which reached PLN29,690mn on 31 December 2024, fell by
3% y/y due to strong decline in term deposits from companies caused by the tighter price
management, whereas current account deposits grew visibly (by 7% y/y).
Average interest rate on all deposits in the Bank in 2024 amounted to 2.3%.
Deposits from banks
Deposits from banks, including credits received, as on 31 December 2024, amounted to PLN317mn.
Value of this item decreased by 44% relative to the balance as on 31 December 2023, mainly in effect
of a decline in balances of term deposits from financial institutions by PLN252mn, but the Group did
not record any credits from financial institutions.
Financial liabilities valued at fair value through Profit and Loss Account and derivative instruments
Financial liabilities valued at fair value through Profit and Loss Account and derivative instruments
included, primarily, negative valuation of derivatives for trading or hedging and liabilities resulting
from securities subject to short sale. Value of this item, as on 31 December 2024, amounted to
PLN525mn, showing a decline by 32% relative to the balance as on 31 December 2023. The changes of
valuation (positive and negative) of derivatives has been described in above comments regarding
Group's assets.
Provisions
The value of provisions as on 31 December 2024 was PLN2,901mn which signifies strong growth by
PLN1,455mn or 101% y/y. The reason for the increase was mostly creating new provisions for legal
issues, especially claims related to FX mortgage loan agreements (increase of the balance sheet value
by PLN1,857mn not including the value of provisions directly allocated to the loan portfolio).
Debt securities issued
Securities issued by the Group amounted to PLN6,125mn as on 31 December 2024 recording significant
increase by PLN2,807mn relative to the balance as on 31 December 2023. The increase resulted from
the issue of bonds by the Bank as well as covered bonds issued by Millennium Bank Hipoteczny - the
Bank’s subsidiary.
In December 2022 the Bank issued Credit Link Notes (‘CLNs’) in the amount of PLN242.5mn within a
synthetic securitisation transaction related to corporate loans. Additionally, in 2023 as a part of
synthetic securitisation transaction, the Bank issued PLN489mn worth of CLNs, while Millennium
Leasing (a subsidiary of the Bank) issued PLN280mn worth of CLNs. In 2024 the Bank redeemed part
of CLNs issued in 2022 in the amount of PLN129mn, in line with the provisions of the transaction,
whereas the nominal value of the rest of CLNs series issued by the Bank and Millennium Leasing
remained unchanged, i.e. PLN489mn and PLN280mn respectively. Total value of CLNs outstanding on
December 31, 2024 stood at PLN883mn.
In order to meet MREL requirements, the Bank issued senior non-preferred bonds in September 2023
with a total value of EUR 500 million and in September 2024 it issued similar bonds with a total value
of EUR 500 million too, both issues under the Euro Medium Term Notes Issuance Program with a total
nominal value of no more than EUR 3 billion.
In June 2024 The Bank’s subsidiary Millennium Bank Hipoteczny (a mortgage bank) issued covered
bonds of total nominal value of PLN300mn and in November 2024 it issued covered bonds of total
nominal value of PLN500mn.
58
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Subordinated debt
The value of subordinated debt amounted to PLN1,562mn as on 31 December 2024, and remained at
almost the same level vs. 31 December 2023 (a slight difference results from interest accrued and
paid). The subordinated debt line includes ten-year subordinated bonds in PLN at the total nominal
value of PLN830mn maturing in January 2029 and ten-year bonds in PLN at the total nominal value of
PLN700mn maturing in December 2027.
Equity
As on 31 December 2024, equity of the Group amounted to PLN7,772mn and recorded an increase by
PLN877mn or 13% y/y. Apart from net profit generated in 12 months period (PLN719mn), the increase
of equity was supported by positive impact of other comprehensive income items (PLN158mn), mainly
valuation of bonds and, to lesser extent, hedge instruments.
Information on capital adequacy is presented in Chapter 11.2 of this document and in Chapter 8.2.
"Capital Management" of the Annual Financial Statements of Bank Millennium S.A. Capital Group for
the period of 12 months ending on 31 December 2024.
The non-consolidated Bank’s liabilities as at 31 December 2024 reached the value of PLN130,414 mn
million and were 10% higher compared to the end of 2023. Structure of the Bank’s liabilities and
equity as well as changes of their particular components are presented in the table below:
Bank's Liabilities and Equity
(PLN million)
31.12.2024
31.12.2023
y/y
Value
Structure
Value
Structure
(%)
Deposits from banks
323
0.2%
565
0.5%
-43%
Deposits from customers
117 643
90.2%
107 506
90.9%
9%
Liabilities from securities sold with
buy-back clause
194
0.1%
0
0.0%
-
Financial liabilities at fair value
through P&L and hedging derivat.
525
0.4%
773
0.7%
-32%
Liabilities from issue of debt
securities
5 030
3.9%
3 028
2.6%
66%
Provisions
2 900
2.2%
1 444
1.2%
101%
Subordinated debt
1 562
1.2%
1 565
1.3%
0%
Other liabilities*
2 237
1.7%
3 392
2.9%
-34%
Total liabilities
130 414
100.0%
118 273
100.0%
10%
Total equity
7 285
6 614
10%
Total liabilities and equity
137 700
124 888
10%
(*) including tax liabilities
The value of customer deposits of the Bank reached PLN117,643mn as on 31 December 2024 and was
higher by PLN385mn than the balance for the Group (mainly effect of intra-group elimination).
Deposits, similar to the Group’s case, grew by 9% y/y.
Debt securities issued by the Bank amounted to PLN5,030mn as on 31 December 2024 and were lower
compared to the corresponding item of Group’s liabilities. The difference resulted from the issue of
CLNs by the Bank’s subsidiary Millennium Leasing, which was explained above in the part related to
Group’s liabilities.
59
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The values and annual changes of other key items of non-consolidated Bank's liabilities are similar to
those of their equivalents in the consolidated reports for the Group, as discussed above in this part
of the report.
Bank’s equity, as on 31 December 2024, amounted to PLN7,285mn and recorded an increase by 10%
y/y.
Contingent liabilities
The structure of contingent liabilities of the Group is presented in the table below:
Group's Contingent Liabilities
(PLN million)
31.12.2024
31.12.2023
y/y
(%)
Total contingent liabilities
16 172
16 101
0%
1. Liabilities granted:
13 441
13 386
0%
a) financial
11 754
11 709
0%
b) guarantees
1 687
1 676
1%
2. Liabilities received:
2 731
2 716
1%
a) financial
0
0
-
b) guarantees
2 730
2 716
1%
Through these operations the Group executes transactions generating conditional liabilities. The main
items under conditional liabilities (granted) are as follows: (i) financial liabilities mainly relative to
loan prolongation (including, inter alia, not utilised credit card limits, not utilised overdraft facilities,
not utilised tranches of investment loans) and (ii) guarantees, including mainly guarantees and letters
of credit issued by the Group (to secure performance of obligations undertaken by Group’s customers
vis a vis third parties). Granted conditional liabilities result in Group’s exposures to various risks,
including credit risk. The Group creates provisions against irrevocable risk based conditional liabilities
booked in the line item “Provisions” on the liability side of the balance sheet.
As on 31 December 2024, the total value of conditional liabilities of the Group amounted to
PLN16,172mn, including liabilities granted by the Group at the level of PLN13,441mn. In 2024, the
value of conditional financial liabilities granted by the Group remained practically unchanged.
More information on the issue of conditional liabilities can be found in Chapter 12 of the Consolidated
Annual Financial Statements of Bank Millennium S.A. Capital Group for the period of 12 months ending
on 31 December 2024.
60
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
9. PRESENTATION OF BUSINESS ACTIVITY
9.1. INNOVATION AND HIGHEST QUALITY OF POSITIVE CUSTOMER
EXPERIENCE
Bank Millennium focus on building positive customer experiences at every stage of clients’
cooperation with the bank. Offering very high quality of experiences is the main guideline when
designing products and services, in sales and after-sales service - in all contact channels. Thanks to
this, in 2024 Bank Millennium strengthened its position as a quality and innovation leader in the
banking sector.
Bank Millennium's goal in 2024 was to strengthen its position in the NPS indicator and achieve a
TOP3 level.
The bank achieved its strategic goal and advanced from third to second place in NPS (retail customer)
- both in the assessment of all customers (+4 p.) and customers with the primary relationship (+7 p.).
In corporate banking, in terms of NPS, the bank took first place. This position is largely due to the
strength of corporate relationships with the bank advisors. The high recommendation score is a good
starting point for the Bank's further growth in this segment.
For years, Bank Millennium has consistently striving to ensure that the customer's transition to
electronic services supports the quality of the relationship with the Bank. We combine service
through our mobile application with access to qualified telephone and branch advisors - in all business
lines. The remote service has increased the convenience of access to the bank's products and services.
We make sure that both, customers and employees, are prepared to use and take advantage of our
digital solutions. The bank has been developing several initiatives focused on digital education and
security.
Bank Millennium uses research, and qualitative and quantitative monitoring activities, to support the
value offer and customers experience development.
Key areas of customer experience are continuously diagnosed, prioritized and forwarded for
improvements implementation, being measurement mainly based on NPS indicator.
We develop these customers and employees researches for all product lines, business lines, channels
and segments. The surveys concerned:
• satisfaction and loyalty monitoring,
• brand awareness among customers,
• evaluation of product concepts,
• employee perspectives.
An additionally important source of information in quality of service is the bank's Mystery Shopper
survey. In 2024, we conducted 2,833 audits in our own and franchise branches.
We have also implemented a new model for identifying the voice of the customer in the retail
banking, which includes:
• Mystery Shopper survey results,
• CSAT,
• Google reviews,
• analysis of complaints caused by the branch.
We analyze the collected voice of the customer and use it to stimulate the elimination of the causes
of dissatisfaction, to further improve the customer experience.
61
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Bank Millennium has established a field team of CX Leaders to support managers in carefully
listening the voice of customers and improve the customer experience offered. CX Leaders also
work with advisors and help to highlight elements that negatively affect customer interaction and
should be overcome.
Thanks to this program we have observed a decrease in complaints with route causes driven by branch
service and an increase in customer satisfaction in the CSAT survey.
Bank Millennium continues to work on simplifying the language used in communication with
customers and the content of all documents. We have been improving the texts provided to
customers, from the moment of opening an account to the information on the use of their products.
We also continue training employees in plain language standards: in 2024, we trained another 100.
At Bank Millennium, we build strong awareness around the importance of plain language in
communication, a perfect example of which are the activities organized as part of the Plain Language
Day.
In addition to the quality of products and channels service NPS is determined by the image and trust
in the Bank, as well as the experience of employees. This way, we also measure employees
experience. The overall participation rate in the employee satisfaction survey completed in 2024 was
63% (12 p.p. higher than a year ago). 76% of respondents were generally satisfied with the Bank - an
increase compared to both the Polish (39%) and banking (62%) benchmarks. Overall job satisfaction
does not differ significantly in terms of areas, roles, locations or work experience.
The results of the employee satisfaction survey provide material for teams throughout the
organization. Meetings of employees with members of the management board organized in the bank
are a source of inspiration for further improvement of internal processes and ideas that can increase
customer satisfaction with the offer and service.
In 2024, Bank Millennium was recognized in the most important quality rankings. It won awards
for service quality in the areas of retail, affluent and business customers:
• first place in both categories of Newsweek's Friendly Bank ranking: traditional banking and remote
module,
• podium in Forbes magazine's Company Friendly Bank Ranking,
• podium in Forbes magazine's Ranking of Banks for the Wealthy Customer,
• podium in the Golden Bank ranking in the Best Multichannel Service Quality category,
• one of the finalists of Forrester's global ranking of “Customer Obsessed Enterprise 2024 Awards”,
• distinction of NPS® Loyalty Leader - current & savings 2024 (NPS Prism Global Banking Report).
9.2. RETAIL BANKING
Current Accounts
Number of active clients has reached almost 3.15 million with growth of active clients of over 145
thousand in 2024 alone.
Sales of current accounts in 2024 amounted to almost 393 thousand. The key acquisition product was
flagship Millennium 360°account. The number of accounts in the Bank's portfolio reached 3.62 million,
with 23% share of Millennium 360º account. After 3Q24, the Bank achieved a market share measured
by the number of accounts at the level of 9% (according to the Puls Biznesu report).
The promotion and acquisition of Millennium 360º accounts in 2024 was supported by:
• advertising campaigns on television and the Internet (including online campaign dedicated
strictly to young clients at age of 18-25 years old);
62
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
• activities using the goodie shopping application and in cooperation with external web portals
- nearly 40% of Millennium 360º accounts were opened online;
• new edition of the "Like it? Share it!" recommendation program.
Saving and Investment Products
Year 2024 was a period of high market interest rates and record high growth of retail deposits. In
2024 retail deposits in whole banking sector grew by almost PLN119bn., of which current and saving
deposits increased by PLN99.5bn, with PLN19.1bn growth of term deposits. In this market situation,
the Bank focused on placing deposit offer in both savings accounts and term deposits in a way that
allows volume growth while taking care of portfolio profitability.
New volumes were acquired mainly on Profit saving account but also on new money time deposits
with attractive remuneration. Parallelly to increased deposit acquisition we have improved retention
offers both in digital channels and branches.
Total retail deposits in Bank Millennium in 2024 increased by PLN11.5bn to the level of PLN92.9bn
(individual clients and microbusiness) and market share at the end of December 2024 was 7%.
In terms of investment products year 2024, was time of very positive sentiment on global capital
markets. Especially debt investment funds attracted substantial volumes and showed yields
competitive to deposit rates. In total, the investment assets of the bank's clients invested in mutual
funds and investment-insurance funds increased by nearly PLN3bn and amounted to nearly PLN10.8bn.
The Bank continued its strategy to offer diversified portfolio of investment products including both
own solutions and products offered by external partners. Depending on client segment the offer
included structured products, mutual funds and bonds.
The Bank continued activities promoting regular investments especially through investment advisory
service based on selected and adjusted Millennium TFI funds (mutual funds) which in easy and
convenient way enables customers entrance to investment products even of small amounts. During
2024 around 20 thousand new customers decided to invest through advisory service, number of
customers investing regularly increased to around 50 thousand.
In order to make the offer more attractive, during the year the Bank launched cyclical promotions of
funds with regards to the fee for their purchase. A special strategy was also continued to reward the
use of remote channels by reducing to 0% the handling fee rates for purchase of selected TFI funds
through Millenet and Mobile Application
Cash Loans
In the field of cash loan sales, the Bank may consider 2024 to be a successful year. Compared to the
previous year, in 2024 sales of loans for any purpose to individual customers increased by almost 11%
and amounted to over PLN 7.0 bn. Bank’s market share was 9% in loan sales and 8% in the loan
balances. Remotely initiated sales in the telephone channel increased by 23%. The Bank's franchise
partners also recorded 9.5 % increase in sales. Both good results were delivered based on the offer
which is increasingly better suited to the needs of the Bank's current customers and that the processes
of remote customer service. On the other hand, the Bank actively acquired new customers. An
important source of sales for new loans was also the developing cross-sell to customers acquired
through instalment loans. The Bank also places great emphasis on the development and improvement
of electronic channels, in particular the mobile application. Already almost 75% of loan sales ended
in digital channels, which was an increase of another 4 percentage points compared to 2023. The Bank
also conducted an active pricing policy, providing customers with attractive promotions and special
offers throughout the year.
63
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Overdrafts
Despite a slight market loss in the sale of account limits (8.1%, a decrease compared to 2023 by 2.9
pp), the Bank increased its market share in the credited balances to 13.5% (+0.11pp). This means that
customers are more willing to use the credit limit offered by the Bank.
Insurance products (bancassurance)
In 2024 the Bank continued its strategic insurance cooperation with Europa Insurance Group, providing
long-term development of bancassurance in relation to specific insurance related to credit products.
The Bank expanded its offer with new value propositions, including travel insurance for customers
travelling with Visa Global credit card, with convenient insurance claim reporting directly in the
mobile application.
Payment Cards
In 2024, there was another significant increase in the payment cards portfolio, both in terms of the
number of cards issued and transaction volume.
The Bank maintained the upward trend in the payment card portfolio with the result of 4.0 million
cards at the end of December 2024 (+1.6% y/y). The turnover in 2024 amounted to PLN 82.632mn on
debit cards (+11% y/y) and PLN 7.453mn on credit cards (+12% y/y). This result was supported by new
product solutions, including among others activation of Google Pay mobile payments directly in mobile
application. From July 1, 2024, multi-currency solutions have been made available to customers: a
currency exchange office and the ability to pay in foreign currencies directly from a currency account
by connecting a debit card to a currency account. This way, customers will not pay currency
conversion fees. Additionally, the currency limit has been increased to PLN 5,000. This is the monthly
amount of transactions in foreign currencies for which the Bank will not charge a currency conversion
fee.
From July 1, 2024, the Bank withdrew the HCE payment method, offering customers BLIK contactless
payments or virtual wallets that allow tokenized card payments.
At the end of December 2024, the credit card portfolio increased to 518 thousand cards and increased
by 24 thousand cards (+4.9% y/y). This allowed Bank Millennium's market share to increase to 10.2%
in 3Q24. Thanks to intensive portfolio activities, Bank Millennium's market share in spending increased
in 3Q24 to 10.6%.
Mortgages
In 2024, a gradual increase in customer interest in mortgage loans was observed on the market. The
bank concluded over 13,900 new commitments with a total value over 5.8 billion PLN. (increase of
almost 17% y/y) and ranked 6th in the market with a sales share of almost 7%. The market noticed a
deceleration in the 2H2024 of the year relative to sales in 1H2024 (down 14%), also an observable
decline in sales in 2H2024 relative to 2H2023 (down 9%).
The Bank implemented a number of projects, including regulatory ones, as well as further
improvements in the process of granting and servicing loans i.a.:
• increasing support within the Borrower Support Fund – amount and period of support
• possibility of using the Borrower Support Fund by flood victims
• Installment repayment deferral for flood victims
• implementation of PESESL verification in the credit process, which increases the financial
security of customers
• expanding information for customers before making a decision to use loans under the
amended Recommendation S
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The Bank's lending campaign, similarly, to last year, was based on the offer of unconditional 0%
commission for granting a loan and 0% commission for early and full repayment of the loan.
The Bank continued its activities to further reduce the CHF loan portfolio, offering customers
individual conditions that favor currency conversion and partial and full repayment of these loans.
Prestige and Private Banking segment - offer for an affluent clients
In 2024, the Bank continued its strategy in the development of an offer particularly important for
wealthy clients:
▪ in July, the currency exchange available in the mobile application along with a multi-currency
service for debit cards was launched, the currency package was withdrawn and at the same
time the amount for which the Bank does not charge an additional margin for currency
conversion of card transactions in foreign currencies raised to 5.000PLN per month,
▪ in October, VISA Global credit card offer was launched along with attractive benefits,
including Safe Travel insurance. With the implementation of the new product, the conversion
process available in remote channels has been made available.
In 2024, the Bank continued its policy of serving affluent clients: individual Prestige Experts are
available to customers not only in the traditional model but also fully remote. Using digital channels,
experts support clients in everyday banking and in important financial decisions while developing
relationships.
Affluent clients in the Bank are customers with PLN200 thousand of assets or PLN20 thousand of
inflow per month. At the end of 2024, number of affluent clients was 152.7 thousand, growing annually
by 21%.
In Private segment, the number of customers at the end of December 2024 was 4.7 thousand. The
condition for entering the Private segment is at least PLN1 million of assets deposited with the Bank.
Biznes Client segment
Business offer is addressed to individuals running sole proprietorship businesses, partnerships and
commercial law companies with annual revenues up to PLN5 million.
In 2024, the number of new accounts for Business customers increase of 24% compared to 2023,
reaching nearly 46,000 new accounts. This growth was achieved thanks to the following initiatives,
among others:
• introduction of an enquiry about interest in an account for a company during the retail
account opening process
• launching a real-time telephone campaign in the event of abandonment of an online account
application
• enabling the opening of another business account through Millenet or the mobile application
• the functioning of special offers for customers opening online accounts and new Business
customers
• the introduction of acquisition campaigns based on activities on the client's account that
indicate the possibility of the client doing business
In 2024, 77% of company accounts were opened online.
Business Bank's customers are offered a wide range of transactional and credit products, with a
particular focus on the attractive Millennium Accounting offer, payment terminals and leasing, as well
as modern online and mobile banking.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
In the second quarter of 2024:
• we made available to our e-commerce customers, the Millennium PAY payment gateway,
which makes it possible to accept electronic payments in online shops
• we offered customers starting an e-commerce business the opportunity to set up an online
shop on the Sellingo platform with the Millennium PAY payment gateway, which they can test
for 6 months for free.
In the third quarter of 2024, the Bank further developed the “Millennium Księgowość” (accounting)
service by introducing additional transfer facilities.
In the fourth quarter of 2024, the Bank made available the possibility of ordering a debit card through
digital channels.
The acquisition of corporate accounts was supported by strong promotional and advertising activities
including:
• 2 TV campaigns for Konto Mój Biznes together with the Millennium Account promotion
• a non-standard marketing campaign ‘Feel the sport in business’ in which we started regular
cooperation with influencers
• broadcast radio campaign strongly focused on acquisition, in which we promoted promotions
for Konto Mój Biznes
• a digital campaign leading directly to the opening of the My Business Account
online/enterprise and to the use of additional services.
In 2024, the value of credit products sold to Business customers increased of more than 4% compared
to 2023 and reached PLN1,035 million, thanks to:
• a further increase in the use of de minimis guarantee. In 2024, 93% of the value of loans was
covered by BGK’s de minimis guarantee
• the implementation of a new risk methodology and decision engine allowing for a better
assessment of the credit risk of the exposures granted
• introduction of an automatic renewal process of overdrafts secured by de minimis guarantee
In 2024, nearly 50% of all credit agreements were signed in Millenet or the mobile app.
Mobile and online banking
Bank Millennium consistently continues its "mobile-first" approach, which puts mobile banking at the
center of its activities. The banking app is now one of the most important applications on customers'
phones. In 2024, the number of logins to the mobile app exceeded one billion. We ended 2024
with 2.9 million active digital users, of which as many as 2.65 million are customers using the mobile
app.
The year 2024 was marked by three key projects in electronic banking. Firstly, in May, the Bank,
in collaboration with the Polish Payment Standard, launched a new solution in the BNPL model, called
BLIK Płacę Później (BLIK Pay Later). At the beginning of the summer, customers gained access to
a currency exchange and a multi-currency service for their cards in the mobile app. In 2024, the
app's design was refreshed, including navigation, menu, and product pages.
Starting in July, the Bank stopped supporting contactless payments using HCE technology directly
within the mobile app. Customers can now use alternative and more modern solutions: BLIK
contactless payments or virtual wallets that allow tokenized card payments.
Significant attention in 2024 was devoted to government and regulatory projects, including new
applications for Active Parent and benefits for people with disabilities, as well as verifying restricted
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
PESEL numbers, AML surveys, statutory mortgage holidays, and support for borrowers affected by the
September floods. In the third quarter of the year, the bank, in collaboration with KIR, offered its
clients the option of using a mobile signature for identity verification (mSzafir).
In 2024, the Bank also developed solutions for businesses and corporations, with a particular focus on
mobile banking in these segments.
Retail and business customers digital activity
2024
2023
change
Active digital users
2,905,039
2,701,645
+8%
Active mobile users
2,653,201
2,473,365
+7%
BLIK payments users*
2,298,144
2,033,538
+13%
* Customer at least one used at least one BLIK service in 2024.
DIGITALISATION
The goal of the "Inspired by People" strategy, which concluded in 2024, was to achieve 90%active
customers in digital channels. This goal was reached by the end of 2023, thanks to efforts made as
part of the digitalization project. In 2024, these efforts continued, and currently, the share of
customers actively using the bank's digital channels is 92%.
To achieve success in digitalization, electronic banking channels work closely with traditional
channels. Reliable technology combined with a human touch is the direction taken in the new strategy
for 2025-2028, as well. In this approach, the role of branch staff and contact center consultants is
crucial, which is why they receive support during regular meetings and webinars, including as part of
the Digital Ambassadors project. The Bank is also enhancing the digital onboarding of new customers,
which includes not only education through digital channels, but also support from Bank employees.
As part of digitalisation, the Bank aims not only to activate new-to-bank users but also to increase
the digital engagement of existing customers. To achieve this, we employ a personalized approach
customized to the activity and needs of the user, who, at the right moments, learns about the
possibilities of digital channels, is educated of cybersecurity principles, and receives support in sales
processes, for example, through contextual chat.
The primary differentiator in the market is now the customer experience, which is why the banking
app and Millenet are designed in collaboration with users. The Bank conducts research and testing in
an in-house UX Lab, simplifies communication according to plain language standards, develops its
Design System, and carries out accessibility audits with an external NGO Partner – “Fundacja
Widzialni”. As a result, the digital channels of Bank Millennium combine convenience, security, and
reliability.
Within the UX Lab, user behaviors are analyzed, interviews are conducted, and test sessions are
organized to better understand customers' needs and expectations, ensuring intuitive and effective
user experiences. In 2024, the UX Lab was equipped with new research tools, such as the IQS panel
for quantitative research and access to the OMNISURV platform, which enables external marketing
research on nationwide samples or selected target groups (with the added feature to present
descriptive, graphic, and video materials). An AI-based attention distribution prediction tool was also
introduced. In the UX Lab, both new functionalities and updates to existing solutions are tested.
An important aspect of the Bank's activities is hyper-personalisation. The Bank is implementing a
new AI-based system that will allow for real-time digital path to meet customer needs.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
DAILY BANKING
Work on digital solutions never ends; it continues as long as they are available to customers. The Bank
constantly improves the mobile app and online banking to meet users' expectations and needs every
day. Designers view processes through the eyes of customers and propose changes that are genuinely
necessary. In the past year, many such enhancements have been implemented in daily banking.
In 2024, one of the more significant projects for the bank was refreshing the mobile app. From the
customer's perspective, the changes were subtle but allowed for better alignment of the app’s
navigation with users' feedback as well as current trends in UX/UI design. The menu and product pages
were redesigned. New options emerged, such as the ability to check payment card details, as well as
educational banners that draw users' attention to secure banking rules. These changes were tested
with users before being widely released. All customers could download the refreshed app in October.
The update did not result in a change in app ratings in stores. Currently, users rate the app at 4.8 (out
of 5) on Google Play and App Store, while the rating reaches 4.9 (out of 5) in Huawei App Gallery.
The app also introduced new forms of contact with the Bank. The contact panel with consultants
across processes was standardized (direct calls or chat directly from the process). The chat feature
has been enhanced with AI, which accelerates customer support for the most common inquiries while
allowing consultants to address more complex issues more quickly. The app also includes a built-in
map of branches, ATMs, and deposit machines. The map allows users to find a selected location using
search filters or their current location and to set a route to the chosen destination.
In the first half of 2024, we completed the rollout of the new transaction history in the mobile app.
After the changes, customers have all transactions in one place, along with additional functions
accessible via shortcuts from the transaction details.
PAYMENTS, E-COMMERCE, AND VALUE-ADDED SERVICES
The bank expands the available forms of mobile and online payments, as well as additional services
offered in electronic banking. In May 2024, deferred payments in the BNPL model (But Now Pay Later)
were introduced for the clients. The BLIK Pay Later service is based on the same scheme as payments
with a BLIK code—transactions are equally quick and intuitive. As a result, this new solution has the
potential to dominate the deferred payments market in Poland. Deferred payments mark another
step toward merging banking services with the rapidly growing e-commerce sector.
BLIK is currently the most popular payment method in online stores. In 2024, almost 2.3 million of our
customers used BLIK services at least once.
The bank promotes contactless payments via mobile devices. By mid-year, the migration from the
old, less efficient HCE payment method was completed. Customers can now use BLIK contactless
payments, as well as Google Pay, Apple Pay, Fitbit Pay, and Garmin Pay. By the end of December
2024, over 1.2 million customers had payments via their phones, watches, or fitness bands activated.
The Bank is also developing its foreign currency payment services. Before the summer of 2024, the
foreign currency limit for cards was increased from PLN 1,000 to PLN 5,000. We have introduced
a currency exchange in the mobile app, allowing users to receive notifications about current exchange
rates. Available currencies include EUR, USD, CHF, and GBP. Customers can open a free currency
account in the app and link it to their existing debit card for their current account.
The Bank is promoting and developing value-added services (VAS). In 2024, customers gained the
ability to purchase gift cards and codes from new suppliers (Amazon, Netflix, and Steam) within the
app. Top-up codes are particularly popular among younger customers.
The Bank confirms and expands its competencies in the field of digital marketing. At the end of 2024,
Bank Millennium became a member of IAB Poland, an association bringing together companies
operating in the interactive, technology, and advertising sectors in the Polish market.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
ONLINE PRODUCTS, SALES, AND ACQUISITION
In the mobile app, new customers can open an account using a "selfie". On the Bank's website, we
offer a process that involves logging in to another bank, based on open banking solution. Additionally,
a new customer can open an account while applying for a cash loan through the Bank's website. Bank
customers can also open new accounts after logging into the mobile app and Millenet. In 2024, the
share of digital channels in account acquisitions reached 43%, while the share of digital channels in
sales of accounts for children was nearly 56%. In 2024, the Bank was once again recognized in the
Institution of the Year ranking for the "Best Remote Account Opening Process."
Work on processes in digital channels is continuous, and even minor changes can enhance user
experience and impact business outcomes. The omnichannel credit card application implemented a
year earlier received exceptional customer recognition in 2024 and was also awarded at the
international PayTech Awards competition.
In 2024, the bank expanded solutions to support customers in self-investing their funds. The app
introduced a new investment hub, which is a page where customers can access all available
investment products in one place. Changes were also made to the robo-advisory process, aimed at
facilitating customers' informed decisions regarding starting investments. The bank promotes regular
saving using standing order functionality.
Customers with cash loans or installment loans gained options in the app for easier management of
their obligations: the ability to change the repayment date of cash loans or installment loans, as well
as an application for “credit holidays” from cash loan repayments. Both options are easily accessible
via shortcuts on the product page. Previously, customers could only change the repayment date or
submit a request for a repayment break through Millenet. In 2024, the share of digital channels in the
number of sold loans reached 83%.
Customers with mortgage loans could extend statutory mortgage holidays through online banking. The
application in Millenet was expanded to include new conditions that applicants had to meet according
to the provisions of the law.
PUBLIC SERVICES
The Bank's strategy ensures full accessibility of public services through mobile banking. Currently,
customers have access to applications for Rodzina 800+, Dobry Start 300+, RKO, and Aktywny Rodzic,
which from October has replaced the previous subsidy for nurseries. In 2024, the bank also made
available in the mobile app and Millenet application for a benefit for people with disabilities. Other
solutions offered through digital banking include Millennium ID (based on mojeID), integration with
the mObywatel application, the registration process for sole proprietorships, and the mobile signature
mSzafir (through KIR).
CYBERSECURITY
The number of digital banking services continues to grow, which is why the bank is constantly
enhancing the security of access to electronic channels and ensuring an appropriate level of
protection against current fraud schemes. A sense of security is one of the crucial factors that promote
digitalization.
The Bank educates customers about cybersecurity rules through regular campaigns and on its website,
participates in sector-wide initiatives, and provides security measures and tools that enable users to
ensure their safety in everyday situations, such as temporary card blocking, identity verification
within the app, biometric login, or transaction limit management. In 2024, an additional authorization
was introduced for logging into the Millenet online banking system. Users must confirm each login
using Mobile Authorization or SMS Password (depending on the chosen method of authorization).
Previously, such additional authorization was required every 90 days.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Many security mechanisms operate without the customer's awareness, ensuring constant system
safety. A new feature in 2024 was the implementation of solutions that detect remote desktop
management applications (to prevent "vishing" fraud) and new rules for detecting suspicious
transactions.
A key project related to the security of online banking services was the introduction of PESEL number
verification. According to current regulations, the Bank is obliged to check whether a customer's
PESEL number has been restricted, for example during the account opening process or in credit
product applications. This solution was implemented at the bank starting June 1, 2024.
Another regulatory project was the verification of customer data in accordance with KYC (Know Your
Customer) regulations as part of AML (Anti-Money Laundering) regulations. Customers could
conveniently confirm their data through electronic channels via a survey, accessed directly from
campaigns or informational banners.
AFFLUENT CLIENTS
In 2024, the Bank focused heavily on refreshing its offerings for affluent clients, with these efforts
being integrated into projects executed through digital channels. In the fourth quarter of 2024, clients
were offered a new VISA Global card with additional services (access to airport lounges, currency
services, and cashback on purchases). The card is linked to Safe Travel insurance, allowing clients to
easily contact the insurance company directly through the banking app. By January 2025, the offering
was expanded with the new Millennium 360 Prestige account. All new services and products are
accessible through digital channels. Clients can convert their existing current accounts into new
Prestige accounts directly within the app. In just a few steps, they can also exchange their credit
card for a VISA Global card and purchase the “Twój Asystent Prestige” insurance in one process.
SUPPORTING FLOOD VICTIMS THROUGH DIGITAL CHANNELS
In September 2024, Poland was struck by tragic floods that affected clients in the southwestern parts
of the country. The bank, in collaboration with the Polish Red Cross and Caritas Polska, facilitated
assistance to those impacted by the flooding. In the mobile app, clients could provide their support
through the CharityTransfer feature. The client uses a pre-filled form, eliminating the need to enter
the account number or the title of the transfer. They simply select the organization and enter the
amount, and upon confirming the transfer, the money is sent directly to the chosen organization’s
account. Through the Bank Millennium app, clients donated PLN1.54 million. The Charity Transfer
feature was first introduced in the app following the outbreak of the war in Ukraine in 2022.
Additionally, borrowers affected by the floods were given access to an application for non-repayable
assistance from the Borrower Support Fund through online banking. This application was made
available at the bank on October 7, alongside the launch of the government program. The
implementation took only a few days.
DIGITAL SOLUTIONS FOR BUSINESS
Developing offerings for clients running their own businesses is an area of increasing significance for
the Bank each year. The comprehensive online banking services and additional tools for running
a business respond to the needs of this group at every stage of building a competitive enterprise. We
are building processes where electronic channels play a dominant role but are supported by remote
experts. Options available for business clients include:
• A process for opening a business account using open banking,
• The ability to register a company along with opening a business account through online
banking and the mobile app,
• Millennium Accounting,
• The Millennium POS app, which transforms a smartphone into a payment terminal,
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
• A complete online application for a cash loan with a de minimis guarantee,
• A payment gateway linked to an online store.
In 2024, one of the key implementations was the launch of the Millennium PAY payment gateway (in
partnership with PayTel), which serves customers building their businesses in e-commerce. The
gateway can be easily linked to their online store - the Bank has prepared an option for micro-
enterprises to create their own store on the Sellingo platform.
The Bank is enhancing solutions offered in previous years. Clients who register their businesses
through theBbank's process can receive real-time accounting support via panic button. Additionally,
the accounting service has been enhanced to include the ability to make predefined transfers. The
app also added the option to connect with a consultant directly from the cash loan application,
allowing clients to receive real-time expert assistance from the Bank.
Furthermore, in 2024, clients gained the ability to order a debit card for their business account
through electronic channels, as well as to open another Konto Mój Biznes account, optionally with
a new VAT account and a new debit card.
AWARDS AND HONOURS
The digital solutions of Bank Millennium are recognized both in Poland and in international rankings:
• Newsweek's Friendly Bank – 1st place in the Remote Banking category
• 2024 Global Finance Best Digital Bank Awards – and other 13 titles for retail and corporate
digital solutions, including:
- Best Digital Consumer Bank in Poland
- Best Information Security and Fraud Management in Central and Eastern Europe
- Best in Transformation in Central and Eastern Europe
- Best Online Product Offerings in Poland
- Best User Experience (UX) Design in Poland
- Best Mobile Banking App in Poland
- Best Information Security and Fraud Management in Poland
- Best in Lending in Poland
- Best in Transformation in Poland
- Best SME Banking/SME Platform in Central and Eastern Europe
- Best SME Banking/SME Platform in Poland
- Best Trade Finance Services in Poland
- Best Information Security and Fraud Management in Poland
- Best in Transformation in Poland
• Institution of the Year 2024 - Best Remote Account Opening Process
• Institution of the Year 2024 – 2nd place for the mobile app
• Institution of the Year 2024 – 4th place for internet banking
• Golden Banker – 2nd place in Electronic Banking (online/mobile)
• PayTech Awards – Best Consumer Cards Initiative for Omnichannel Credit Card Application &
Digital Service
• Global Finance The Innovators - Top Innovator in Finance 2024 for Best UX for Corporates (for
Bank Millennium for Companies mobile app)
• Mobile Trends Awards – Nomination for the Bank Millennium app for companies
• The Digital Banker Global Retail Awards 2024 – Best SME Mobile Banking App
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
9.3. CORPORATE BANKING
As part of Corporate Banking, we professionally and comprehensively provide services to companies
with annual sales revenues exceeding PLN 5 million as well as public sector institutions and entities.
Our objective is to assure the highest quality of service and the shortest time for our reaction.
Therefore we are consistently automating our internal processes relating to customer service. At the
same time we support our clients in implementation of projects reducing the environmental impact
of their businesses, by financing projects connected with renewable energy, innovations reducing the
demand for energy and natural resources and more effective waste management.
We provide each client with the care of a permanent team of experts. Relationship Managers, who
are the first line of contact with the client, are supported by product specialists in transactional
banking, treasury products, trade finance products and leasing as well as FX dealers. In the area of
support for digital channels, including host 2 host solutions, clients are supported by a team of
electronic banking experts. In operational issues support is provided by specialists in transactional
systems and consultants. The team working with the clients is augmented by experts in funding
mergers and acquisitions as well as experts in EU funds.
The high quality of service is confirmed by the results of the annual survey of corporate banking
customer satisfaction. In the third quarter, we conducted a satisfaction survey of corporate banking
customers. As many as 85% of the surveyed customers are very satisfied with the support of our
Relationship Managers (NPS RMs 77), and 88% are very satisfied with the ongoing operational
cooperation with Consultants. The Bank's NPS for the corporate banking line was 47 points. These
results confirm our high competence and commitment to ensuring the highest quality of service
processes. At the same time, the results of the survey are feedback from our customers, setting the
directions for further work on our product portfolio and the development of digital services offered
to customers.
CORPORATE BANKING PERFORMANCE
At the end of 2023, we met the capital requirements, thanks to which we began to return to the
growth of loan volumes, reversing the previous downward trend. At the end of 2024, this resulted in
an increase of PLN 0.6bn (4.5%) to the level of PLN 14.0bn. In 2024, the volumes of new credit products
increased by 47%. For individual product areas, the levels were as follows: increase in loans by 49%,
factoring by 62%, leasing by 37%.
On the deposit side, we focused on improving the deposit margin, which increased by 0.21%, with a
decrease in volume by 6.6% to PLN 23.9bn. The number of payment cards increased by 11.5% to over
100 thousand.
COMPREHENSIVE PRODUCT OFFERING
We create flexible financial solutions tailored to the nature of a specific company's business. We
support them with modern digital solutions conducive to automation and optimisation of the work of
financial departments of companies, including minimising operational activities related to
cooperation with the bank.
Digitalisation of customer service processes
We digitalise processes, which allows us to reduce paper documentation. In 2024, 66% of credit
agreements were signed using a qualified electronic signature, 84% of guarantees were issued in the
form of e-guarantees, 84% of applications for bank accounts and 39% of applications for payment cards
were submitted in digital form.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The option to conclude transactions in the Millennium Forex Trader electronic online currency
exchange platform has been enjoying greater and greater interest among clients. Already 74% of
transactions are carried out via online banking and the mobile application.
The share of customers using Millennium Leasing's eBOK is consistently growing – at the end of
December it was already 95% of leasing customers. Since the beginning of the year, electronic
applications regarding the handling of contracts and leased items have accounted for 61% of all leasing
applications submitted by customers, while 51% of lease agreements in the corporate banking segment
have been signed electronically.
In the Documents Module in Millenet for Companies, which is used for bilateral exchange of documents
between us and the client via the online transaction service, we have doubled the number of
processed documents compared to 2023.
FLEXIBLE FINANCING
With our products, we support environmentally friendly solutions, energy transformation, innovation
development and at the same time respond to rising electricity prices.
Entrepreneurs can take advantage of credit products and leasing of green assets. We equip
relationship managers with practical competences in the field of broadly understood ESG, which allow
them to effectively identify key issues related to green transformation and sustainable development,
better understand the perspective of companies and their needs.
We support entrepreneurs in accessing financing. By participating in the guarantee programmes of
Bank Gospodarstwa Krajowego, we facilitate access to financing for entrepreneurs.
De minimis guarantees
The de minimis guarantee can secure up to 60% of the loan amount granted to companies from the
small and medium-sized enterprise (SME) sector, and the maximum amount of the guarantee is PLN 5
million (the amount of the individual guarantee and the sum of active guarantees at the lending bank).
The commission rate for the guarantee granted is 0.5% of the guarantee amount on an annual basis.
The maximum period of a guarantee is 60 months for working capital loans and up to 120 months for
investment loans.
Biznesmax Plus guarantees
Free Biznesmax Plus guarantees secure up to 80% of the loan amount financing innovative and eco-
innovative investments. Companies from the SME segment have the opportunity to apply for subsidies
to:
• interest of 5% of the loan amount per annum, for a period of 24 months in the case of working
capital loans, or
• principal at 20% of the loan, in the case of an investment aimed at the digital transformation
of enterprises or
• principal in the amount of 10% in the case of implementation of an innovative or eco-
innovative investment.
The offer of loans with Biznesmax Plus guarantees is available to entrepreneurs from the SME sector,
small mid-caps and mid-caps. Preferences related to subsidies are available only to companies from
the SME segment.
Ekomax guarantees
Our offer also includes investment loans with Ekomax guarantees, which can secure up to 80% of the
loan amount financing energy efficiency projects, consisting in thermal modernisation of buildings or
reduction by at least 30% of primary energy consumption. The offer is available to entrepreneurs from
the SME sector, small mid caps and mid-caps. Companies from the SME segment can take advantage
of capital subsidies of the loan principal amount of 20%.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Investmax guarantee
The Bank's SME customers can use the new Investmax guarantee. It will make it easier for
entrepreneurs to access working capital and investment loans. The Investmax guarantee is designed
for entrepreneurs in the SME sector, with a particular focus on micro-entrepreneurs. For them, the
guarantee under the microfinance formula is provided free of charge. In other cases, the fee for
granting the guarantee is 0.3%. The Investmax guarantee can secure 80 per cent of the principal of a
working capital or investment loan.
Benefits of BGK guarantees
Thanks to public-funded guarantees, we offered our clients a longer than standard financing period
in the case of working capital loans, and in the case of investment loans, we reduced the borrower's
minimum own contribution to 10 percent. For the sake of "green financing", we have waived the
collection of the origination fee.
Financing with the support of the Korporacja Ubezpieczeń Kredytów Eksportowych
We expanded the loan guarantee offer of Korporacja Ubezpieczeń Kredytów Eksportowych (KUKE)
Corporate Banking clients have the option of extending the KUKE guarantee to repay loans granted to
exporters for their investments in Poland and to exporters who apply for a loan to finance their current
operations, including the refinancing of their existing loan. This guarantee is available to customers
who have generated export revenues of at least 20% of total annual average revenues over the last
three out of the last five years. The guarantee can secure up to 80% of the loan amount. There is no
limit to the amount of the guarantee. A working capital loan secured by a guarantee can be granted
for a maximum of 12 months, while an investment loan for a maximum of 14 years.
Factoring and trade finance
The KUKE guarantee can also be used to secure reverse factoring, recourse factoring and receivables
financing transactions. The guarantee is granted at the request of the customer who is an exporter
and can be used to cover up to 80% of the client's liabilities under the agreement, including the
amount of outstanding financing as well as interest and commission.
In the area of trade financing, KUKE counter-guarantees can be used as collateral for contractual
guarantees issued by us, such as: advance payment guarantee, contract performance
guarantee/defect removal guarantee/warranty for defects and quality guarantee (including with and
without a reduction amount) and tender guarantee.
TRANSACTIONAL AND ELECTRONIC BANKING
We have introduced further solutions and improvements helping clients to manage their company's
finances even more efficiently and conveniently.
Electronic banking for corporate clients
We are developing our offer for enterprises in accordance with the strategic approach that it should
consist of three pillars: a universal browser-based system, a convenient and intuitive mobile
application, and solutions supporting direct integration with clients' financial and accounting systems.
Working with clients in the corporate area is particularly demanding given their diversity – from small
and medium-sized companies to large corporations and government agencies. We improve digital
solutions in response to customer needs, which we get to know, among other things, through
interviews and tests with users.
In 2024, we made changes to the documents module to make its operation more intuitive. We
expanded the service of working capital, investment and revolving loans in Millenet for Companies.
We added a view of loan details, repayment history, instalment schedule, information about interest
rates or possible debt. Customers now have full knowledge of their obligations immediately after
logging in. We also improved the visibility of accounts in Millenet for Companies in response to
customer requests.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Mobile application
We are expanding with new features the mobile application for business customers released in 2023.
In 2024, we enriched it by adding payment card options (activation, limit and security management
options, including temporary card blocking or restriction and PIN change), deposit management
functionality, direct consultant connection, transaction notifications. Since its launch, Bank
Millennium dla Firm has been the best-rated application in Poland as regards bank mobile applications
designed for enterprises. At the end of 2024, 35% of corporate customers actively using electronic
banking were active users of the mobile application.
Millennium PAY payment gateway
We have launched the Millennium PAY Payment Gateway, which is integrated with the largest open-
source platforms (WooCommerce, PrestaShop, Magento) and gives the possibility of individual
integration when customers use their online shops. Thanks to cooperation with Sellingo, customers
also get the opportunity to create and run an online shop.
eBOK Millennium Leasing in Millenet for Companies
We have expanded the functionalities of the eBOK service with a transparent history of settlements,
including all issued invoices along with recorded customer payments, current balance and balance
after each operation. Thanks to this, customers can check the moment and the reason for arrears or
overpayments and control the status of their settlements at any time.
Transactional Banking
Deposit Machines
We have piloted a new solution to automate cash processes at our clients - the so-called "deposit
machines". The device works similarly to a cash deposit machine. It identifies the depositors,
calculates the deposit, and issues a confirmation. Information about the deposit is electronically
transferred to the bank and automatically posted. Such a process provides the customer with quick
access to cash on the account, reduces the cost of preparing deposits and the number and cost of
convoys.
Residential Escrow Accounts
We have implemented changes to Open and Closed Residential Escrow Accounts (MRP), which enable
the handling of payments under construction projects whose sales began before the entry into force
of the so-called new Developer Act and are continuing after the transitional period provided for in
this Act.
The provisions of the new Developer Act impose different requirements for construction projects
whose sales began during the validity of the old Developer Act, and different requirements for the
period after the so-called transitional period, which ended on 1 July 2024. Our Residential Escrow
Accounts meet all statutory requirements, enabling developers to maintain the continuity of sales
started before the Act was introduced.
WE SUPPORT CLIENTS THROUGH EDUCATIONAL ACTIVITIES
We support our clients in the challenges they face. We provide up-to-date macroeconomic
information; every week we present a summary and analysis of the most important events from the
domestic and foreign markets. We constantly educate on IT security and fraud risk, and provide
information about available assistance programmes.
We provide information through the Inspiration Zone in the Millenet for Companies transactional
system and, among others, in the form of webinars with the participation of internal and external
experts, presentations by the Bank's experts during conferences and meetings of which we are
partners.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
We cooperate with the CFO Club of ICAN Institute
CFO Club is a development and networking initiative bringing together financial directors (CFOs). The
CFO Club provides access to current knowledge, it is also a platform for exchanging experiences and
networking. The topics discussed during webinars, meetings, podcasts and articles are related to the
most current challenges faced by financial departments in companies: green transformation, ESG,
obtaining public funds for the development of companies, cybersecurity, the use of artificial
intelligence in company operations.
We are a partner of the Forbes Family Business Forum
In the 7th edition of the Forbes Family Business Forum – a joint initiative of Forbes magazine and Bank
Millennium - 9 meetings were held with entrepreneurs in Poland’s biggest cities. During presentations
and panel discussions, we covered topics related to the opportunities and challenges faced by family
businesses: the impact of political and macroeconomic factors on shaping business strategy,
succession planning and execution, investments in innovation and green business transformation, or
the use of artificial intelligence.
BROKERAGE BUSINESS IN THE BANK MILLENNIUM GROUP
Brokerage services are provided within an organisationally separate unit of the Bank under the name
of Brokerage Office of Bank Millennium S.A.
Pursuant to the authorisation granted by the Polish Financial Supervision Authority, we provide
brokerage services to retail and institutional clients as regards, among others:
• execution of orders to purchase or sell financial instruments on the account of the person
placing the order,
• purchasing or selling financial instruments on own account,
• investment advice,
• offering financial instruments,
• safekeeping or registering financial instruments, including the maintenance of securities
accounts, derivatives, omnibus accounts and cash accounts for the purposes of servicing
them,
• preparation of investment and financial analyses and other general recommendations
regarding transactions in financial instruments.
In 2024, we carried out work to increase the scale of operations through i.a.:
• the modernisation and integration of technological infrastructure based on the highest
standards applied in Bank Millennium,
• the project of construction and implementation of a new trading system of the Warsaw
Stock Exchange called WATS (Warsaw Automated Trading System). The planned date of
production launch of WATS is November 2025.
• further integration of processes within the Bank, e.g. in the AML area,
• enabling the conclusion of brokerage agreements electronically using the channels and
technology available in the Bank and provision of a new mobile and web application.
In 2024 trading by Bank Millennium’s Brokerage Office on the equities market amounted to approx.
PLN 2.7bn, which according to the Warsaw Stock Exchange data gave market share at 0,4%. In the
retail investor sector, this translated into a share of 1.5%.
As on 31 December 2024 the Brokerage Office serviced 22.7 thous. investment accounts, acted as
market maker and issuer market maker for companies listed on the Warsaw Stock Exchange.
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Management Board report on the activities of Bank Millennium S.A.
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In 2024, the Brokerage Office of Bank Millennium offered covered bonds of Millennium Bank
Hipoteczny with a total value of PLN 800 million. Two series of covered bonds were placed. The first
series carried out in June 2024 was worth PLN 300 million, and the second in October was worth PLN
500 million. Both series attracted a lot interest among with investors, as a result of which the reported
total demand significantly exceeded the value of the instruments offered.
CUSTODIAL SERVICES
We provide custodial services on the basis of an individual permit issued by the Securities and
Exchange Commission (now the Polish Financial Supervision Authority). We are a direct participant of
deposit and settlement systems such as the National Depository of Securities (kdpw_stream), NBP
Register of Securities (RPW), Euroclear Bank SA/NV (Brussels) and Clearstream Banking Luxembourg.
Custody Department customers include domestic and foreign financial institutions (global custodial
banks, banks - depositaries of global depositary receipts, investment banks, asset management
institutions, insurance companies, collective investment institutions, investment funds) and other
legal persons actively participating in capital and money market transactions, requiring
comprehensive and customised service and advanced ICT and infrastructural solutions.
The value of assets on securities accounts of customers, as on 31 December 2024 reached the value
of 69 bn PLN. At the same time as of the end of 2024 we maintained 12843 securities accounts and
foreign financial instruments accounts. In 2024, we also acted as an Issue Agent and Depositary for 22
Investment Funds.
INTERNATIONAL OPERATIONS AND EXTERNAL FINANCING
We continued projects connected with the long-term process of strengthening the base of credible
counterparties and partners on the interbank market, including in particular in the segment of
instruments involving medium and long-term liquidity management in FX. One of the important
aspects of the activities in this area was managing the portfolio of agreements with domestic and
foreign banks (including ISDA, GMRA and CDEA agreements) whose form requires regular adjustment
to a changing regulatory environment and market standards. A considerable part of the activity was
also connected with broadly understood compliance issues (including growing demands in the
KYC/AML area as well as sanctions), and also with continuation of work involved with the next issue
of debt instruments meeting the MREL criteria.
Irrespective of the above activities, in the past period we were performing, on an on-going basis, all
other tasks connected with the overall carrying out of international operations, in areas of
implementing various objectives including, among others, the processing of payments and
settlements, current financing of own needs and those of our clients, processing foreign trade
transactions, participating in international money and FX market transactions, operating on the
capital market. The achievement of these objectives was supported, to a large extent, by an almost
thirty-year long process of developing the Bank’s cooperation with its foreign partners and
counterparties. We maintain ongoing contacts and relations with selected reputable correspondent
banks and their units located in all important countries in terms of the structure of turnover of Polish
foreign trade as well as non-trade transactions.
In parallel, in September 2024, we issued Senior Non-Preferred bonds in the amount of EUR 500 million
under the EMTN program.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
9.4. SUBSIDIARIES’ ACTIVITY
Millennium Goodie
In 2024, the goodie cashback service continued its upward trend. The number of users actively using
the service increased by 35% y/y. The number of transactions made in this period increased by almost
50% y/y.
Numerous promotions were carried out to encourage users to use the service frequently and to attract
new users. Promotional activities also included the popularisation of the cashback plugin, as well as
increasing the number of promotional leaflets viewed.
A number of activities were carried out to test new communication channels through which new users
could be acquired. In addition, in 4Q24, an intensive video campaign was carried out on the most
popular platforms.
There were also significant increases in the "Moneyback for purchases" service available in the Bank
Millennium application and website – both among new users and in the number of transactions made
through the service.
In terms of the number of gift cards sold, an increase of 20% y/y was achieved.
Millennium Leasing
Millennium Leasing sp. z o.o., a subsidiary of Bank Millennium, was established in 1991 and is one of
the longest operating leasing companies on the Polish market. Its activities cover the financing of all
types of fixed assets: cars and vans, machinery and equipment for most industries, heavy transport
(including: road, rail and water), as well as real estate.
In 2024, the value of leasing agreements initiated by Millennium Leasing amounted to a total of PLN3.9
billion, which is 24.5% higher than in 2023. As of 31 December 2024, the value of the capital engaged
in active leasing agreements was PLN 7 billion, which is 5.6% higher than at the end of 2023. By the
end of 2024, the company achieved a 4% market share in leasing, compared to 3.6% in 2023. In 2024,
Millennium Leasing recorded an increase in sales in the following leasing categories: heavy transport
(including railway rolling stock) by 42.9%, light transport by 24.3%, and machinery by 10.8%.
In 2024, Millennium Leasing continued to offer leasing with a de minimis guarantee from BGK bank.
In 2024, BGK granted the company the ability to cover a new pool of leasing agreements with de
minimis guarantees, amounting to a record PLN 850 million. The Company is the market leader in
executing agreements with de minimis guarantees from BGK, with over a 65% market share as of
December 2024, considering the number of signed agreements with the de minimis guarantee from
BGK. In 2024, 3,034 agreements were signed with a total net value of PLN 669 million.
Millennium Leasing actively developed its “green” leasing products launched in April 2023. Thanks to
this offer, entrepreneurs can finance green assets comprehensively and under preferential conditions.
The offer includes a wide selection of assets from 40 groups, the most important of which are
machines and devices. In 2024, the Company activated leasing agreements for sustainable assets with
a total net value of PLN 233 million.
In 2024, Millennium Leasing continued the implementation of the Mój elektryk programme, which
guarantees the Clients subsidies for leasing zero-emission vehicles. The programme is implemented
by the Narodowy Fundusz Ochrony Środowiska i Gospodarki Wodnej (National Fund for Environmental
Protection and Water Management, NFOŚiGW) and Bank Ochrony Środowiska bank. The aim of the
programme is to reduce air pollution emissions by reducing the use of emission-intensive fuels in
transport. It provides real support and encouragement to choose zero-emission vehicles. Millennium
Leasing has been participating in the programme since 2022. Since its launch, the Company has
received 169 applications for electric vehicles worth PLN 30.2 million. On 27 August 2024, Bank
Ochrony Środowiska temporarily stopped accepting subsidy applications. No new subsidy applications
were accepted until the end of 2024.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Since the beginning of 2024, the Company has actively promoted its car insurance and GAP insurance
offers. In 2024, the Company recorded an 11% increase in car insurance production compared to the
previous year and a 12% increase in GAP insurance production.
During the period, the Company promoted its Benefit Packages in the MilleFlota programme.
Customers can benefit from fleet management services/tools and attractive discounts on parts and
services for vehicles (up to 3.5 tons). In 2024, 2,106 Benefit Packages were sold.
In July 2024, the Company launched the “Free Registration” campaign, in which customers accepting
leasing offers based on a fixed interest rate for specific asset groups could register their vehicle for
free. The promotion covered 2,675 leasing agreements in 2024.
The Company continued the process of digitization of its services, actively promoting the electronic
handling of leasing agreements via the electronic Customer Service Centre (elektroniczne Biuro
Obsługi Klienta, eBOK) on the Millenet platform. At the end of 2024, 95% of customers used eBOK.
The website has been expanded to include the possibility of submitting applications, thanks to which
the customer can order all standard matters regarding contracts and leased items online. In December
2024, over 60% of such applications were submitted electronically, using the eBOK platform.
Millennium Leasing is also implementing additional features and improvements, making eBOK a
convenient platform for comprehensive operational cooperation with customers.
The Company continued promoting e-Signatures, enabling remote signing of leasing agreements with
the use of qualified electronic signatures. The number of electronically signed agreements in the
corporate customer segment remained stable. In 2024, 53% of leasing agreements were signed
electronically. Additionally, since the third quarter of 2024, the Company has continued a pilot
program for remote signing of agreements through the Autenti platform, aimed at self-employed
clients, adding a free qualified electronic signature for execution of leasing agreements. Current
results indicate an increasing number and share of remote agreements in this customer segment.
Millennium Leasing services are sold by leasing advisors in 57 locations throughout Poland. Moreover,
the Company actively cooperates with banking advisors in retail branches and in the corporate banking
service network of Bank Millennium. This allows the Company to offer entrepreneurs a full range of
financial services, including both leasing and banking products.
Millennium TFI investment funds
Millennium TFI S.A is a licensed financial institution operating since 2001 as an entity creating and
managing investment funds. At the end of the year 2024, the company managed customer assets
worth PLN7.6 billion. The number of Millennium funds participants at the end of 2024 amounted to
over 180 thousands.
The main goal of Millennium TFI’s activity is delivering to Clients an attractive and effective
investment solutions and providing professional investment customer service. The fund managers
are professionals with long years of experience and excellent insight into financial markets.
During the year 2024, Millennium TFI has experienced a significant increase of assets under
management of 44.7%. This has been a consequence of a strong performance of the global economy
and lack of escalations of geopolitical tensions. Important role has been played by high interest rates
and bond yields.
In 2024 major central banks started to ease their monetary policies. Both FOMC an ECB decided to
cut interest rates by 100 bp in the second half of the year. Despite softer attitude of main central
banks, victory of D. Trump in US presidential elections deteriorated sentiment in global bond markets
raising fears of worldwide inflation surge and leading to increase of core bond yields.
In Poland Monetary Policy Council maintained interest rates unchanged in entire 2024 year. NBP’s
restrictive monetary policy together with rising core bond yields led also to increase of yields in local
sovereign bond market. As a result, returns of debt investment funds in 2024 were positive in general
but varied from binding strategies and exposure to interest rate risk.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The global equity markets have finished the year of 2024 with further spectacular double digit positive
rates of return. The increases in stock prices were supported by the profits and development of
companies in the artificial intelligence sectors, strength of the US economy, dovish monetary policy
of major central banks and a decline in geopolitical risks.
The Polish stock market stood out negatively compared to developed markets in 2024. Weakness was
particularly evident in the second half of the year. It was related to the US elections and concerns
about the new president’s policies. The main focus was on the possibility of introducing tariffs and
further steps regarding the war in Ukraine. In 2024 the broad market index (WIG) gained 1.4%.
In summary, the behavior of the capital markets in 2024, both in Poland and worldwide, not only
supported the growth of accumulated assets' value but also contributed to a dynamic increase in the
scale of fund unit acquisitions, particularly among fixed-income strategies and in the affluent clients
segment.
Millennium TFI S.A. currently manages three umbrella funds: the Open-End Investment Fund with 6
separate sub-funds investing on the Polish market (Millennium FIO), Specialist Open-End Investment
Fund with 6 separate sub-funds investing on the global markets (Millennium SFIO) and Millennium PPK
Specialist Investment Fund with 9 target date sub-funds. In 2024 Millennium TFI offered
participation units in 21 investment sub-funds with different investment strategies and different
risk levels.
The company’s broad offering includes also various savings products based on the investment funds it
manages. The most frequently chosen by customers include retirement products, including Employee
Capital Plans (PPK) and Individual Pension Account (IKE). Millennium TFI currently manages IKE
programs for 25 thousand customers, with the total asset value of PLN405 million. The assets under
management of the PPK subfunds for over 30 thousands of participants reached PLN237 million at the
end of 2024.
Millennium Bank Hipoteczny
Millennium Mortgage Bank S.A. ("MBH") began operating on June 14, 2021 with an initial capital of
PLN120 million, fully subscribed by Bank Millennium S.A. The purpose of the establishment and mission
of MBH is to provide the Group with stable and long-term financing of mortgage loans in the form of
covered bonds secured by mortgage receivables.
In 2024, MBH began to implement its main strategic goal – the issue of covered bonds. In June, the
1st series of covered bonds with a three-year maturity and a value of PLN300 million was issued. The
second series of bonds with a five-year maturity and a value of PLN500 million was settled at the
beginning of November. Both series were placed on the domestic market of institutional investors,
and their interest rate was determined as a result of bookbuilding in the form of a fixed margin over
the variable WIBOR 3M rate. Both series of covered bonds have been admitted and are listed on the
domestic regulated market operated by the WSE. As of July 2024, MBH's covered bonds have the
highest possible AAA rating obtained by Fitch Ratings.
MBH's covered bonds are secured by mortgage receivables under loans granted by the Bank. In 2024,
four transfers of mortgage loans to MBH were carried out and preparatory work for further transfers
continued. These works primarily include determining the mortgage lending value of real estate
("MLV"). All loans scheduled for transfer meet a number of specific criteria, the most important of
which are:
• loan currency in PLN
• earmarked for housing purposes
• ownership title with established mortgage in favour of Bank Millennium in the 1st place
• no evidence of impairment
• loan value lower than the mortgage lending value (MLV).
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
At the end of 2024, MBH had PLN3.1 billion in assets, including PLN2.9 billion of high-quality mortgage
loans - the share of basket 3 loans accounted for 0.1% of the total portfolio value at the end of the
reporting period.
MBH maintains liquidity and solvency ratios at very high, safe levels. At the end of the reporting
period, the total capital ratio (TCR) amounted to 23.1%.
In 2024, MBH achieved a net profit of PLN17.1 million and a return on equity (ROE) of 5.1%.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
10. MAIN AWARDS AND ACHIEVEMENTS in 2024
Bank Millennium is the Best Bank in Poland
The Bank won the Newsweek ranking for the second year
in a row, taking a double crown - winning in both the
“Traditional Banking” and “Remote Banking” categories.
This is a spectacular achievement. We are the best bank
in Poland in terms of service quality, our advantage over
other banks is constantly growing.
Bank Millennium is again one of the best in Golden
Banker
Bank Millennium took the high second place in the
category of the best multi-channel service quality, with
a difference of only 0.4 p.p. compared to the winner. In
the payment card – best design category, gold was
awarded to the unique WWF Millennium Mastercard with
the image of a lynx, a species threatened with extinction
in Poland. Konto 360° Junior also deserved a distinction,
taking third place in the category of accounts for
children.
2nd place in the new Ranking of Banks for Affluent
Clients of Forbes magazine
The organisers emphasise that the three best banks in
the ranking offer by far the highest quality of affluent
customer service and have taken care of the entire
customer service path, leaving the others behind.
3rd place in the Company-Friendly Bank ranking of
Forbes magazine
It has been recognised as one of the top three banks in
serving business customers. Banks were evaluated in four
categories – "Service quality", "Customer acquisition",
"Remote service channels" and "Branch features".
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Bank Millennium is one of the best employers in Poland
Bank Millennium received the prestigious title of Top
Employer Polska 2024. This distinction, confirming the
bank's application of high standards in the field of human
resources management and HR practices and the strong
position of Bank Millennium as one of the best and valued
employers.
Bank Millennium is the best bank in Poland according
to Global Finance Magazine
Bank Millennium was again awarded by the prestigious
Global Finance. The magazine honoured the Bank with
the title of The Best Bank in Poland for 2024. The winners
of Global Finance awards are those banks that have
carefully taken care of the needs of their clients in
difficult markets and achieved good results, at the same
time laying the foundations for future success. The
winning organisations managed their assets and
liabilities prudently, taking into account scenarios of
rapidly changing interest ratse.e
Bank Millennium is again the best digital bank in
Poland according to Global Finance Magazine
In this year’s edition of the World’s Best Digital Banks
competition by Global Finance Magazine, Bank
Millennium was again hailed The Best Consumer Digital
Bank in Poland. The bank was also recognised as the best
in as many as 13 other categories, concerning both
services for individual customers and companies.
Bank Millennium with the title of The Greatest
Financial Innovation 2024
The new Bank Millennium app for companies received
the title of the Greatest Innovation in Finances – in
corporate banking category. The awards are granted by
the Global Finance Magazine.
Jurors recognised specifically the User Experience (UX)
of the mobile app. In the programme, awards are granted
to institutions who, on regular basis, discover
innovations and design new tools in finances.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Bank Millennium is Service Quality Star 2024
For the eleventh time, Bank Millennium was among
companies honoured with the title of Service Quality
Star. The award is granted on the basis of a consumer
satisfaction survey to institutions that represent the
highest standards of service. In this edition of the
survey, consumers pointed to the commitment of
advisers, reliable service, extensive knowledge of the
staff, advanced and transparent mobile application, as
well as products, solutions and promotions that appealed
to them.
Bank Millennium among ESG leaders
Bank Millennium was on the podium of this year's edition
of the "ESG Ranking. Responsible Management". In the G
(Governance) section, it was ranked third. In the general
classification it took a high 9th place. "ESG ranking.
Responsible Management" is the most important list of
the largest companies on the Polish market, assessed in
terms of the quality of responsible management in
accordance with ESG guidelines.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
11. RISK MANAGEMENT
11.1. RISK MANAGEMENT OVERVIEW
The mission of risk management in the Bank Millennium Group is to ensure that all types of risks,
financial and non-financial, are managed, monitored, and controlled as required for the risk profile
(risk appetite), nature and scale of the Group's operations. Important principle of risk management is
the optimization of the risk and profitability trade-off – the Group pays special attention to ensure
that its business decisions balance risk and profit adequately.
The goals of the risk management mission are achieved through implementation of the following
actions:
▪ Development of risk management strategies, credit policy, processes and procedures defining
the principles for acceptance of the allowable level of particular types of risk,
▪ Increasingly wider implementation of the IT tools for risks identification, control, and
measurement,
▪ Increasing awareness of employees as regards their responsibility for proper risk management
at every level of the Group's organizational structure.
Risk management is centralized for the Group and considers the need to obtain the assumed
profitability and to maintain proper risk-capital relationship, in the context of having proper level of
capital to cover the risk. Within risk management system, a broad range of methods is used, both
qualitative and quantitative, including advanced mathematical and statistical tools supported by
adequate IT systems.
When defining the business and profitability targets, the Group considers the specified risk framework
(risk appetite) to ensure that business structure and growth will respect the risk profile that is
targeted and that will be reflected in several indicators such as:
▪ Loan growth in specific products / segments,
▪ Structure of the loan portfolio,
▪ Asset quality indicators,
▪ Cost of risk,
▪ Capital requirements / Economic capital,
▪ Amount and structure of liquidity needed.
The risk management and control model at the Group’s level is based on the following main principles:
▪ ensuring the full-scope quantification and parameterization of distinct types of risks in the
perspective of optimizing balance sheet and off-balance sheet items to the assumed level of
profitability of business activity. The primary areas of analysis encompass credit risk, market
risk, liquidity risk and operational risk. Legal and litigation risk also are subject to specific
attention;
▪ all types of risks are monitored and controlled in reference to the profitability of operations
and the level of capital necessary to ensure the safety of operations from the point of view
of capital adequacy. The results of risk measuring are regularly reported as part of the
management information system;
▪ the segregation of duties between risk origination, risk management and risk control.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The Risk management process of the Group is presented in the below diagram
The split of competence in the field of risk management is as follows:
▪ The Supervisory Board is responsible for overseeing the compliance of the Group’s risk-taking
policy with the Group’s strategy and its financial plan. Within the Supervisory Board acts the
Committee for Risk Matters, which supports it in realization of those tasks, among others,
issuing opinion on the Group's Risk Strategy, including the Group's Risk Appetite;
▪ The Management Board is responsible for the effectiveness of the risk management system,
internal capital estimation process, for reviewing the internal capital calculation and
maintenance process and the internal control systems;
▪ The Credit Committee, the Capital, Assets and Liabilities Committee, and the Liabilities at
Risk Committee are responsible for current management of different areas of banking risk,
within the framework determined by the Management Board;
▪ The Risk Committee and the Processes and Operational Risk Committee are responsible for
defining the policy and for monitoring and control of different areas of banking risk, within
the framework determined by the Management Board;
▪ The Product Committee reviews proposals for the implementation and withdrawal of products
and services from the bank's offering;
▪ The AML Committee is responsible for supervision of anti-money laundering and terrorism
financing in the Bank and cooperation in combating financial crime;
▪ The Validation Committee is responsible for confirmation of risk models’ validation results
and follow-up in the implementation of the measures defined by the Models Validation Office;
▪ The Sustainability Committee is responsible for making key decisions regarding sustainable
development in the Bank Millennium S.A. Group, in relation to environmental, social and
governance factors;
▪ The Sub-Committee for Court Cases is responsible for expressing opinions and taking decisions
in matters regarding court proceedings, for the cases when value of the dispute or direct
effect for assets value as a consequence of court verdict exceeds PLN1mn or as result of
multiple cases with the same nature, excluding most of the cases belonging to the
restructuring and recovery portfolio of Bank’s receivables managed by the Corporate Recovery
Department and Retail Restructuring and Debt Collection Department;
▪ The Risk Department is responsible for risk management, including identifying, measuring,
analysing, monitoring, and reporting on risk within the Bank. The Risk Department also
prepares risk management policies and procedures as well as provides information and
proposes courses of action necessary for the Capital, Assets and Liabilities Committee, Risk
Committee, and the Management Board to make decisions with respect to risk management;
▪ The Rating Department is mainly responsible for risk rating assignment for Corporate clients
(based on the evaluation of clients’ creditworthiness) as well as for rating monitoring and
Delineate key
risk definitions
Delineate the
models and
definitions to
classify
customers,
products,
processes, and
risk measures
Define Risk
Strategy
Defining
principles and
risk targets
according to risk
appetite, risk
capacity and
business
strategy
Define risk
policy
Defining
thresholds,
levels,
competences,
limits, cut-offs
according to Risk
Strategy
Implement
policy
Designing
products with
Business and
implement
them in tools
and
regulations,
Decision
processes
Monitor,
Control,
Reporting
Monitor the
models’
performance and
the portfolios
behavior
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
potential revision during the period of its validity. Rating assignment process is independent
from credit decision process;
▪ The Corporate Credit Underwriting Department, Mortgage Credit Underwriting Department
and Consumer Finance Credit Underwriting Department have responsibility, within the
Corporate Customer segment and Retail Customer segment, respectively, for the credit
decision process, including analysing customers’ financial situation, preparing credit
proposals for the decision-making levels, and making credit decisions within specified limits;
▪ The Retail Liabilities Monitoring and Collection Department and Retail Liabilities
Restructuring and Recovery Department have responsibility for monitoring repayment of
overdue debts by retail customers and their collection;
▪ The Corporate Recovery Department develops specific strategies with respect to each debtor
from recovery portfolio, which aims to maximize timely collection of the outstanding debt
and minimize the risk incurred by the Group. This approach is constantly revised to reflect
updated information, and the best practices and experiences regarding collection of overdue
debts;
▪ The Treasury Control and Analyses Office has responsibility for monitoring the use of part of
the Group’s limits, including counterparty and stop-loss limits, the Group’s FX position, results
of active trading and control of operations of the treasury segment;
▪ The Models Validation Office has responsibility for qualitative and quantitative models’
analysis and validation, independent from the function of models’ development; development
of the models’ validation and monitoring tools; activities connected with issuing opinions on
the adequacy of the models for the segment, for which they were developed; preparing
reports for the Validation Committee needs;
▪ The Sustainability Department is responsible for supervising and coordination of the process
of implementing the principles of sustainable development in the Bank and the Group.
▪ The Anti-fraud Sub-unit has responsibility for implementation and monitoring Bank policy
execution in the scope of fraud risk management in cooperation with others Bank units. The
Sub-unit constitutes a competence centre for anti-fraud process;
▪ The Compliance Department has the responsibility to ensure compliance with legal
regulations, related regulatory standards, market principles and standards as well as internal
organization regulations and codes of conduct;
▪ The Legal Department has responsibility for handling the litigation cases of the Bank, with
support of external legal offices and legal experts whenever necessary.
The Group has prepared a comprehensive guideline document for the risk management
policy/strategy: “Risk Strategy for 2025-2028”. The document takes a 4-year perspective and is
reviewed and updated annually. It is approved by the Bank’s Management Board and Supervisory
Board. The risk strategy is inextricably linked to other strategic documents, such as: Budget, Liquidity
Plan, and Capital Plan.
The Risk Strategy bases on the two concepts defined by the Group:
1. Risk profile – current risk level expressed in amount or type of risk the Group is currently
exposed. The Group also has a forward-looking view how their risk profile may change under
both expected and stress economic scenarios in accordance with risk appetite,
2. Risk appetite – the maximum amount or type of risk the Group is prepared to accept and
tolerate to achieve its financial and strategic objective. Three zones are defined in
accordance with warning / action required level.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Risk appetite must ensure that business structure and growth will respect the forward risk profile.
Risk appetite was reflected through defined indicators in several key areas, such as:
• Solvency
• Liquidity and funding
• Earnings volatility and Business mix
• Franchise and reputation.
The Bank and the Group have a clear risk strategy, covering retail credit, corporate credit, markets
activity and liquidity, operational and capital management. For each risk type and overall, the Group
clearly defines the risk appetite.
The Risk Management is mainly defined through the principles and targets defined in Risk Strategy
and complemented in more detail by the principles and qualitative guidelines defined in the following
documents:
a. Capital Management and Planning Framework
b. Credit Principles and Guidelines
c. Rules on Concentration Risk Management
d. Principles and Rules of Liquidity Risk Management
e. Principles and Guidelines on Market Risk Management on Financial Markets
f. Principles and Guidelines for Market Risk Management in Banking Book
g. Investment Policy
h. Principles and Guidelines for Management of Operational Risk
i. Policy, Rules, and Principles of the Model Risk Management
j. Stress tests policy
k. Sustainability Policy
l. Anti-money laundering and combating of the financing of terrorism policy of Bank Millennium
SA.
Within risk appetite, the Group has defined tolerance zones for its measures (build up based on the
“traffic lights” principle). As for all tolerance zones for risk appetite, it has been set:
▪ Risk appetite status – green zone means a measure within risk appetite, yellow zone means
an increased risk of risk appetite breach, red zone means risk appetite breach
▪ Escalation process of actions/decisions taken - bodies/organizational entities responsible for
decisions and actions in a particular zone
▪ Risk appetite monitoring process.
The Group pays particular attention to continuous improvement of the risk management process. One
measurable effect of this is a success of the received authorization to the further use of the IRB
approach in the process of calculating capital requirements.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
11.2. CAPITAL MANAGEMENT
Capital management and planning
Capital management relates to two areas: capital adequacy management and capital allocation. For
both areas, management goals were set.
The goal of capital adequacy management is: (a) meeting the requirements specified in external
regulations (regulatory capital adequacy) and (b) ensuring the solvency in normal and stressed
conditions (economic capital adequacy/internal capital). Completing that goal, Bank strives to
achieve internal long-term capital limits (targets), defined in Risk Strategy.
Capital allocation purpose is to create value for shareholders by maximizing the return on risk in
business activity, considering established risk appetite.
In a scope of capital management process, there is also a capital planning process. The goal of
capital planning is to designate the own funds (capital base that is risk-taking capacity) and capital
usage (regulatory capital requirements and economic capital) in a way to ensure that capital
targets/limits shall be met, given forecasted business strategy and risk profile – in normal and
stressed macroeconomic conditions.
Regulatory capital adequacy
The Bank is obliged by law to meet minimum own funds requirements, set in art. 92 of Regulation
(EU) No 575/2013 on prudential requirements for credit institutions and investment firms (CRR). At
the same time, the following buffers were included in capital targets/limits:
• Pillar II FX mortgage loans buffer (P2R buffer) - Polish Financial Supervision Authority (PFSA)
decision regarding order to maintain additional own funds to secure risk resulting from FX
mortgage loans granted to households, under the art. 138.2.2 of Banking Act. A value of that
buffer is defined for particular banks by PFSA every year because of Supervisory Review and
Evaluation Process (SREP) and relates to risk that is in PFSA’s opinion - inadequately covered by
minimum own funds requirements, set in CRR art. 92. The required level of YE24 the buffer was
set by PFSA in the decisions issued in the end of 2023 at the level of 1.47pp (Bank) and 1.46pp
(Group) as for Total Capital Ratio (TCR), which corresponds to capital requirements over Tier 1
ratio of 1.10pp (Bank and Group), and which corresponds to capital requirements over CET 1 ratio
of 0.82pp (Bank and Group);
▪ On January 23, 2025 and February 4, 2025, the Bank received from PFSA decisions regarding
the expiration of the decisions respectively from 13
th
and 21
st
December 2023 on additional
own funds to secure risk resulting from FX mortgage for households’ loan portfolio („P2R
buffer”) accordingly at solo and consolidated basis. Therefore, from the moment of such
decisions, the P2R equals 0,0%.
• Combined buffer – defined in Act on macro prudential supervision over the financial system and
crisis management – that consists of:
▪ Capital conservation buffer at the level of 2.5%;
▪ Other systemically important institution buffer (OSII) – at the level of 0.25%, and the value is
set by PFSA;
▪ Systemic risk buffer at the level of 0% in force from March 2020, in line with Regulation of
Ministry of Development and Finance;
▪ Countercyclical buffer at the 0% level. According to Regulation of the Minister of Finance, the
countercyclical capital requirement will be introduced from 25 September 2025 at 1% and
raised to 2% on 25 September 2026.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
In accordance with binding legal requirements and recommendations of PFSA, the Group defined
regulatory minimum levels of capital ratios, being at the same time the base of defining capital limits.
The below table presents these levels as of 31 December 2024. The Bank will inform on each change
of required capital levels in accordance with regulations.
Minimum required capital ratios as at the end of 2024
Capital ratio
31.12.2024
CET1 ratio
Bank
Group
Minimum
4.50%
4.50%
P2R Buffer
0.82%
0.82%
TSCR CET1 (Total SREP Capital Requirements)
5.32%
5.32%
Capital Conservation Buffer
2.50%
2.50%
OSII Buffer
0.25%
0.25%
Systemic risk buffer
0.00%
0.00%
Countercyclical capital buffer
0.00%
0.00%
Combined buffer
2.75%
2.75%
OCR CET1 (Overall Capital Requirements CET1)
8.07%
8.07%
T1 ratio
Bank
Group
Minimum
6.00%
6.00%
P2R Buffer
1.10%
1.10%
TSCR T1 (Total SREP Capital Requirements)
7.10%
7.10%
Capital Conservation Buffer
2.50%
2.50%
OSII Buffer
0.25%
0.25%
Systemic risk buffer
0.00%
0.00%
Countercyclical capital buffer
0.00%
0.00%
Combined buffer
2.75%
2.75%
OCR T1 (Overall Capital Requirements T1)
9.85%
9.85%
TCR ratio
Bank
Group
Minimum
8.00%
8.00%
P2R Buffer
1.47%
1.46%
TSCR TCR (Total SREP Capital Requirements)
9.47%
9.46%
Capital Conservation Buffer
2.50%
2.50%
OSII Buffer
0.25%
0.25%
Systemic risk buffer
0.00%
0.00%
Countercyclical capital buffer
0.00%
0.00%
Combined buffer
2.75%
2.75%
OCR TCR (Overall Capital Requirements TCR)
12.22%
12.21%
90
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Considering of above mentioned decisions in January and February 2025 on expiration of P2R, the
minimum regulatory capital ratios required for the Bank and the Group at the date of this report are
presented in the table below.
Minimum required capital ratios
From 23.01.2025
From 4.02.2025
CET1 ratio
Bank
Group
Minimum
4.50%
4.50%
P2R Buffer
0.00%
0.00%
TSCR CET1 (Total SREP Capital Requirements)
4.50%
4.50%
Capital Conservation Buffer
2.50%
2.50%
OSII Buffer
0.25%
0.25%
Systemic risk buffer
0.00%
0.00%
Countercyclical capital buffer
0.00%
0.00%
Combined buffer
2.75%
2.75%
OCR CET1 (Overall Capital Requirements CET1)
7.25%
7.25%
T1 ratio
Bank
Group
Minimum
6.00%
6.00%
P2R Buffer
0.00%
0.00%
TSCR T1 (Total SREP Capital Requirements)
6.00%
6.00%
Capital Conservation Buffer
2.50%
2.50%
OSII Buffer
0.25%
0.25%
Systemic risk buffer
0.00%
0.00%
Countercyclical capital buffer
0.00%
0.00%
Combined buffer
2.75%
2.75%
OCR T1 (Overall Capital Requirements T1)
8.75%
8.75%
TCR ratio
Bank
Group
Minimum
8.00%
8.00%
P2R Buffer
0.00%
0.00%
TSCR TCR (Total SREP Capital Requirements)
8.00%
8.00%
Capital Conservation Buffer
2.50%
2.50%
OSII Buffer
0.25%
0.25%
Systemic risk buffer
0.00%
0.00%
Countercyclical capital buffer
0.00%
0.00%
Combined buffer
2.75%
2.75%
OCR TCR (Overall Capital Requirements TCR)
10.75%
10.75%
In December 2024, the Bank received a letter from PFSA about non-imposing of additional capital
add-on (P2G). In the supervisory assessment process, the Bank's sensitivity to the possible
materialisation of stress scenarios affecting the level of own funds and risk exposure was assessed as
low. In particular, based on the 2024 supervisory stress tests carried out by the PFSA, the PFSA set
the P2G capital add-ons, before the offsetting of the capital conservation buffer, at 0.17pp at the
stand-alone level and 0.28pp at the consolidated level. The total capital charges recommended under
Pillar II offset by the capital buffer requirement are 0.00pp at the stand-alone level and 0.00pp at
the consolidated level.
Capital risk, expressed in the above capital targets/limits, is measured, and monitored in a regular
manner. Capital limits were defined based on the minimum regulatory capital levels. They are the
basis of setting safety zones and risk appetite. Capital ratios in each zone determine the need to
make appropriate decisions or management actions. Regular monitoring of capital risk is based on the
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
classification of capital ratios into appropriate zones, and then the assessment of trends and factors
influencing the level of capital adequacy is carried out.
Own funds capital requirements
The Group continues to be during a project of an implementation of internal ratings-based method
(IRB) for calculation of own funds requirements for credit risk and calculates its own funds minimum
requirements using the IRB and standardise method for credit risk and standardise methods for other
risk types.
In the end of 2012, Banco de Portugal (consolidating Regulator) with cooperation PFSA granted an
approval to the use of IRB approach as to following loan portfolios: (i) Retail exposures to individual
persons secured by residential real estate collateral (RRE), (ii) Qualifying revolving retail exposures
(QRRE). According to the mentioned approval, minimum own funds requirements calculated using the
IRB approach should be temporarily maintained at no less than 80 per cent (‘Regulatory floor’) of the
respective capital requirements calculated using the Standardized approach.
In the end of 2014, the Bank received another decision by Regulatory Authorities regarding the IRB
process. According to its content, for the RRE and QRRE loan portfolios, the minimum own funds
requirements calculated using the IRB approach had to be temporarily maintained at no less than 70
per cent (‘Regulatory floor’) of the respective capital requirements calculated using the Standardized
approach until the Bank fulfils further defined conditions. In July 2017, the Bank received the decision
of Competent Authorities (ECB cooperating with PFSA) on approval of material changes to IRB models
(LGD models) and revoking the ‘Regulatory floor’.
Since 2018, the Bank has been successively implementing a multi-stage process of changes to the IRB
method, related to the requirements regarding the new definition of default. In the first phase, in
line with the “two-step approach” approved by Competent Authorities, the Bank in 2020 successfully
implemented solutions for the new definition of default in the production environment. The Bank is
obliged to include an additional conservative charge on the estimates of the RWA value for exposures
classified under the IRB approach. The level of this add-on, calculated based on the supervisory
algorithm, was set at 5 per cent above the value resulting from the IRB method.
In 2021, all credit risk models included in the rating system subject to the current regulatory approval
were recalibrated and rebuilt. In 2021 the Bank also obtained a decision from Competent Authorities
to approve significant changes to the IRB models used (LGD, LGD in-default and ELBE) for rating
systems subject to the IRB approval.
In 2024, these models were recalibrated in connection with the modification of the default definition
and an application for consent to their use was submitted to the Supervisory Authority.
Further work was carried out on credit risk models for the remaining credit portfolios covered by the
IRB method roll-out plan: other retail exposures and corporate exposures.
Internal capital
The Group defines internal capital according to Polish Banking Act, as the estimated amount needed
to cover all identified, material risks found in the Bank’s activity and changes in economic
environment, considering the anticipated level of risk in the future.
Internal capital is used in capital management in following processes: economic capital adequacy
management and capital allocation. The Bank defined an internal (economic) capital estimation
process. To this end, as for measurable risk types, mathematic and statistic models and methods are
used.
Maintaining economic capital adequacy means a coverage (provision) of internal capital (that is an
aggregated risk measure) by available financial resources (own funds). An obligation to banks to have
in place that sort of risk coverage stems from Banking Act. It was mirrored in the Group’s capital
targets/limits: economic capital buffer and economic capital buffer in stressed conditions.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
In 2024, both above capital targets were met with a surplus. A surplus of own funds over internal
capital supports a further increase of banking activity, in areas with a higher risk-adjusted return.
At the same time internal capital is utilised in capital allocation process, to assign an internal capital
to products/business lines, calculating risk-adjusted performance measures, setting risk limits and
internal capital reallocation.
Capital adequacy evolution
Capital adequacy evolution of the Group and the Bank in 2024 and 2023 was as follows:
Capital adequacy measures
31.12.2024
31.12.2023
31.12.2024
31.12.2023
(PLN million)
Group
Group
Bank
Bank
Risk-weighted assets
45 116.2
41 354.5
40 928.3
37 960.4
Own Funds requirements, including:
3 609.3
3 308.4
3 274.3
3 036.8
- Credit risk and
counterparty credit risk
3 086.6
2 841.2
2 773.8
2 589.0
- Market risk
19.8
15.4
19.8
15.4
- Operational risk
500.4
446.4
478.0
427.0
- Credit Valuation
Adjustment CVA
2.5
5.4
2.6
5.4
Own Funds, including:
7 776.4
7 470.6
7 352.5
7 228.3
- Common Equity Tier 1
Capital
6 688.4
6 089.7
6 264.6
5 847.4
- Tier 2 Capital
1 087.90
1 380.9
1 087.9
1 380.9
Total Capital Ratio (TCR)
17.24%
18.06%
17.96%
19.04%
Minimum required level (at
31.12.2024)
12.21%
12.21%
12.22%
12.22%
Surplus (+) / Deficit (-) of TCR ratio
(pp)
5.03
5.85
5.74
6.82
Tier 1 Capital ratio (T1)
14.82%
14.73%
15.31%
15.40%
Minimum required level (at
31.12.2024)
9.85%
9.85%
9.85%
9.85%
Surplus (+) / Deficit (-) of T1 ratio (pp)
4.97
4.88
5.46
5.55
Common Equity Tier 1 Capital ratio
(CET1)
14.82%
14.73%
15.31%
15.40%
Minimum required level (at
31.12.2024)
8.07%
8.07%
8.07%
8.07%
Leverage ratio
4.64%
4.66%
4.68%
4.77%
At the end of 2024, compared to the end of 2023, capital adequacy measured by the Common Equity
Tier 1 capital ratio and the total capital ratio increased by 9 bps and decreased by 82 bps respectively.
Risk-weighted assets (RWA) increased by PLN 3,762 million (9%) in 2024. The largest annual change
concerned RWA for credit risk - an increase of PLN 3,068 million (9%). Changes in RWA for operational
risk, market risk and CVA (due to the fair value adjustment for credit risk) were smaller - a total
increase of PLN 694 million.
Own funds increased by PLN 306 million (4%) in 2024, with basic own funds increasing by PLN 599
million and Tier 2 capital decreasing by PLN 293 million (due to regular depreciation of the existing
subordinated bond issues).
The minimum values of capital ratios required by the PFSA in terms of the combined buffer
requirement (OCR) are achieved with a surplus at the end of 2024.
Leverage ratio stood at the safe level of 4.64%, and it exceeds the regulatory minimum of 3%.
93
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Entry into force starting from January 2025 onwards the Regulation (EU) 2024/1623 of the European
Parliament amending Regulation (EU) No 575/2013 (CRR 3) will impact the Group’s capital adequacy
ratios.
Main changes according to CRR 3 will regard credit conversion factors (CCF) under standardized
method, new approach to the determination of off-balance sheet exposures, risk weight for exposures
secured by real estate property, deletion of 1.06 factor from risk weight calculation under IRB method
(credit risk) and change the way of operational risk capital requirements calculation.
The Bank is still waiting for some areas of CRR 3 interpretation to be closed, namely the calculation
of the operational risk capital requirements, and is working on the revision of the approach for
determination of off-balance-sheet exposures.
According to the current Bank's estimates, the initial negative impact of CRR 3 on consolidated TCR
will be in the range between 0.95pp and 1.81pp, while for consolidated T1 capital ratio in the range
between 0.81pp and 1.55pp.
In December 2024, Bank carried out a synthetic securitization transaction of a portfolio of corporate
and SME loans with the total value PLN of 2.1 billion with the option of increasing the nominal amount
of the Transaction up to the maximum amount of PLN 4.1 million (Ramp-up Option). As part of the
transaction, the Bank transferred to the investor (EBRD) a significant part of the credit risk from the
selected portfolio subject to securitisation. The selected loan portfolio covered by the securitisation
remains on the Bank's balance sheet. The transfer of the risk of the securitised portfolio is carried out
through a credit protection instrument in the form of a financial guarantee issued by the EBRD.
The transaction meets the requirements for transferring a significant part of the risk specified in the
CRR Regulation (Regulation No. 575/2013 of the European Parliament and of the Council of 26 June
2013 on prudential requirements for credit institutions and investment firms). The Bank is waiting for
confirmation of regulatory non-objection to the use of the transaction in the calculation of risk-
weighted assets. Considering the impact of this transaction, capital ratios as at 31.12.2024 would
increase in terms of the Tier 1 capital ratio by 31 bps to 15.13%, and in terms of the Total Capital
Ratio by 35 bps to 17.59%.
Earlier, in 2024, the Bank renegotiated and extended the period of replenishment of two transactions
concluded in 2023. The replenishment period for the securitisation transactions done by Bank’s
subsidiary, Millennium Leasing, was extended till April 2025 and the replenishment period for Bank’s
transaction on the unsecured retail loans was extended till August 2025.
Minimum requirement for own funds and eligible liabilities (MREL)
In the area of minimum requirements for own funds and eligible liabilities subject to write-down or
conversion, the Bank manages MREL requirements indicators in a manner analogous to capital
adequacy indicators.
In June 2024 the Bank received a joint decision from the resolution authorities, obliging it to comply
with MREL requirements. The decision sets updated minimum requirements at the levels of 18.03%
(consolidated MRELtrea) and 5.91% (consolidated MRELtem). Additionally, in relation to the above
decisions, the Bank should also meet the MREL requirement taking into account the Combined Buffer
Requirement (currently 2.75%).
Considering the above, in September 2024, the Bank successfully completed the subscription of senior
non-preferred green bonds with a total value of EUR500million under the Euro Medium Term Notes
Issuance Program.
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and the Bank Millennium S.A. Group in 2024
MREL requirements and ratios in 2023 and 2024
MREL
31.12.2024
30.09.2024
30.06.2024
31.12.2023
MRELtrea ratio (consolidated)
28.06%
28.60%
22.92%
23.77%
Minimum required level MRELtrea
18.03%
18.03%
18.03%
18.89%
Surplus (+) / Deficit (-) of MRELtrea (pp)
10.03
10.57
4.89
4.88
Minimum required level including Combined Buffer
requirement (CBR)
20.78%
20.78%
20.78%
21.64%
Surplus (+) / Deficit (-) of MRELtrea + CBR (pp)
7.28
7.82
2.14
2.13
MRELtem (consolidated)
8.71%
8.97%
7.05%
7.50%
Minimum required level of MRELtem
5.91%
5.91%
5.91%
5.91%
Surplus (+) / Deficit (-) of MRELtem (pp)
2.80
3.06
1.14
1.59
In terms of the MRELtrea and MRELtem requirements, the Group presents a surplus compared to the
minimum required levels as of December 31, 2024, and meets the MRELtrea Requirement after the
inclusion of the Combined Buffer Requirement.
11.3. CREDIT RISK
Credit risk means uncertainty about the Client’s compliance with the financing agreements concluded
with the Group i.e., repayment of the principal and interest in the specified time, which may cause
a financial loss to the Group.
The credit policy pursued in the Group is based on a set of principles such as:
▪ centralization of the credit decision process;
▪ using specific scoring/rating models for each Client segment/type of products;
▪ using IT information (workflow) to support the credit process at all stages;
▪ existence of specialized credit decisions departments for particular Client segments;
▪ regular credit portfolio monitoring, both at the level of each transaction in the case of major
exposures, and at credit sub-portfolio level (by the Client segment, type of product,
distribution channels, etc.);
▪ using the structure of limits and sub-limits for credit exposure to avoid credit concentration
and promote the effects of credit portfolio diversification;
▪ separate unit responsible for granting rating to corporate Client, thus separating the credit
capacity assessment and credit transaction granting from his creditworthiness assessment.
In the area of credit risk, in 2024, the Group focused on adjusting the principles of its credit policy
to changing economic conditions and on improving the tools and processes of credit risk management,
in particular
▪ updated the Risk Strategy for the years 2025-2028;
▪ optimised the methodology, tools, and processes of credit risk management for retail and
corporate clients;
▪ updating the industry risk classification and industry limits.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
In the retail segment, emphasis was placed on revamping risk policy in the area of financing business
activity and improving the processes and the tools that support credit decision process in this
segment. In the area of mortgage loans, activities were focused on improving the processes in
accordance to adaptation to changing legal regulations and changing supervisory requirements, while
improving automation and digitalization of the process. Similar approach was also undertaken in
consumer finance area. In particular the credit processes was improved with focus on further
digitalization while adjusted to changing supervisory requirements.
In the corporate segment, the Group focused on the optimal use of capital while maintaining the
current profitability and maintaining a good risk profile. The Group also carried out activities aimed
at improving and accelerating credit processes, including decision-making processes. As in previous
periods, work continued improving IT tools supporting the credit process. The Group also continued
the close monitoring of the loan portfolio as well as the individual monitoring of the largest exposures.
All the above changes in both the retail and corporate segment enabled the Group to maintain the
risk at an acceptable level defined in the Risk Strategy as well as prepared the Group to new
challenges and to act in changed conditions.
Loan portfolio quality
At the end of December 2024, the share of impaired loans (including stage 3 portfolio and the
defaulted portfolio of Purchased or Originated Credit Impaired assets – POCI) in total loan portfolio
reached the level of 4.45%. This means a drop of 13bps from the level of 4.58% at the end of 2023,
which was achieved largely due to the sales of NPL portfolios and Group’s write-offs policy. Share of
loans past-due more than 90 days in total portfolio slightly increased from 2.12% in December 2023
to 2.19% in December 2024.
Coverage ratio of impaired loans, defined as relation of total risk provisions to the volume of stage 3
loans and POCI assets in default, has slightly increased from 72.21% in December 2023 to 72.89%. The
ratio improved despite the reduction by PLN254mn of 100% covered loans (write-offs) and by
PLN286mn of highly covered loans (NPL sales) in 2024. Coverage by total provisions of loans past-due
more than 90 days decreased from 156% year ago to 148% at the end of December 2024.
The evolution of main indicators of the Group’s loan portfolio quality is presented below:
Group loans quality indicators
31.12.2024
31.12.2023
Total impaired loans (PLN million)
3 450
3 488
Total provisions (PLN million)
2 514
2 518
Impaired over total loans ratio (%)
4.45%
4.58%
Loans past-due over 90 days /total loans (%)
2.19%
2.12%
Total provisions/impaired loans (%)
72.89%
72.21%
Total provisions/loans past-due (>90d) (%)
147.91%
155.68%
(*) Purchase Price Allocation (PPA) implied consolidation of Euro Bank impaired (stage 3) portfolio at net value
Impaired loans ratio for retail clients decreased from 4.79% to 4.40% (including drop in other retail of
1.39pp and drop in mortgage portfolio of 0.09pp) and at the same time increased in the corporate
portfolio from 3.77% to 4.65% (growth in leasing portfolio of 0.30pp and growth in other corporate
portfolio of 1.31pp). The value of foreign currency mortgage loans (deducted by allocated provisions)
decreased as much by approx. 56.3% year-to-date (in PLN terms) as a result of verdicts, write-offs
and amortization of this portfolio as well as due to increase of provisions created for legal risk.
Additionally, it should be noted that ex-Euro Bank mortgage portfolio, in amount of approx.
PLN697mn, enjoys a guarantee and indemnity from Société Genéralé. Excluding this portfolio, the
share of FX mortgage loans in the total loan portfolio decreases from 3.7% to 1.5%. The improvement
in the currency structure of the mortgage loan portfolio was supported by a significant increase in
sales of new loans in PLN.
96
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The evolution of the Group’s loan portfolio quality by main products groups is presented in the table
below:
Portfolio quality by products:
Loans past-due
> 90 days ratio
Impaired loans
Ratio
31.12.2024
31.12.2023
31.12.2024
31.12.2023
Mortgage
0.95%
1.00%
2.29%
2.37%
Other retail*
4.65%
5.38%
8.16%
9.55%
Total retail clients*
2.28%
2.48%
4.40%
4.79%
Leasing
1.11%
1.02%
4.86%
4.56%
Other loans to companies
2.43%
0.58%
4.50%
3.19%
Total companies
1.85%
0.77%
4.65%
3.77%
Total loan portfolio
2.19%
2.12%
4.45%
4.58%
(*) incl. Microbusiness, annual turnover below PLN 5 million
The Group's portfolio is characterized by appropriate diversification, both due to the concentration
of the largest exposures and due to the concentration in sectors of the economy. Participation of the
10 largest exposures remain at a safe, low level of 4.2% (marginal increase in 2024 from 4.1% at the
end of 2023).
The distribution of the portfolio by Stage 1/2 and PD ranges as well as the distribution by Stage3/POCI
and months in default is presented below separately for the following homogenous portfolios:
Mortgage, Other retail, Other Corporate and Leasing.
The average 12-month Probability of Default (PD) for Stage 1/2 in Mortgage decreased from 2.23% in
2023 to 0.59%, primarily due to a reduction in conservative PD adjustments driven by an improved
macroeconomic outlook regarding interest rates. Meanwhile, the average Loss Given Default (LGD)
increased from 14.74% to 17.40%, reflecting a more cautious approach concerning expected recoveries
in this segment. This upward trend in LGD is also observed in Stage 3/Purchased or Originated Credit
Impaired (POCI) portfolios, where the figures rose from 49.34% in 2023 to 55.13%.
97
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Distribution of non-defaulted portfolio by 12-month PD for Mortgage segment (PLN mln):
31.12.2024
PD scale
Gross
balance
exposure
Off-
balance
exposure
Number of
exposures
Average
maturity
(yrs)
EAD*
Average
PD (%)
Average
LGD (%)
ECL**
Stage 1
0% - 0.14%
25 090.4
545.0
115 512
21.0
26 057.6
0.10%
17.67%
4.6
0.15% - 0.24%
3 163.0
40.9
30 095
19.4
3 335.0
0.19%
15.97%
0.9
0.25% - 0.49%
2 898.4
66.5
13 726
21.2
3 354.4
0.34%
18.07%
2.0
0.50% - 0.74%
1 415.9
20.3
6 694
21.9
1 498.4
0.65%
17.22%
1.6
0.75% - 2.49%
2 302.7
34.7
12 189
22.1
2 433.1
1.09%
16.30%
4.1
2.50% - 9.99%
811.1
12.5
3 941
22.5
873.2
4.25%
16.51%
5.9
10.00% - 44.99%
43.9
0.0
165
23.2
45.4
15.07%
17.25%
1.1
45.00% - 100.00%
0.0
0.0
0
0.0
0.0
0.00%
0.00%
0.0
Total Stage 1
35 725.3
719.9
182 322
21.0
37 597.1
0.33%
17.42%
20.3
Stage 2
0% - 0.14%
245.7
0.0
856
23.7
248.8
0.10%
17.01%
0.5
0.15% - 0.24%
34.9
0.0
204
19.8
35.4
0.17%
16.73%
0.2
0.25% - 0.49%
147.7
0.0
775
18.9
152.9
0.36%
17.19%
1.3
0.50% - 0.74%
201.4
0.0
910
18.8
205.7
0.65%
17.15%
2.1
0.75% - 2.49%
1 070.7
1.2
4 149
21.9
1 092.5
1.11%
17.22%
17.5
2.50% - 9.99%
701.2
6.8
2 879
22.2
723.2
4.65%
16.99%
23.1
10.00% - 44.99%
186.8
0.0
850
22.5
191.8
26.26%
16.82%
15.5
45.00% - 100.00%
16.6
0.2
134
20.8
20.6
74.44%
16.24%
2.8
Total Stage 2
2 604.8
8.2
10 757
21.7
2 670.9
4.25%
17.09%
63.0
Total Stage 1+2
38 330.1
728.1
193 079
21.1
40 268.0
0.59%
17.40%
83.3
31.12.2023
Stage 1
0% - 0.14%
624.5
0.0
4 852
15.7
631.4
0.13%
14.56%
0.1
0.15% - 0.24%
1 858.9
0.3
11 937
18.5
2 214.3
0.19%
14.75%
0.6
0.25% - 0.49%
95.2
0.0
740
16.4
114.3
0.42%
14.79%
0.1
0.50% - 0.74%
180.3
0.1
1 016
19.5
192.2
0.61%
14.73%
0.2
0.75% - 2.49%
29 419.4
849.1
128 265
22.1
30 611.5
1.37%
14.63%
59.3
2.50% - 9.99%
4 249.7
20.4
42 998
20.1
4 381.8
6.59%
15.63%
44.3
10.00% - 44.99%
175.7
0.0
1 005
22.8
178.5
11.67%
15.96%
3.2
45.00% - 100.00%
0.2
0.0
1
15.5
0.2
49.02%
14.54%
0.0
Total Stage 1
36 603.9
870.0
190 814
21.6
38 324.1
1.92%
14.75%
107.8
Stage 2
0% - 0.14%
1.6
0.0
12
17.3
1.6
0.14%
14.54%
0.0
0.15% - 0.24%
9.3
0.0
70
17.8
12.9
0.20%
14.87%
0.0
0.25% - 0.49%
62.0
0.0
367
18.0
63.2
0.39%
14.54%
0.5
0.50% - 0.74%
67.0
0.0
379
19.3
67.9
0.62%
14.54%
0.6
0.75% - 2.49%
1 035.0
0.8
3 898
22.1
1 051.1
1.79%
14.49%
11.9
2.50% - 9.99%
799.9
4.6
3 162
22.9
815.1
4.68%
14.45%
20.5
10.00% - 44.99%
420.0
0.0
1 938
23.0
429.7
20.70%
14.87%
29.5
45.00% - 100.00%
36.7
0.4
223
21.1
39.1
70.99%
14.81%
5.3
Total Stage 2
2 431.4
5.7
10 049
22.3
2 480.7
7.03%
14.55%
68.3
Total Stage 1+2
39 035.3
875.7
200 863
21.6
40 804.8
2.23%
14.74%
176.2
* EAD after credit risk mitigation and application of the credit conversion factor
** For Stage 2 - ECL Lifetime
98
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Distribution of Stage 3 and POCI portfolio by time in default for Mortgage segment (PLN mln):
31.12.2024
Time in default
Number of exposures
EAD*
Average LGD (%)
ECL**
Stage 3
<12 months
881
167.6
32.80%
55.0
13 - 24 months
848
171.6
39.72%
68.1
25 - 36 months
616
119.0
44.22%
52.6
37 - 48 months
382
76.5
48.24%
36.9
49 - 60 months
295
48.4
53.97%
26.1
61 - 84 months
765
130.4
66.88%
87.2
> 84 months
604
117.4
79.30%
93.1
Total Stage 3
4 391
830.8
50.44%
419.0
POCI
Non-Default
129
21.5
30.04%
9.3
<12 months
11
1.8
35.40%
0.6
13 - 24 months
12
3.2
45.31%
1.4
25 - 36 months
15
4.8
55.27%
2.7
37 - 48 months
7
1.5
73.80%
1.1
49 - 60 months
23
10.2
90.82%
9.3
61 - 84 months
229
95.1
95.41%
90.7
> 84 months
14
6.4
99.36%
6.3
Total POCI
440
144.5
82.10%
121.5
Total Stage 3+POCI
4 831
975.3
55.13%
540.5
31.12.2023
Stage 3
<12 months
1 279
250.5
22.13%
55.4
13 - 24 months
833
158.4
29.73%
47.1
25 - 36 months
476
97.2
39.14%
38.0
37 - 48 months
357
64.1
46.15%
29.6
49 - 60 months
338
62.9
53.57%
33.7
61 - 84 months
709
134.2
64.22%
86.2
> 84 months
580
120.4
80.65%
97.1
Total Stage 3
4 572
887.6
43.61%
387.1
POCI
Non-Default
143
24.7
30.73%
10.8
<12 months
17
4.0
35.88%
1.4
13 - 24 months
22
5.6
46.48%
2.6
25 - 36 months
7
1.5
57.80%
0.9
37 - 48 months
28
9.9
87.16%
8.7
49 - 60 months
280
108.8
93.73%
102.0
61 - 84 months
7
2.3
94.39%
2.2
> 84 months
14
6.0
98.97%
5.9
Total POCI
518
162.9
80.58%
134.5
Total Stage 3+POCI
5 090
1 050.6
49.34%
521.5
* EAD after credit risk mitigation and application of the credit conversion factor
** For POCI – current ECL value (not provisions)
In the Other Retail portfolio, the average 12-month Probability of Default (PD) for Stage 1/2 decreased
from 4.16% to 2.87%, reflecting a lower observed default rate in this segment. Conversely, the average
99
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Loss Given Default (LGD) increased for both Stage 1/2 portfolios (47.26% compared to 42.69% in 2023)
and Stage 3/POCI portfolios (63.48% compared to 57.54%), attributed to higher allocation of provisions
to this portfolio.
100
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Distribution of non-defaulted portfolio by 12-month PD for Other Retail segment (PLN mln):
31.12.2024
PD scale
Gross
balance
exposure
Off-
balance
exposure
Number of
exposures
Average
maturity
(yrs)
EAD*
Average
PD (%)
Average
LGD (%)
ECL**
Stage 1
0% - 0.14%
771.7
209.4
275 695
5.3
949.7
0.10%
45.47%
0.4
0.15% - 0.24%
1 752.5
2 342.3
599 434
9.0
3 819.6
0.17%
49.51%
3.1
0.25% - 0.49%
1 807.1
228.9
244 261
5.2
1 987.2
0.38%
44.36%
3.2
0.50% - 0.74%
2 066.0
201.4
185 521
5.7
2 232.9
0.62%
46.06%
6.1
0.75% - 2.49%
5 368.8
328.6
350 456
6.2
5 694.9
1.37%
47.36%
35.2
2.50% - 9.99%
3 438.7
69.1
150 035
6.5
3 542.5
4.38%
49.10%
72.3
10.00% - 44.99%
629.8
4.5
25 476
6.5
642.1
15.00%
48.35%
44.0
45.00% - 100.00%
0.0
0.0
0
0.0
0.0
0.00%
0.00%
0.0
Total Stage 1
15 834.5
3 384.2
1 830 878
6.6
18 868.9
1.90%
47.59%
164.3
Stage 2
0% - 0.14%
6.9
0.2
8 482
1.0
7.0
0.10%
40.76%
0.0
0.15% - 0.24%
28.5
52.6
21 370
10.2
78.2
0.17%
44.41%
0.8
0.25% - 0.49%
56.3
34.4
20 178
7.6
86.8
0.39%
44.91%
1.6
0.50% - 0.74%
101.5
41.6
22 458
7.5
137.4
0.60%
44.52%
2.8
0.75% - 2.49%
581.6
113.7
74 363
7.3
680.5
1.40%
45.75%
24.6
2.50% - 9.99%
653.5
41.4
62 485
7.1
689.9
4.83%
44.36%
53.3
10.00% - 44.99%
637.9
6.8
47 862
5.8
638.3
23.06%
43.70%
96.2
45.00% - 100.00%
76.9
1.3
6 976
6.1
77.7
77.94%
44.83%
28.1
Total Stage 2
2 143.1
292.1
264 174
6.9
2 395.7
10.52%
44.62%
207.5
Total Stage 1+2
17 977.7
3 676.3
2 095 052
6.7
21 264.6
2.87%
47.26%
371.7
31.12.2023
Stage 1
0% - 0.14%
436.7
1 990.0
365 957
11.6
2 223.5
0.07%
38.92%
0.6
0.15% - 0.24%
149.0
308.7
77 834
10.4
430.6
0.18%
38.47%
0.3
0.25% - 0.49%
470.5
427.7
132 743
9.9
864.8
0.36%
39.27%
1.2
0.50% - 0.74%
183.1
85.2
29 280
8.1
256.2
0.61%
41.02%
0.6
0.75% - 2.49%
7 831.4
269.6
967 898
5.0
8 002.8
1.65%
42.04%
53.4
2.50% - 9.99%
4 590.7
56.8
225 085
6.2
4 683.7
4.87%
46.74%
101.6
10.00% - 44.99%
627.2
4.9
27 566
6.6
640.9
17.25%
46.48%
48.8
45.00% - 100.00%
0.0
0.0
2
10.9
0.0
49.84%
39.02%
0.0
Total Stage 1
14 288.8
3 142.9
1 826 365
6.7
17 102.5
2.79%
42.84%
206.4
Stage 2
0% - 0.14%
9.6
36.7
12 037
11.2
44.6
0.07%
38.59%
0.2
0.15% - 0.24%
8.1
27.7
6 465
11.4
33.4
0.19%
38.22%
0.7
0.25% - 0.49%
54.7
73.9
19 753
11.3
123.2
0.38%
39.03%
2.7
0.50% - 0.74%
25.6
21.3
6 688
11.0
45.1
0.62%
39.51%
1.4
0.75% - 2.49%
604.2
79.4
72 725
7.0
677.7
1.76%
41.81%
22.2
2.50% - 9.99%
816.6
32.7
66 691
6.3
844.8
5.18%
42.54%
50.1
10.00% - 44.99%
563.2
6.7
48 564
5.6
564.6
22.74%
40.30%
84.8
45.00% - 100.00%
223.1
1.5
13 841
6.2
225.0
69.55%
44.25%
83.5
Total Stage 2
2 304.9
279.9
246 764
6.8
2 558.5
13.34%
41.65%
245.6
Total Stage 1+2
16 593.7
3 422.8
2 073 129
6.7
19 660.9
4.16%
42.69%
452.0
* EAD after credit risk mitigation and application of the credit conversion factor
** For Stage 2 - ECL Lifetime
101
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Distribution of Stage 3 and POCI portfolio by time in default for Other Retail segment (PLN mln):
31.12.2024
Time in default
Number of exposures
EAD*
Average LGD (%)
ECL**
Stage 3
<12 months
37 135
578.4
47.86%
276.8
13 - 24 months
21 048
330.4
59.79%
197.6
25 - 36 months
12 690
202.4
70.57%
142.8
37 - 48 months
8 502
153.4
78.39%
120.2
49 - 60 months
5 585
108.2
84.11%
91.0
61 - 84 months
5 794
68.8
82.05%
56.5
> 84 months
2 196
22.2
97.79%
21.7
Total Stage 3
92 950
1 463.7
61.94%
906.6
POCI
Non-Default
1 628
22.9
41.52%
7.9
<12 months
143
4.0
51.29%
2.1
13 - 24 months
106
3.1
67.37%
2.1
25 - 36 months
81
1.7
71.47%
1.2
37 - 48 months
84
2.8
72.81%
2.0
49 - 60 months
173
6.8
81.05%
5.5
61 - 84 months
3 518
115.3
85.04%
98.0
> 84 months
241
5.3
91.52%
4.8
Total POCI
5 974
161.8
77.41%
123.7
Total Stage 3+POCI
98 924
1 625.5
63.48%
1 030.3
31.12.2023
Stage 3
<12 months
48 166
691.1
45.59%
315.1
13 - 24 months
24 512
372.6
54.69%
203.8
25 - 36 months
13 223
229.3
61.00%
139.9
37 - 48 months
9 431
192.5
70.12%
135.0
49 - 60 months
5 486
80.3
68.72%
55.2
61 - 84 months
3 846
38.9
69.26%
26.9
> 84 months
1 976
19.8
96.88%
19.2
Total Stage 3
106 640
1 624.6
55.10%
895.1
POCI
Non-Default
2 102
31.7
40.86%
9.1
<12 months
294
8.7
53.34%
4.6
13 - 24 months
169
4.4
66.73%
2.9
25 - 36 months
171
5.5
73.37%
4.0
37 - 48 months
295
9.8
77.52%
7.6
49 - 60 months
4 932
153.5
81.75%
125.5
61 - 84 months
275
9.9
86.28%
8.6
> 84 months
263
6.0
91.02%
5.4
Total POCI
8 501
229.5
74.80%
167.8
Total Stage 3+POCI
115 141
1 854.1
57.54%
1 062.9
* EAD after credit risk mitigation and application of the credit conversion factor
** For POCI – current ECL value (not provisions)
102
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Within the Other Corporate portfolio, an increase in the average 12-month Probability of Default (PD)
for Stage 1/2 from 1.89% to 2.36% indicates a slight deterioration in the portfolio, both in terms of
observed default rates and outlook for the year 2025. Despite the increase in the average Loss Given
Default (LGD) for the Stage 3/POCI portfolio from 33.15% to 34.23%, it continues to indicate a high
level of recoveries. This is primarily attributed to the good quality and value of the collaterals.
103
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Distribution of non-defaulted portfolio by 12-month PD for Other Corporate segment (PLN mln):
31.12.2024
PD scale
Gross
balance
exposure
Off-
balance
exposure
Number of
exposures
Average
maturity
(yrs)
EAD*
Average
PD (%)
Average
LGD (%)
ECL**
Stage 1
0% - 0.14%
169.8
145.1
4 800
7.4
309.4
0.05%
34.22%
0.1
0.15% - 0.24%
118.3
20.4
2 041
6.2
138.7
0.22%
33.32%
0.1
0.25% - 0.49%
320.1
475.3
3 750
2.6
714.1
0.47%
42.08%
1.4
0.50% - 0.74%
1 046.4
3 051.7
3 560
1.5
2 907.6
0.60%
45.05%
7.7
0.75% - 2.49%
5 404.5
3 515.0
87 287
2.1
7 320.8
1.41%
45.73%
46.3
2.50% - 9.99%
2 633.9
1 266.9
11 029
2.0
3 221.4
4.02%
43.51%
54.5
10.00% - 44.99%
248.4
19.0
2 619
5.2
255.5
16.83%
31.62%
12.7
45.00% - 100.00%
0.0
0.0
0
0.0
0.0
0.00%
0.00%
0.0
Total Stage 1
9 941.4
8 493.3
115 086
2.2
14 867.5
2.00%
44.34%
122.7
Stage 2
0% - 0.14%
2.1
2.3
87
9.5
4.3
0.05%
36.70%
0.1
0.15% - 0.24%
6.5
2.7
78
7.1
9.2
0.21%
35.10%
0.2
0.25% - 0.49%
22.2
3.6
178
6.3
25.6
0.44%
34.67%
0.5
0.50% - 0.74%
33.8
81.3
152
1.3
89.7
0.62%
45.39%
0.4
0.75% - 2.49%
253.0
185.7
623
1.8
394.9
1.53%
41.57%
3.6
2.50% - 9.99%
348.1
143.5
982
2.1
389.1
4.71%
35.45%
9.0
10.00% - 44.99%
205.1
29.8
2 231
3.9
210.9
20.92%
30.50%
17.6
45.00% - 100.00%
13.2
0.1
206
4.7
13.2
85.43%
25.32%
3.0
Total Stage 2
883.9
449.0
4 537
2.4
1 136.9
7.07%
37.31%
34.2
Total Stage 1+2
10 825.3
8 942.3
119 623
2.2
16 004.4
2.36%
43.84%
157.0
31.12.2023
Stage 1
0% - 0.14%
54.3
9.1
1 066
5.2
62.9
0.12%
22.82%
0.0
0.15% - 0.24%
41.9
3.7
624
6.0
46.1
0.20%
21.86%
0.0
0.25% - 0.49%
448.9
1 876.7
4 563
1.6
1 751.4
0.44%
42.56%
3.2
0.50% - 0.74%
2 386.2
2 480.6
68 402
1.5
3 813.6
0.63%
44.68%
10.6
0.75% - 2.49%
4 673.4
3 386.3
12 393
2.3
6 587.2
1.37%
41.44%
36.6
2.50% - 9.99%
2 011.0
742.3
10 243
2.9
2 255.9
3.87%
40.82%
33.5
10.00% - 44.99%
78.2
1.1
1 060
5.5
80.2
20.30%
22.90%
3.5
45.00% - 100.00%
0.0
0.0
0
0.0
0.0
0.00%
0.00%
0.0
Total Stage 1
9 693.8
8 499.9
98 351
2.1
14 597.3
1.54%
42.08%
87.5
Stage 2
0% - 0.14%
0.4
0.5
22
8.0
1.0
0.12%
33.76%
0.0
0.15% - 0.24%
1.2
0.4
25
4.8
1.5
0.21%
25.85%
0.0
0.25% - 0.49%
6.2
27.3
163
1.6
24.3
0.45%
44.83%
0.1
0.50% - 0.74%
39.5
76.1
179
1.1
92.7
0.62%
38.06%
0.3
0.75% - 2.49%
298.7
256.0
871
1.8
350.8
1.39%
35.28%
2.5
2.50% - 9.99%
222.5
83.0
1 311
2.3
234.2
5.90%
34.02%
6.8
10.00% - 44.99%
120.0
1.7
1 890
4.8
121.7
23.45%
24.31%
11.7
45.00% - 100.00%
31.9
0.2
589
4.7
31.8
59.20%
24.02%
5.7
Total Stage 2
720.3
445.3
5 050
2.4
858.2
7.79%
33.52%
27.1
Total Stage 1+2
10 414.1
8 945.2
103 401
2.2
15 455.5
1.89%
41.61%
114.6
* EAD after credit risk mitigation and application of the credit conversion factor
** For Stage 2 - ECL Lifetime
104
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Distribution of Stage 3 and POCI portfolio by time in default for Other Corporate segment (PLN mln):
31.12.2024
Time in default
Number of exposures
EAD*
Average LGD (%)
ECL**
Stage 3
<12 months
1 561
364.2
25.80%
94.0
13 - 24 months
906
123.0
36.21%
44.6
25 - 36 months
459
15.4
53.58%
8.3
37 - 48 months
202
7.5
69.12%
5.2
49 - 60 months
149
35.5
45.44%
16.2
61 - 84 months
192
32.2
71.90%
23.1
> 84 months
90
37.1
59.53%
22.1
Total Stage 3
3 559
614.9
34.69%
213.3
POCI
Non-Default
1
0.0
0.00%
0.0
<12 months
0
0.0
0.00%
0.0
13 - 24 months
0
0.0
0.00%
0.0
25 - 36 months
1
18.7
19.35%
3.6
37 - 48 months
0
0.0
0.00%
0.0
49 - 60 months
0
0.0
0.00%
0.0
61 - 84 months
1
0.0
97.49%
0.0
> 84 months
0
0.0
0.00%
0.0
Total POCI
3
18.7
19.36%
3.6
Total Stage 3+POCI
3 562
633.5
34.23%
216.9
31.12.2023
Stage 3
<12 months
1 275
253.8
20.92%
53.1
13 - 24 months
590
36.3
48.94%
17.8
25 - 36 months
295
12.5
64.94%
8.1
37 - 48 months
184
48.4
33.20%
16.1
49 - 60 months
154
33.7
76.48%
25.8
61 - 84 months
105
5.1
58.71%
3.0
> 84 months
110
39.2
61.61%
24.2
Total Stage 3
2 713
429.1
34.49%
148.0
POCI
Non-Default
1
0.3
54.66%
0.0
<12 months
0
0.0
0.00%
0.0
13 - 24 months
1
19.6
9.14%
1.8
25 - 36 months
0
0.0
0.00%
0.0
37 - 48 months
0
0.0
0.00%
0.0
49 - 60 months
1
0.0
81.45%
0.0
61 - 84 months
1
8.3
19.88%
1.7
> 84 months
0
0.0
0.00%
0.0
Total POCI
4
28.2
12.82%
3.4
Total Stage 3+POCI
2 717
457.3
33.15%
151.4
* EAD after credit risk mitigation and application of the credit conversion factor
** For POCI – current ECL value (not provisions
105
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Compared to the year 2023, the average 12-month PD for Stage 1/2 in Leasing increased from 4.28%
to 4.44%. There was observed deterioration of the average LGD for Stage 1/2 (24.57% vs. 21.25% in
2023). The average Stage 3 LGD decreased from 28.83% to 22.28% which is the effect changing
portfolio’s structure in terms of time in default.
Distribution of non-defaulted portfolio by 12-month PD for Leasing segment (PLN mln):
31.12.2024
PD scale
Gross
balance
exposure
Off-
balance
exposure
Number of
exposures
Average
maturity
(yrs)
EAD*
Average
PD (%)
Average
LGD (%)
ECL**
Stage 1
0% - 0.14%
308.4
0.0
2 792
3.3
308.4
0.07%
23.63%
0.1
0.15% - 0.24%
73.2
0.0
551
3.5
73.2
0.19%
22.34%
0.0
0.25% - 0.49%
175.5
0.0
1 892
3.1
175.5
0.32%
25.22%
0.1
0.50% - 0.74%
216.7
0.0
1 926
3.1
216.7
0.57%
27.43%
0.3
0.75% - 2.49%
1 011.4
0.0
9 959
2.7
1 011.4
1.49%
28.03%
3.9
2.50% - 9.99%
4 237.9
0.0
37 970
3.3
4 237.9
4.36%
23.96%
41.1
10.00% - 44.99%
18.8
0.0
213
3.4
18.8
17.25%
23.15%
0.7
45.00% - 100.00%
0.0
0.0
0
0.0
0.0
0.00%
0.00%
0.0
Total Stage 1
6 041.8
0.0
55 303
3.2
6 041.8
3.40%
24.76%
46.3
Stage 2
0% - 0.14%
2.2
0.0
37
1.3
2.2
0.09%
11.38%
0.0
0.15% - 0.24%
0.4
0.0
29
1.3
0.4
0.20%
16.75%
0.0
0.25% - 0.49%
4.9
0.0
91
1.9
4.9
0.33%
21.93%
0.0
0.50% - 0.74%
4.0
0.0
79
2.3
4.0
0.59%
19.60%
0.0
0.75% - 2.49%
46.8
0.0
479
2.3
46.8
1.47%
25.18%
0.3
2.50% - 9.99%
354.5
0.0
2 994
3.2
354.5
4.49%
22.55%
6.1
10.00% - 44.99%
98.0
0.0
851
2.8
98.0
34.21%
22.78%
8.4
45.00% - 100.00%
78.7
0.0
836
3.1
78.7
49.90%
21.62%
9.2
Total Stage 2
589.5
0.0
5 396
3.0
589.5
15.17%
22.60%
24.0
Total Stage 1+2
6 631.4
0.0
60 699
3.1
6 631.4
4.44%
24.57%
70.3
31.12.2023
Stage 1
0% - 0.14%
195.8
0.0
1 359
2.9
195.8
0.08%
20.50%
0.0
0.15% - 0.24%
103.0
0.0
829
2.7
103.0
0.20%
21.35%
0.0
0.25% - 0.49%
303.7
0.0
3 362
2.7
303.7
0.36%
22.69%
0.2
0.50% - 0.74%
354.3
0.0
2 964
2.9
354.3
0.61%
21.53%
0.4
0.75% - 2.49%
1 082.7
0.0
9 987
3.0
1 082.7
1.57%
23.94%
4.0
2.50% - 9.99%
3 674.8
0.0
37 972
3.1
3 674.8
4.30%
20.81%
29.9
10.00% - 44.99%
3.2
0.0
56
3.2
3.2
18.13%
15.86%
0.1
45.00% - 100.00%
0.0
0.0
0
0.0
0.0
0.00%
0.00%
0.0
Total Stage 1
5 717.6
0.0
56 529
3.0
5 717.6
3.13%
21.54%
34.7
Stage 2
0% - 0.14%
0.8
0.0
33
0.6
0.8
0.08%
5.35%
0.0
0.15% - 0.24%
1.1
0.0
29
1.2
1.1
0.19%
14.48%
0.0
0.25% - 0.49%
6.5
0.0
140
1.1
6.5
0.37%
12.29%
0.0
0.50% - 0.74%
5.8
0.0
64
2.1
5.8
0.60%
19.61%
0.0
0.75% - 2.49%
66.7
0.0
884
2.0
66.7
1.62%
22.07%
0.3
106
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
2.50% - 9.99%
336.7
0.0
2 984
2.9
336.7
4.69%
18.86%
4.0
10.00% - 44.99%
77.2
0.0
718
2.7
77.2
35.62%
15.64%
4.3
45.00% - 100.00%
88.0
0.0
882
3.2
88.0
52.64%
16.86%
7.6
Total Stage 2
582.8
0.0
5 734
2.8
582.8
15.58%
18.41%
16.3
Total Stage 1+2
6 300.3
0.0
62 263
3.0
6 300.3
4.28%
21.25%
51.0
* EAD after credit risk mitigation and application of the credit conversion factor
** For Stage 2 - ECL Lifetime
Distribution of Stage 3 and POCI portfolio by time in default for Leasing segment (PLN mln):
31.12.2024
Time in default
Number of exposures
EAD*
Average LGD (%)
ECL**
Stage 3
<12 months
2 206
229.3
16.21%
37.2
13 - 24 months
1 125
72.0
29.03%
20.9
25 - 36 months
232
21.6
31.69%
6.8
37 - 48 months
431
21.8
54.50%
11.9
49 - 60 months
0
0.0
0.00%
0.0
61 - 84 months
0
0.0
0.00%
0.0
> 84 months
0
0.0
0.00%
0.0
Total Stage 3
3 994
344.7
22.28%
76.8
POCI
Non-Default
0
0.0
0.00%
0.0
<12 months
0
0.0
0.00%
0.0
13 - 24 months
0
0.0
0.00%
0.0
25 - 36 months
0
0.0
0.00%
0.0
37 - 48 months
0
0.0
0.00%
0.0
49 - 60 months
0
0.0
0.00%
0.0
61 - 84 months
0
0.0
0.00%
0.0
> 84 months
0
0.0
0.00%
0.0
Total POCI
0
0.0
0.00%
0.0
Total Stage 3+POCI
3 994
344.7
22.28%
76.8
31.12.2023
Stage 3
<12 months
2 385
249.9
24.05%
60.1
13 - 24 months
869
46.9
42.84%
20.1
25 - 36 months
219
6.3
67.34%
4.2
37 - 48 months
118
4.1
100.00%
4.1
49 - 60 months
0
0.0
0.00%
0.0
61 - 84 months
0
0.0
0.00%
0.0
> 84 months
0
0.0
0.00%
0.0
Total Stage 3
3 591
307.3
28.83%
88.6
POCI
Non-Default
0
0.0
0.00%
0.0
<12 months
0
0.0
0.00%
0.0
13 - 24 months
0
0.0
0.00%
0.0
25 - 36 months
0
0.0
0.00%
0.0
37 - 48 months
0
0.0
0.00%
0.0
107
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
49 - 60 months
0
0.0
0.00%
0.0
61 - 84 months
0
0.0
0.00%
0.0
> 84 months
0
0.0
0.00%
0.0
Total POCI
0
0.0
0.00%
0.0
Total Stage 3+POCI
3 591
307.3
28.83%
88.6
* EAD after credit risk mitigation and application of the credit conversion factor
** For POCI – current ECL value (not provisions)
On 31.12.2024 value of collaterals on accounts or assets of borrowers from the corporate segment
(without leasing) amounted to PLN7,114,218,143.31, while on accounts or assets of mortgage
borrowers (including MBH) amounted to PLN96,587,952,197.92.
11.4. OTHER RISKS
Market Risk and Interest Rate Risk in the Banking Book (IRRBB)
The market risk encompasses current and prospective impact on earnings or capital, arising from
changes in the value of the Group’s portfolio due to adverse market movement (prices).
The interest rate risk arising from Banking Book activities (IRRBB) encompasses current or prospective
impact to both the earnings and the economic value of the Group’s portfolio arising from adverse
movements in interest rates that affect interest rate sensitive instruments. The risk includes gap risk,
basis risk and option risk.
The framework of market risk and interest rate risk management and its control are defined on
a centralized basis with the use of the same concepts and metrics which are used in all the entities
of the BCP Group.
The main measure used by the Group to evaluate market risks is the parametric VaR (Value at Risk)
model – an expected loss that may arise on the portfolio over a specified period (holding period) with
a required probability (confidence level) due to an adverse market movement. The market risk
measurement is carried out daily (intra-day and end-of-day), both on an individual basis for each of
the areas responsible for risk taking and risk management, and in consolidated terms for Global Bank,
Banking Book and Trading Book considering the effect of the diversification that exists between the
portfolios. In addition, each Book is divided into the risk management areas.
In 2024, the VaR limits were not breached for Global Bank and also for Trading and Banking Book. It
should be noted that the value at risk in Banking Book is only complementary risk measurement tool
as positions are expected to be held to maturity and are in large majority not marked to market. All
excesses of market risk limits are always reported, documented, and ratified at the proper
competence level.
Within the current market environment, the Group continued to act very prudently. In 2024, open
positions mostly included interest-rate instruments and FX risk instruments. In 2024, the VaR
indicators for the Group remained on average at the level of 263.2m PLN (48 per cent of the limit)
and 223.4m PLN (39 per cent of the limit) as of the end of December 2024. The current limits in place
have been valid since 30
th
September 2024 and remains conservative - level for Global Bank no more
than 575.5m PLN and for Trading Book no more than 20.8m PLN. FX open position (Intraday as well as
Overnight) remained below 2 per cent of The Own Funds and well below the maximum limits in place.
Apart from daily measurement at the level of each book and market risk area, the VaR model is mainly
applicable and analysed at the Trading Book level, where the policy intention is to trade positions on
the regular basis (mostly daily). On contrary, following the supervisory guidelines, the interest rate
risk in Banking Book is mainly covered by both earnings-based and economic value measures, by
measuring:
- the impact on the net interest income over a time horizon of next 12 months resulting from
one-off interest rate shock of upward/downward yield curve shift by 100 basis points,
108
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
- the impact on net interest income over a time horizon of next 12 months resulting from a
supervisory outlier test (SOT) shocks including parallel up and parallel down scenarios,
- the impact on the economic value of equity (EVE) resulting from 100 bps upward/downward
yield curve movements,
- the impact on the economic value of equity (EVE) resulting from different upward/downward
basis points shocks, including scenarios defined by the supervisor (standard, supervisory test
assuming sudden parallel +/-200 basis points shift of the yield curve as well supervisory outlier
test - SOT with set of six interest rate risk stress scenarios).
Exposure to interest rate risk in the Banking Book are primarily generated by the differences in
repricing dates of assets and liabilities as well as its reference indexes, if contractually existing.
Regarding EVE measures, it is specifically affected by the unbalance between assets and liabilities
that have fixed rate. In case of low interest rates, significant impact is tied to liabilities which cannot
have interest rate lower than 0. Consequently, the level of sensitivity to interest rate changes is
influenced by the level of interest rates taken as a reference. Additionally, due to specificity of the
polish legal system, the interest rate of credits is limited (it cannot exceed two times Reference Rate
of the National Bank of Poland increased by 7 percentage points). In situations of decreasing interest
rates, the impact on Net Interest Income is negative and depends on the structure of the asset
portfolio, including the share of assets subject to immediate revaluation. On the other hand,
assumptions regarding the timing and size of deposits repricing are also very important when assessing
the interest rate sensitivity and risk.
The results of the IRRBB measurement as of the end of December 2024 indicate that the Group is the
most exposed to scenarios of interest rates increase in case of EVE metrics and interest rates decrease
in case of NII metrics. In case of supervisory outlier test for EVE, results as of December 2024 show
that even under the most severe outlier test scenario, the decline of EVE for Banking Book is below
supervisory limit of 15% of Tier 1 Capital.
The results of sensitivity of NII for the next 12 months after 31
st
December 2024 and for position in
Polish Zloty in Banking Book are carried out under the following assumptions:
• static balance sheet structure as of that reference date (no change during the following 12
months),
• reference level of net interest income assuming that all assets and liabilities with variable interest
rate already reflect market interest rates levels as of 31
st
December 2024 (for example, the NBP
Reference rate at the end of 2024 was set at 5.75%),
• application of a parallel move of 100 bps in the yield curve up and down is an additional shock to
all market interest rates levels as of 31
st
December 2024 and is set at the repricing date of the
assets and liabilities that happens during the 12 following months
In a scenario of parallel decrease of interest rates for position in Polish Zloty by 100 bps, the results
are positive and equal to PLN4mn or 0.08% of the Group’s NII reference level. In a scenario of parallel
increase of interest rates for position in Polish Zloty by 100 bps, the results are positive and equal to
+PLN3mn or +0.05% of the Group’s NII reference level. The results show that the Group is now in
balanced situation regarding strength in the scenario of a decline or increase in interest rates. At the
same time, the results indicate that the Group is immaterially sensitive to a change in interest rates
in Polish Zloty by 100 bps over a 12-month horizon – significantly below the limit set (10% of the
reference interest income for the last 12 months).
For positions in all significant currencies (PLN, CHF, EUR, USD) the impact of parallel decrease of
interest rates by 100 bps is equal to -PLN27mn or -0.49% of the Group’s NII reference level. In a
scenario of parallel increase of interest rates by 100 bps, the results are positive and equal to
+PLN27mn or +0.49% of the Group’s NII reference level. The Group also meets the limit of the
Supervisory Outlier Test for the measure of net interest income, which is defined at 5% of Tier 1
capital.
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More information on market risk and interest rate risk management can be found in chapter 8.4 of
the Annual Consolidated Report of the Bank Millennium S.A. Capital Group for the 12-month period
ending 31
st
December 2024.
Liquidity risk
Liquidity risk reflects the possibility of incurring significant losses because of deteriorated financing
conditions (financing risk) and/or of the sale of assets for less than their market value (market
liquidity risk) to meet the funding needs arising from the Group’s obligations.
The process of the Group’s planning and budgeting covers the preparation of a Liquidity Plan to make
sure that the growth of business will be supported by an appropriate liquidity financing structure and
supervisory requirements in terms of quantitative liquidity measures will be met.
In 2024, the Group continued to be characterized by solid liquidity position. All the supervisory and
internal liquidity indicators remained significantly above minimum limits in place. The steps taken as
part of standard and binding risk management procedures have proved sufficient for managing
liquidity in the current market environment. In 2024, in consequences of the increase of the deposits
from Customers at the faster pace than loans, there was further improvement of the Group’s Loan-
to-Deposit ratio to 64 per cent at the end of December 2024 (comparing to level of 69 per cent as of
end of December 2023).
The liquid assets portfolio is treated by the Group’s as liquidity reserve, which will overcome crisis
situations. This portfolio consists of liquid debt securities issued or guaranteed by Polish government,
other EU’s sovereigns, European Union and multilateral development banks’, supplemented by the
cash and exposures to the National Bank of Poland. At the end of 2024, the share of liquid debt
securities (including NBP Bills) in total securities portfolio amounted to 99.9% and allowed to reach
the level of approx. PLN 53.9bn (39 per cent of total assets), whereas at the end of December 2023
was at the level of approx. PLN 40.9bn (33 per cent of total assets).
Main liquidity ratios
31.12.2024
31.12.2023
Loans/Deposits ratio (%)
64%
69%
Liquid assets portfolio (PLNmn)*
53 646
41 529
Liquidity Coverage requirement, LCR (%)
371%
327%
Net Stable Funding Ratio, NSFR (%)
196%
180%
Long-term Funding Ratio, LTFR**
28%
(*) Liquid Assets Portfolio: The sum of cash, nostro balance (reduced by the required obligatory reserve), unencumbered liquid
securities portfolio, NBP-Bills and short-term, due from banks (up to 1 month); (**) Long-term Funding Ratio enters into force
on Dec 31, 2026
Consequently, the large, diversified, and stable funding from retail, corporate and public sector
Clients remains the main source of financing of the Group. At the end of 2024, the source of medium-
term funding included subordinated debt, own EUR bonds issue and securitization of loan and leasing
portfolios, as well as covered bonds issued by Millennium Bank Hipoteczny (mortgage bank).
The Group manages its FX liquidity using FX-denominated deposits, own issue of EUR bonds as well as
Cross Currency Swap and FX Swap transactions. The importance of swaps has been decreasing because
of the reduction of the FX mortgage loan portfolio and the hedge in foreign currency of most of the
provisions for legal risk. For most counterparties, the Bank has signed a Credit Support Annex to the
master agreements.
The estimation of the Group’s liquidity risk is carried out both with the use of the ratios defined by
the supervisory authorities and own indicators, for which exposure limits were also established.
According to the final provisions of CRD V/CRR II package, the Group is calculating the liquidity
coverage requirement (LCR) and the net stable funding ratio (NSFR). The regulatory minimum of 100%
for both LCR and NSFR was compiled by the Group. LCR improved substantially during 2024 and
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reached the level of 371% at the end of December 2024 (327% as of the end of December 2023). The
increase was mainly connected with increase of deposit from retail Clients, which was invested in
liquid assets portfolio. The measure is calculated daily and has been reported on the monthly basis
to NBP since March 2014. Internally, the LCR is estimated daily and reported to the areas responsible
for the management and control of the liquidity risk in the Group. NSFR is monitored and reported
monthly. In 2024, the NSFR was above the supervisory minimum of 100% (supervisory minimum valid
since June 2021). NSFR reached the level of 196% at the end of December 2024 (180% as of the end
of December 2023). Moreover, in line with Recommendation WFD (issued in July 2024), the Group is
calculating monthly Long Term Funding Ratio (LTFR/WFD), which in December 2024 reached 28.0%.
Additionally, the Group employs an internal structural liquidity analysis based on cumulative
behaviour liquidity gaps. In 2024 all the liquidity gaps were maintained positive. The safe level
adopted by the Group for the ratio of liquidity shortfall is established for each time bucket below 5
years at the level of 12 per cent of total assets.
Liquidity stress tests are performed at least quarterly, to understand the Group’s liquidity-risk profile
and to ensure that the Group can fulfil its obligations in the event of a liquidity crisis and to update
the Liquidity Contingency Plan and management decisions. As of December 2024, the results of the
stress test analysis demonstrated that liquidity position is not threaten as even in the most severe
scenario the survival period is still significantly above the limit of 3 months.
The liquidity risk management process is regulated in the internal policy that is a subject of the Bank’s
Management Board approval.
The Group has also emergency procedures for situations of increased liquidity risk – the Liquidity
Contingency Plan. The Liquidity Contingency Plan establishes the concepts, priorities, responsibilities,
and specific measures to be taken in the event of a liquidity crisis. The Liquidity Contingency Plan is
tested and revised at least once a year. The revised Plan was approved by the Supervisory Board in
November 2024.
More information on liquidity risk management can be found in chapter 8.5 of the Annual Consolidated
Report of the Bank Millennium S.A. Capital Group for the 12-month period ending 31
st
December 2024.
Operational risk
Operational risk management is based on the processes structure implemented in the Group and
overlapping the traditional organizational structure. Current management of the specific processes,
including the management of the profile of process operational risk, is entrusted to Process Owners,
who report to all other units participating in the risk management process and are supported by these
units.
To manage the fraud risk, the Group has in its structure a special organizational unit to develop,
implement and monitor the Group’s policy for management of this risk in cooperation with other
organizational units of the Group and in accordance with its internal regulations. Fraud Risk
Management Sub-unit in the Security Department is a centre of competence for the fraud prevention
process.
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Non-compliance risk
Lack of compliance of the Bank’s operations with binding laws, internal regulations, and market
standards is linked with the risk of legal and regulatory sanctions, material, or reputation losses.
Therefore, it is one of the areas threatening the banking activity. By monitoring compliance with both
internal and external regulations, Bank Millennium considers it to be particularly important:
▪ Preventing money laundering and financing of terrorism,
▪ Ensuring consistency of Bank Millennium’s internal normative acts with binding laws as well
as recommendations issued by supervisory authorities,
▪ Counteracting and managing conflicts of interest,
▪ Counteracting corruption,
▪ Observance of ethical principles,
▪ Monitoring personal transactions and protecting confidential information related to Bank
Millennium, financial instruments issued by the Bank as well as information connected with
purchase/sale of such instruments,
▪ Monitoring and ensuring compliance of products and services, including investment products
and services covered by MiFID II Directive.
Bank Millennium undertakes appropriate actions for the purpose of ongoing and continuous tracking
of changes occurring in binding legal regulations as well as recommendations and guidance given by
supervisory authorities, both national as well as of the European Union. To ensure compliance of the
Bank's operation with the applicable laws, the Compliance Department undertakes several activities
such as:
1) informing about changes in law,
2) analysis of internal normative acts binding at the Bank in terms of compliance with applicable
laws and standards,
3) analysing new products and services and changes in products and services,
4) measuring compliance risk in processes operating at the Bank,
5) participating in key implementation projects, and
6) staff training.
The Bank’s operations may generate a conflict of interest between Bank’s interests and the interests
of Customers. The Bank’s main principle is to take all reasonable steps to identify a conflict of interest
between the Bank and its Customers, as well as between individual Customers, and to establish rules
ensuring that such conflicts have no adverse impact on Customers’ interests.
The Bank Millennium Group undertakes also appropriate actions to ensure conduct concerning
personal transactions, which is compliant with standards and laws. These actions and measures are
meant to, according to the circumstances, to restrict or prevent performance of personal transactions
by relevant persons in situations, which may cause a conflict of interest or be involved with access to
confidential information or to data about Customers’ transactions.
Shares of Bank Millennium are admitted to public trading on the Warsaw Stock Exchange. Such status
requires special attention and observance of the obligation to maintain highest standards for
transparency of financial markets. The policy of Bank Millennium is to maintain strict control as
regards protection of the flow of confidential information (including in accordance with the
requirements of Regulation No. 596/2014 of the European Parliament and of the Council of 16 April
2014 on abuses on the market abuse, MAR). The Bank prohibits the use and disclosure of confidential
information in any form. Purchasing and selling by persons discharging managerial responsibilities, of
the Bank’s shares, debt instruments of the Bank or derivatives or other financial instruments linked
to them is forbidden during closed periods.
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The Anti-Money Laundering and Counter Terrorism Financing programme (AML/CTF), applied by the
Bank Millennium, is a comprehensive system of identification of threats related to money laundering
crimes.
Actions launched under this programme include in particular:
▪ application of financial security measures to Customers, depending on the degree of risk and
based on „Know your Client” or (KYC) principle – the key concept of the program,
▪ transaction registration and reporting,
▪ identification of suspicious transactions,
▪ cooperation with the General Inspector of Financial Information.
Bank Millennium adjusts its reports to the analysis of suspected transactions on the on-going basis,
considering up-to-date patterns (sectors, cash-flow routes, Customer behaviour) for effective
identification and reporting of transactions suspected of money laundering. Implemented internal
procedures, organizational solutions and employee training programmes ensure efficient operation of
the programme.
Bank Millennium, with view to protecting Customers who invest their funds in investment products
with varied degree of risk, strictly monitors compliance of these products, their offering and handling
process with relevant internal regulations, laws, and external guidelines – on the domestic and
European Union level. A specific compliance monitoring programme also covers consumer loans and
insurance products (including insurance–investment products) addressed to consumers.
The Bank Millennium has mechanisms and internal regulations allowing for anonymous reporting of
violations of law and internal regulations and ethical standards (the so-called whistleblowing) to the
Chairman of the Management Board, and in the case of notification concerning a Member of the
Management Board - to the Supervisory Board. The Bank Millennium will verify each application,
ensuring that the reporting person will be protected by acts of repressive, discriminatory, and unfair
nature.
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12. HUMAN RESOURCES MANAGEMENT
12.1. HUMAN RESOURCES (HR) POLICY
The Human Resources (HR) policy is based on the mission and values of Bank Millennium and defines
the framework for the functioning of the HR area in the Bank Millennium Group, referring to both the
HR management model and the regulations that constitute the legal basis for the HR management
system in the Bank Millennium Group.
The HR Policy defines the main areas of HR activities, such as recruitment and onboarding,
remuneration and benefits, training and development, leadership, employee opinion surveys,
digitalisation of processes and HR data analysis, defines objectives in these areas that result from the
Bank Millennium Group's strategy and HR itself, and refers to the ambitions and aspirations that HR is
guided by.
The HR Strategy is based on the assumptions of the HR Policy and is also part of Bank Millennium's
business strategy "Growth and Value", which was announced for 2025-2028, constituting an
important element supporting its implementation. The strategic objectives of HR for the strategic
period are:
1. Support for business lines, primarily corporations and small businesses, in the form of
recruitment, ensuring effective onboarding, training and development, and continuing extensive
development activities for retail banking employees;
2. Active work on employee satisfaction and increasingly better results of Top Employer
certification to ensure that Bank Millennium is considered the possibly best place to work;
3. An active remuneration policy to ensure employee retention, job satisfaction and to enable
the recruitment of new people to Bank Millennium;
4. Supporting activities in the area of organisational culture, which should be conducive to the
implementation of the Bank strategy;
5. Digitalisation of HR processes and increasingly better implementation of HR services.
HR policy means strategic activities in the field of human resources management support the business
needs of the Bank Millennium Group in order to create a friendly, development-oriented and safe
workplace.
Friendly workplace
Bank Millennium creates a good working environment for employees regardless of gender, age, race,
religion, nationality, ethnic origin, disability, political beliefs, trade union membership and sexual
orientation, who find here conditions for professional development in an atmosphere of cooperation
and mutual respect.
Therefore, in 2024 Bank Millennium became the winner of a number of awards, which can be found
in chapter 10 of this report. The Bank was recognised for its activities for the benefit of employees,
responsible management, supporting diversity and sustainable development.
Bank and Bank Millennium Group also reward their employees.
• In 2024, the IMPAKT Employee Rewards Program, in which employees reward their
colleagues, was continued. The program integrates the community, builds a culture of
cooperation and mutual appreciation. In 2024, 58 employees were awarded for their
commitment, quality improvement, innovative solutions and taking on challenges that inspire
others.
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• The best employees and managers are given the Chairman's Awards for above-average
professional achievements once a year. In 2024, they were distributed to 11 employees from
the head office and sales network.
Competence development
The Bank continued to implement extensive training programs for business lines, in particular those
that enable both on-boarding of new employees and ensure their development during their work in
the organisation. The trainings were addressed in particular to employees of retail and franchise
networks, direct banking employees, corporate banking advisors, those from affluent customer
banking and people involved in the sale of insurance products. They covered a wide variety of issues
necessary for the effective performance of tasks, in particular issues related to sales techniques,
customer service models and knowledge of the Bank’s products and systems.
The development of managers is carried out on many levels.
Consistently, for several years, the M#leaders leadership skills development program has been
implemented. The programme is based on the John Maxwell methodology used in the Bank Millennium
Group and includes several dozen hours of workshops at the basic and advanced levels.
Managers also develop their competences by using access to the Youniversity streaming service,
which gives access to knowledge in dozens of thematic areas important in management.
Individual development needs are met through access to the Coachhub coaching platform. As part
of individual meetings, managers can identify and select areas for development, and then - with the
help of a certified coach - achieve the set goals. The programme is carried out online. Thanks to this,
you can develop anywhere and at any time preferred by the employee.
People entering the managerial path use a solution focused on learning basic and intermediate
managerial tools. The process consists of a diverse set of development activities – from a group
development session, through an advanced competence diagnosis, implementation of skills in practice
and many weeks of support from a mentor experienced in business.
A separate managerial certification program, supporting managers of retail outlets, is implemented
in retail banking.
The Bank ran a programme of lectures as part of Development Fridays, which was highly appreciated
by its employees. The purpose of the "Development Fridays" programme is to support the sharing of
knowledge and experience of employees. The speakers are specialists of the Bank Millennium Group
and the proposal to participate in the programme is addressed to all employees. Lectures are
conducted online, recordings with additional materials are made available on the training platform
and on the "Millennium World" intranet.
The Bank Millennium Group also supports the development of employees through a wide range of e-
learning courses. The bank uses a specialized platform that allows it to manage both the content and
the course of training processes.
Supporting the development of digital technologies
Bank Millennium is one of the most modern banks on the market, which is based on the development
of information technologies. Bank Millennium won the "Mobile Bank" ranking of the cashless.pl service.
The ranking presents banks that best meet the requirements of modern customers who prefer to use
financial services on mobile devices.
The bank also received a number of awards for digital channels:
• Newsweek's Friendly Bank – 1st place in the Remote Banking category
• Best Digital Retail Bank in Poland and 13 other titles in the Global Finance Best Digital
Bank 2024 competition for digital solutions for individual and corporate clients
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• Institution of the Year 2024 - Best Remote Account Opening Process
• Institution of the Year 2024 – 2nd place for the mobile app
• Institution of the Year 2024 – 4th place for online banking
• Golden Banker – 2nd place – Electronic banking (online/mobile)
• PayTech Awards – award for omnichannel credit card application
• Global Finance Top Innovator Award for Business Apps for Best UX
• Mobile Trends Awards – nomination for applications for companies
• The Digital Banker Global Retail Awards 2024 – Best Banking App for SME
The awards received and the results in the rankings confirm that Bank Millennium's activities are a
response to the changing needs of customers and that the digital offer is constantly being improved.
The Bank constantly maintains and develops large teams of IT specialists in various fields.
Diversity policy
When implementing the Diversity Policy, the Bank operates with respect for human dignity and
observes the right to equal treatment regardless of age, gender, ethnic and national origin, religion,
denomination, family status, sexual orientation, health condition, beliefs, trade union membership
and other premises exposing to discriminatory behaviour. The Bank is also a signatory of the Diversity
Charter, which is a commitment signed by organisations that decide to prohibit discrimination in the
workplace and work to create and promote diversity. Respect for diversity in the Bank Group is also
regulated by the Code of Ethics, the Work Regulations and recruitment regulations. The
implementation of these policies has resulted in a number of actions:
• All employees undergo mandatory training on ethical issues. In addition, the managerial
staff is trained in counteracting mobbing and discrimination in employment. The Bank
has anti-mobbing and anti-discrimination procedures in place. There is a system for
reporting abuse, which is independent of the hierarchy.
• When recruiting employees, criteria exposing them to discriminatory behaviour are
not applied. These rules also apply to termination of employment, terms of employment,
promotion and access to training to improve professional qualifications. Candidates are
selected on the basis of objective criteria, such as, in particular: education, professional
experience, general and specific competences, knowledge of foreign languages and
general fit to the profile.
• The Bank analyses the remuneration structure and equality in access to earnings and
positions on an ongoing basis due to gender, age and nationality. Periodically, interviews
are conducted with people leaving the Bank to determine the reasons for leaving.
• Benefits such as medical care, group insurance, co-financing of sports and recreation,
and culture are offered to all employees, including those who work part-time. Employees
are provided with a "cafeteria where they have access to a wide range of benefits." The
bank encourages employees to use up their holidays.
• The Bank supports people in a difficult financial and health situation through the
existing social assistance system based on the Company Social Benefits Fund.
• Persons with disabilities can use office infrastructure adapted to their abilities.
• The Bank regularly conducts managerial training aimed at strengthening appropriate
attitudes – including overcoming stereotypes and promoting openness to diverse beliefs
of employees and shaping their own and subordinate responsibility.
• Employees have the opportunity to freely present their opinions on internal Internet
forums.
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• The Bank conducted training for managerial staff on managing a multigenerational team.
• The Bank conducts development initiatives available to all employees. "Diversity is OK!"
It is an initiative that supports diversity. Regular meetings are organised with speakers
who are specialists, scientists, and public figures to educate employees in the field of
multigenerationality, cultural differences, disability, gender identity, gender equality,
levelling the pay gap, and neurodiversity. Such activities allow for a better understanding
of diversity, noticing different points of view, creating a synergy effect from differences
and looking for non-standard solutions for both employees and customers to level the
playing field and create more opportunities. Recordings and meeting materials are
available to employees in the internal training platform and in the Millennium World, on
a separate intranet website.
The me zone is a separate space on the Intranet that was created to take care of the well-being of
employees. The website with recordings and materials as well as activities are available to all
employees. In addition to webinars on health and building mental resilience, differences and coping
with social and professional roles of women and men, the Bank organised the Week for Health and an
oncological prevention campaign.
The Bank allows the use of tickets to selected amusement parks for employees and their children
during the summer and Christmas holidays. Campaigns of this type are aimed at inspiring employees
to spend time together with their loved ones.
• The Bank promotes and encourages volunteering activities. For the 11th time, the Christmas
Charity Auction was organized, during which people employed at Bank Millennium put up
among others hand-made items for auction. PLN 66,736 was collected, and by the decision of
the Management Board of Bank Millennium this amount was doubled and divided equally
among all beneficiaries of Bank Millennium.
• The Bank, together with the Bank Millennium Foundation, encourages all employees to
volunteer activities. Employees have the opportunity to support ecology, education and
culture. 2024 was a breakthrough year for the Bank Millennium Foundation, full of successfully
implemented initiatives for the benefit of local communities: children and their parents, the
environment and culture. The Sports Challenge Our People'24: Save the Planet is a charity
initiative organised by the Bank Millennium Foundation and Bank Millennium, which aims to
promote a healthy lifestyle and protect the environment. The challenge lasted three months
and involved 1433 Bank Millennium employees in regular physical activity, collecting points
and competing both individually and in teams. Finally, Bank Millennium donated PLN 250,000
to the Bank Millennium Foundation for the implementation and promotion of volunteering. As
part of Save the Planet, volunteers of Bank Millennium and the Bank Millennium Foundation
organised Eco-initiatives and Actions to help people affected by the flood.
At Bank Millennium, women make up the majority of employees - 65%. Their share in the Bank's
management team (starting from the position of branch manager) was about 54%. Although the share
of women in senior management has been steadily increasing in recent years, they are still under-
represented and account for 33% of this group.
The Bank's strategy, including, for example, building units to serve foreigners working in Poland, also
serves to increase the diversity of employees in terms of nationality: in 2024, 40 foreigners were
employed.
The age structure of employees is relatively balanced, with people both entering the labour market
and people at the end of their professional careers being employed. The largest group of employees
are people between 30 and 50 years of age – over 65%. Young people up to 30 years of age - 20%.
In connection with the long-term development strategy, the Bank will strive to further take into
account diversity in terms of competences and professional experience of employees in its human
resources management policy.
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12.2. EMPLOYMENT AND PERSONNEL COSTS
Effectiveness of human resources management is an important element of the Bank Millennium Group'
strategy. The Group monitors both individual personnel cost items and the level of FTEs, and for
several years has been pursuing a policy of stable employment. Employee turnover is monitored and
reported on an ongoing basis. Employment levels and resource efficiency are verified against relevant
market benchmarks.
Employment in the Group
(full-time)
31.12.2024
31.12.2023
Change (y/y)
Number of the Bank employees
6 450
6 460
-10
- including key positions
171
172
-1
Subsidiaries
264
287
-23
Total Bank Group
6 714
6 747
-34
Employment in the Bank Millennium Group at the end of 2024 reached 6,714 FTEs, which means a
decrease by 10 FTEs (i.e. 0.5%) compared to the end of 2023. The largest employer in the Group is
Bank Millennium, employing 6,450 FTEs at the end of 2024. At the end of the year, Bank Millennium
Group subsidiaries employed a total of 264 FTEs, of which the most important were Millennium
Leasing, Millennium TFI and Millennium Bank Hipoteczny.
Employment in the Bank
(full-time)
31.12.2024
31.12.2023
Change (y/y)
Branches and direct sales
3 806
3 962
-157
Head office
2 644
2 498
147
Total Bank Millennium
6 450
6 460
-10
The employment structure of Bank Millennium shows a definite predominance of people employed
directly in the sale of banking products and services, including primarily in the network of the Bank's
branches located throughout the country.
Employment in the Bank
(full-time)
31.12.2024
31.12.2023
Change (y/y)
Direct banking
801
806
-5
Digital technologies
700
666
33
Retail and corporate banking
3 004
3 156
-152
Support units
1 945
1 832
113
Total Bank Millennium
6 450
6 460
-10
The remuneration policy of the Bank Millennium Group is aimed at ensuring that the remuneration of
employees is adequate to the current tasks, competences and responsibilities.
In particular, great importance is attached to the proper formation of the basic salary. On the basis
of internal reports, the Bank assesses and verifies the level of remuneration in relation to specific
categories of employees. We are committed to ensuring consistency in the remuneration system and
maintaining a balance in the way employees who perform the same work or work of the same value
are remunerated. Salary levels are verified taking into account periodic performance assessments and
possible evolution of the level of skills involved in the implementation of the organisation's tasks. The
analyses also take into account salary benchmarks on the financial market.
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The total level of personnel costs in the Bank Millennium Group in 2024 and the previous year was as
follows:
Personnel costs
(in PLN million)
2024
2023
Change (y/y)
Bank Millennium
1 138.0
982.4
15.8%
Subsidiaries
58.8
52.3
12.6%
Total Bank Millennium Group
1 196.9
1 034.6
15.7%
12.3. REMUNERATION POLICY
The Bank Millennium Group has in place the "Employee Remuneration Policy in the Bank Millennium
Group", which formulates the assumptions used in shaping the components of fixed and variable
remuneration for all employees of the Group.
According to the policy, the main source of income for employees is the basic salary resulting from
employment contracts. Variable remuneration is an additional, motivational element of the total
remuneration. The basic salary of an employee is determined in relation to the tasks performed in a
given organisational unit, the scope of responsibility, qualifications, impact on the company's risk
profile and on the basis of the analysis of salary information presented in salary surveys on the
financial market.
The Bank conducts periodic reviews of salaries and positions. The Bank's Management Board may
decide to allocate a pool of funds to be used to change the base salaries of employees, after assessing
the Group's financial condition and business environment, including current reports on remuneration
levels in the financial sector.
Individual pay rates are verified taking into account periodic assessment of work performance, the
scope of the employee's tasks and skills, and are also compared with data on market wages for
positions with a similar scope of competences. The gender pay gap is also being analysed, taking into
account the differences in the level of pay between men and women in similar positions.
Variable remuneration is shaped as part of various bonus systems, the purpose of which is to motivate
employees to achieve business and organisational goals. Bonus systems and periodic evaluation
criteria in the Bank Millennium Group are tailored to the specific nature of employees' activities in
individual areas of the Group. The amount of bonus budgets granted for bonus payments is determined
after an analysis of capital and liquidity ratios and depending on the degree of achievement of Bank
Millennium's operating results. In the case of employees of business lines, budgets can also be linked
to the achievement of the goals of individual lines. It is assumed that individual bonuses cannot
exceed 100% of the total annual basic salary. Individual bonuses are awarded as part of the variable
remuneration pool based on the assessment of the quality of work and the degree of commitment to
achieving the goals set for employees.
The Bank Millennium Group attaches importance to the proper formation of remuneration of
employees in managerial positions, who are classified as Risk Takers. The rules for granting variable
remuneration to Members of the Management Board of Bank Millennium and other Risk Takers are
included in the "Remuneration policy with respect to Risk Takers in the Bank Millennium SA Group".
The policy is reviewed annually.
The bonus pool for Risk Takers is determined after a prior analysis of the Bank's situation in terms of:
• results of the Bank Millennium Group,
• the level of the capital adequacy ratio at the individual and consolidated level,
• the level of risk ratios relating to the liquidity of the Bank Millennium Group.
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Performance evaluation includes financial and non-financial criteria and takes place over a period
of at least three years.
Rules applicable to the payment of variable remuneration paid in 2024 for 2023:
Risk Takers - Members of the Management Board of Bank Millennium (Risk Takers I)
50% of the value of variable remuneration components is awarded and paid after the end of the
settlement period and after the announcement of financial results. The payment of 50% of the
variable remuneration is deferred for 5 years, payable in equal annual instalments. Members of the
Management Board will receive each part of the bonus granted – paid in the year following the
settlement period and deferred – after re-evaluation - a half in cash and half in the form of financial
instruments. The part of the bonus paid in the form of financial instruments is retained for 12 months.
Other Risk Takers (non-Management Board) (Risk Takers II)
60% of the value of variable components of remuneration for the previous year is awarded and paid
after the end of the settlement period. The payment of the remaining 40% of the variable
remuneration is deferred for 5 years, payable after re-evaluation, in equal annual instalments. A
minimum of 50% of the variable remuneration is, as a rule, paid in the form of financial instruments.
Part of the bonus paid in the form of financial instruments is subject to retention for 12 months.
The Personnel Committee of the Bank's Management Board has the right to decide not to postpone
variable remuneration in an amount below a certain value. When the bonus amount set for a Risk
Taker II for a given calendar year does not exceed the equivalent of EUR 50,000 and 1/3 of the total
annual salary, the bonus may be paid in full in cash, in a non-deferred form, on the basis of a decision
made by the Personnel Committee of the Bank's Management Board.
As part of the bonus programme for Risk Takers II for 2023, in 2024 bonuses were awarded in full in
cash without the application of the deferral mechanism.
Remuneration of the Management Board
Determining the terms of contracts and remuneration for Members of the Management Board is the
competence of the Supervisory Board, taking into account the recommendations of the Personnel
Committee of the Supervisory Board responsible for supervising the remuneration policy. The
framework for remunerating Members of the Management Board and the Supervisory Board is defined
in the "Remuneration Policy with regard to Members of the Management Board and Supervisory Board
of Bank Millennium SA" adopted by the General Meeting of Shareholders.
The Policy is one of the tools for the implementation of the Bank's business strategy, long-term
interests and stability, supporting proper and effective risk management and mitigation of conflicts
of interest, in particular by:
a) shaping the appropriate level of individual components of remuneration in relation to the
function performed and the scale of the Bank's operations, taking into account the
transparency of the rules for their creation,
b) making part of the remuneration of Management Board Members dependent on the Bank's
financial and business results,
c) adopting such a structure of fixed and variable remuneration components of Management
Board Members that the motivation directed at obtaining variable remuneration is not a factor
conducive to excessive risk-taking,
d) ensuring only a fixed component of remuneration for Supervisory Board Members and making
it independent of the Bank's financial and business results,
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e) supporting responsible management attitudes in relation to the Bank's long-term business
objectives through a transparent process of evaluation of the Bank's Management Board
Members.
The total remuneration of the Management Board Members consists of a fixed and a variable part.
The variable part of the remuneration may be an annual bonus, which depends on the Bank's result,
the result compared to banks of similar size and the individual assessment of the Management Board
Member.
Decisions on granting bonuses to Management Board Members are made after an analysis of risk,
liquidity and capital ratios, taking into account the following financial criteria:
▪ implementation of planned budgets and indicators established for the managed area of
activity,
▪ comparison with competing banks of similar size (peer banks),
▪ the market criteria established for the period;
and non-financial criteria, in particular:
▪ the overall quality of management in the area of responsibility,
▪ effective leadership and contribution to the Bank's development,
▪ management and supervision of units in the area of responsibility.
The total value of base salaries of Management Board Members for performing this function in 2024
amounted to PLN 12,075 thousand PLN. In addition, the Management Board Members received
payment of part of the annual bonus for 2021, 2022 and 2023 (in cash and phantom shares) and
additional benefits.
Fixed remuneration (basic salary and benefits) of Management Board Members in 2024 (in PLN
thousand)
Name and surname
Basic salary
Medical
ECPs
Additional
benefits*
Joao Bras Jorge
2 622.00
30.09
83.00
1 312.14
Fernando Bicho
1 863.00
30.04
46.93
39.97
Wojciech Haase
1 518.00
15.98
-
-
Andrzej Gliński
1 518.00
30.09
-
-
Wojciech Rybak
1 518.00
4.60
-
-
Antonio Pinto Júnior
1 518.00
4.60
46.71
652.53
Jarosław Hermann
1 518.00
10.42
37.66
-
In total:
12 075.00
125.82
214.30
2 004.64
(*) Additional benefits are mainly related to the costs of stay of foreign Members of the Management Board
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Variable remuneration transferred in 2024 to Members of the Management Board:
Name and surname
Bonuses paid for the years: 2021, 2022 and 2023 (in PLN
thousand)
in cash
in phantom shares
Joao Bras Jorge
662.82
735.10
Fernando Bicho
553.06
604.42
Wojciech Haase
454.10
495.95
Andrzej Gliński
454.10
495.95
Wojciech Rybak
454.10
495.95
Antonio Pinto Júnior
454.10
495.95
Jarosław Hermann
454.10
495.95
In total:
3 486.38
3 819.27
The decision to grant variable remuneration to Management Board Members for 2024 will be made
after the Bank's results are approved by the General Meeting of Shareholders.
Members of the Supervisory Board receive only fixed remuneration for work in Boards and
Committees, which is adequate to their function and the scale of operations of the Bank Millennium
Group.
Policy evaluation
In its annual assessment of the functioning of Bank Millennium S.A.'s remuneration policy, the
Supervisory Board assessed that it was conducted in a stable manner, based on the continuation of
the adopted strategies. The measures taken in 2024 to adapt to the challenges arising from the current
business context of the remuneration policy were positively assessed.
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13. PRINCIPLES OF CORPORATE GOVERNANCE AT BANK MILLENNIUM
13.1. STATEMENT ON THE PRINCIPLES OF CORPORATE GOVERNANCE
APPLIED IN 2023
Corporate governance is a set of rules addressed to governing bodies of companies and their members
as well as defining relations with shareholders and investors.
The set of rules covering the area of Polish financial institutions and companies listed on the Warsaw
Stock Exchange (GPW) are in particular ‘Best Practice for GPW Listed Companies’ (hereinafter
referred to also as ‘Best Practice’) adopted by the Board of the Warsaw Stock Exchange, the
‘Principles of Corporate Governance for Supervised Institutions’ (hereinafter referred to as the
‘Principles’) adopted by the Polish Financial Supervision Authority and Recommendation Z adopted
by the Polish Financial Supervision Authority (hereinafter referred to as the “Recommendation Z”.
The application of corporate governance principles guarantees the transparency of company
operations and strengthens the protection of shareholder rights, also with respect to issues not
regulated by generally applicable laws.
The most important standard of the above-mentioned Best Practice and Principles is the ‘comply or
explain’ rule, This rule means that a company is obliged to apply the principles stipulated in the
document, and in the event of deviation from use of a particular principle the company must clarify
the causes of such conduct and make this fact publicly known in the form of a report by using the
GPW Electronic Information Database (in the case of Best) or by means of a website (in the case of
the Principles).
The Bank, as a publicly traded company, is subject to the following from 2021. Best Practice,
published on the GPW's website at: https://www.gpw.pl/pub/GPW/pdf/DPSN_2021.pdf. As in
previous years, the Bank has complied with the principles of the Best Practice. The Bank's Supervisory
Board's assessment of the application of the Best Practice on 30 January 2025 is confirmation of its
compliance. The results of this assessment indicate that the Bank properly implemented the
requirements formulated in the Best Practice in 2024 and that the solutions and mechanisms applied
in the Bank for the implementation and execution of the Best Practice duly met the objectives of the
regulations in conjunction with the needs of optimal organisation of the Bank's operations.
The Bank, as a financial institution, has also been subject to the Principles since the beginning of
2015, which are available on the KNF's website at:
https://www.knf.gov.pl/dla_rynku/regulacje_i_praktyka/zasady_ladu_korporacyjnego?articleId=488
80&p_id=18. As in previous years, the Bank has complied with the guidelines described in the
Principles, except for the obligation under para. 16 the obligation to conduct the Bank's Management
Board meetings in Polish. The knowledge of the English language by the members of the Bank's
Management Board allows for complete mutual understanding and an appropriate level of
communication during the meetings. Confirmation of their compliance is provided by the evaluation
of the application of the Principles carried out by the Bank's Supervisory Board on 30 January 2025.
The results of this assessment indicate that the Bank has adequately implemented the requirements
formulated in the Principles in 2024 and that the solutions and mechanisms used in the Bank to
implement and carry out the Principles duly take into account the objectives included in the
regulation in conjunction with the needs of optimal organisation of the Bank's activities.
The Bank since 2022 is also subject to the internal governance requirements formulated by the KNF
in Recommendation Z. The document is available on the KNF's website at:
Recommendation_Z_70998.pdf. As in previous years, the Bank complied with the guidelines described
in Recommendation Z. The Bank's compliance with them is confirmed by: the positive assessment of
the scope of application of the internal governance principles at the Bank made by the Bank's
Management Board on 22 January 2025 and the recognition by this body that the solutions and
mechanisms applied at the Bank to implement and implement Recommendation Z, duly met the
objectives of the regulation in conjunction with the needs of optimal organisation of the Bank's
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activities, including in terms of adjusting the Bank's internal governance to the changing internal
situation and environment; and the assessment made on 30 January 2025 by the Bank's Supervisory
Board indicating that the Bank adequately implemented the provisions of Recommendation Z in 2024
and that the solutions and mechanisms used in the Bank to implement and implement
Recommendation Z, adequately met the objectives of the regulation in conjunction with the needs
of optimal organisation of the Bank's operations, including in terms of adapting internal governance
at the Bank to the changing internal situation and environment.
In subsequent years, the GMS adopted the assessment of the manner in which the obligations arising
from the application of the Best Practice were fulfilled, as included in the Report on the activities of
the Bank's Supervisory Board.
13.2. SHAREHOLDERS AND GENERAL MEETING OF SHAREHOLDERS
The General Meeting is the highest governing body of the Bank’s operating in particular on the basis
of the Code of Commercial Companies and the Banking Law, as well as the Bank’s internal regulations,
i.e. the Articles of Association and the Regulations of the General Meeting. The Bank’s Articles of
Association and Regulations of the General Meeting are available from the Bank’s website on the tab:
“About the Bank > Corporate bodies and governance”, link to website
https://www.bankmillennium.pl/about-the-bank/corporate-bodies-and-governance.
These documents describe in detail the functioning of the General Meeting and scope of its
competencies as well as specific rights of the shareholders during the deliberations of a General
Meeting. The competencies of the General Meeting include inter alia making amendments to the
Articles of Association, including change in the amount of the share capital.
As at 31 December 2024, the Bank’s share capital was PLN 1,213,116,777 and was divided into
1,213,116,777 shares with the nominal value of PLN 1 each. Information is presented below, in
accordance with the data held by the Bank, on shareholders holding, directly or indirectly, significant
blocks of shares, together with an indication of the number of shares held by these entities, their
share in the share capital and in the total number of votes at the General Meeting of the Bank.
According to the information available to the Bank, with respect to shareholders holding more than
5% of votes at the General Meeting, as at 31 December 2024, the following entities were the Bank's
shareholders:
Banco Comercial Portugues (BCP), one of the largest private Portuguese bank – as the strategic
investor - holds 50.10% of all the shares of the Bank. The Bank’s significant shareholders are also:
Nationale-Nederlanden Otwarty Fundusz Emerytalny, which held 9.29% of the Bank’s shares, Allianz
Polska Otwarty Fundusz Emerytalny which held 8.97% of the Bank’s shares and Otwarty Fundusz
Emerytalny PZU “Złota Jesień”, which held 5.41% of the Bank’s shares.
The remaining shares, i.e. 26.24% of the share capital, are dispersed among Polish and foreign
shareholders, both institutional and private.
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Shareholders of the Bank as at 31 December 2024
Shareholders
Number of
shares
% stake in share
capital
Number of
votes
% participation
in votes at GM
Banco Comercial Portugues S.A.
607 771 505
50.10
607 771 505
50.10
Nationale-Nederlanden Otwarty
Fundusz Emerytalny
112 638 286
9.29
112 638 286
9.29
Allianz Polska Otwarty Fundusz
Emerytalny
108 832 510
8.97
108 832 510
8.97
Otwarty Fundusz Emerytalny
PZU „Złota Jesień”
65 599 757
5.41
65 599 757
5.41
Shareholders of the Bank as at 31 December 2023
Shareholders
Number of
shares
% stake in share
capital
Number of
votes
% participation
in votes at GM
Banco Comercial Portugues S.A.
607 771 505
50.10
607 771 505
50.10
Nationale-Nederlanden Otwarty
Fundusz Emerytalny
107 970 039
8.90
107 970 039
8.90
Allianz Polska Otwarty Fundusz
Emerytalny
100 990 351
8.32
100 990 351
8.32
Otwarty Fundusz Emerytalny
PZU „Złota Jesień”
65 492 207
5.40
65 492 207
5.40
Data in the tables were ascertained according to the rules described below. With respect to Banco
Comercial Portugues S.A. these are data collected in connection with the registration of shareholders
authorised entitled to take part in the Bank’s Ordinary General Meeting convened for 27 March 2024
and 30 March 2023.
However, as regards Nationale-Nederlanden Otwarty Fundusz Emerytalny, Allianz Polska Otwarty
Fundusz Emerytalny and Otwarty Fundusz Emerytalny PZU „Złota Jesień”, the number of shares and
their stake in the Bank's share capital were calculated on the basis of the Annual Structure of Assets
of the above-mentioned Funds as at 31 December 2024 and 29 December 2023 (as published on the
websites, respectively: www.nn.pl, www.allianz.pl and www.pzu.pl). With regard to the calculations
made on the basis of the annual structures of the above-mentioned Funds, the volume-weighted
average price (VWAP) of the Bank's shares was assumed: for 2024 in the amount 8.9290, and for 2023
in the amount of PLN 8.3321.
Banco Comercial Portugues S.A., as the majority shareholder, exercises a shareholder’s rights
specified in the Code of Commercial Companies and in the Bank’s Articles of Association. BCP is a
dominate entity with regard to the Bank. By holding a majority of votes at a General Meeting it can
exercise decisive influence on GMS over decisions regarding the most important corporate matters
such as change of the Bank’s Articles of Association, issue of new shares of the Bank, reduction of the
share capital of the Bank, issue of convertible bonds, payment of a dividend and other activities,
which in accordance with Code of Commercial Companies require majority of votes at a General
Meeting. BCP also holds a sufficient number of votes to appoint all members of the Supervisory Board,
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which in turn appoints members of the Management Board. In connection with the above-mentioned
corporate rights BCP has the capacity to exercise significant control over the Bank.
The Bank is not aware of any agreements concluded between its shareholders regarding their mutual
cooperation and the Bank is not aware of any agreements that, in future, might cause changes in the
proportions of shares held by existing shareholders.
The Bank’s shareholders exercise their corporate rights in the way and within the limits defined by
generally applicable laws, the Articles of Association of the Bank, as well as the By-laws of the General
Meeting of Shareholders. Each share of the Bank entitles to one vote, however registered founder
shares in the outstanding number of 61,600 items are preferential in as much as one share entitles to
two votes at a General Meeting. Registered founder shares in total accounted for 0.0051% of the
Bank’s share capital and 0.0102% of the total number of votes at a General Meeting, as at 31 December
2024.
Registered founder shares are subject to disposal restrictions, i.e. their disposal subject to the
consent of, at least, three fourths of the founders, to other founders does not result in their loss of
preferential status. A disposal of registered founder shares in all other cases causes loss of their
preferential status. There are no restrictions on exercising voting rights under the Bank’s shares and
none of the holders of securities issued by the Bank has any special controlling rights with respect to
the Bank.
Bank Millennium shares have been listed on the Warsaw Stock Exchange since 13 August 1992 (first
bank to be listed). Currently 1 213 017 297 shares with the code ISIN PLBIG0000016 (GPW symbol:
MIL; Reuters: MILP.WA; Bloomberg: MIL PW) are traded on the stock exchange.
Shareholders have 99 480 registered shares, of which 61,600 are preferential founder shares (right
to two votes at a General Meeting). Thus, the total number of Bank Millennium shares is 1,213,116,777
and total number of votes at a General Meeting of Shareholders is 1,213,178,377.
13.3. SUPERVISORY BOARD
The Supervisory Board exercises constant supervision over the activity of the Bank operating under
legal regulations, including the Articles of Association of the Bank, resolutions of the General Meeting
as well as the Bylaws of the Supervisory Board available from the Bank’s website on the “About the
Bank > Corporate bodies and governance” tab, link to website
https://www.bankmillennium.pl/about-the-bank/corporate-bodies-and-governance.
Meetings of the Supervisory Board are convoked once a quarter and if such need arises. The
competences of the Supervisory Board comprise, in particular, the appointment and recalling of
Members of the Management Board (by a simple majority of votes) and determination of their
remuneration principles. Resolutions are adopted by a simple majority of votes with at least half of
its members present. In the case of an equal number of votes the Chairman of the Supervisory Board
has a decisive vote.
The Supervisory Board of the Bank consists of at least five Members, of whom at least a half, including
the Chairman, are of Polish nationality. Members of the Supervisory Board are appointed at a General
Meeting for a three-year term of office.
The composition of the Supervisory Board between 1 January 2024 and 31 December 2024 was as
follows:
- Bogusław Kott – Chairman of the Supervisory Board,
- Nuno Manuel da Silva Amado – Deputy Chairman of the Supervisory Board,
- Dariusz Rosati – Deputy Chairman and Secretary of the Supervisory Board,
- Miguel de Campos Pereira de Bragança – Member of the Supervisory Board,
- Olga Grygier-Siddons – Member of the Supervisory Board,
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- Anna Jakubowski – Member of the Supervisory Board,
- Grzegorz Jędrys – Member of the Supervisory Board,
- Alojzy Nowak – Member of the Supervisory Board,
- José Miguel Bensliman Schorcht da Silva Pessanha – Member of the Supervisory Board,
- Miguel Maya Dias Pinheiro – Member of the Supervisory Board,
- Beata Stelmach – Member of the Supervisory Board,
- Lingjiang Xu – Member of the Supervisory Board.
Members of the Bank's Supervisory Board met the requirements set out in Article 22aa of the Banking
Law.
1. Bogusław Kott – Chairman of the Supervisory Board
Mr Bogusław Kott graduated from the Foreign Trade Faculty at SGPiS (present name SGH - Warsaw School
of Economics) in Warsaw. For many years he worked at the Ministry of Finance, specializing in foreign
trade financing.
He co-founded and co-organised Bank Millennium S.A., and from 1989 when the Bank was established,
till 24 October 2013 was the Chairman of the Management Board. Since 24 October 2013 he has been the
Chairman of the Supervisory Board of Bank Millennium S.A. From 31 May 2019 to the day of merger with
Bank Millennium S.A. i.e. 1 October 2019, also the Chairman of the Supervisory Board of Euro Bank S.A.
Mr Bogusław Kott has been a Member of the Polish Business Roundtable since 1994 and since May 2020
Honorary Member. Since 1 September 2018 he has been a Member of Board of Trustees of Kozminski
University in Warsaw.
2. Nuno Manuel da Silva Amado – Deputy Chairman of the Supervisory Board
Mr Nuno Manuel da Silva Amado has a Business Degree from ISCTE (Instituto Superior de Ciencias do
Trabalho e da Empresa) and attended the Advanced Management Programme at INSEAD (France).
From 1980 he worked in auditing (KPMG) and in international banks (Citibank, Deutsche Bank and Banco
Santander) in Portugal. Between 2006 - 2012 he was Vice-Chairman of the Board of Directors and CEO
of Banco Santander Totta (Portugal). From 2012 to 2018 he was Vice-Chairman of the Board of Directors
and CEO of Banco Comercial Portugues (BCP), Portugal. Since July 2018 he has been Chairman of the
Board of Directors of BCP.
Since 20 April 2012 Deputy Chairman of the Supervisory Board of Bank Millennium S.A.
3. Dariusz Rosati – Deputy Chairman and Secretary of the Supervisory Board
Mr Dariusz Rosati graduated in International Trade from the Main School of Planning and Statistics -
SGPiS (now the SGH Warsaw School of Economics) in Warsaw. Professor Emeritus of Economic Sciences,
Institute of International Economic Policy at SGH.
In 1978 – 1979 he was a consultant at Citibank in New York. In 1985 – 1986 and 1987 – 1988 - founder
and Director of the World Economy Research Institute at SGH. In 1986 – 1987 he was a Fulbright scholar
at the University of Princeton (USA). In 1988 – 1991 he was the director of the Foreign Trade Research
Institute. Since 1990 Professor of Economic Sciences at SGH. In 1991 – 1995 he worked in the UN
Economic Commission for Europe in Geneva (Switzerland) as Head of the Central and Eastern European
Section. In 1995 – 1997 he was Minister of Foreign Affairs of the Republic of Poland. In 1998 – 2004
Member of the Monetary Policy Council of the National Bank of Poland.
In 1978 – 1991, UNIDO consultant and member of numerous missions to developing countries. In 1988 –
1991 many times worked as an expert of the World Bank, the United Nations University World Institute
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for Development Economics Research (WIDER), International Labour Organisation and European
Commission. Member of the Economic Reform Commission (1987 – 1989), team of the economic advisors
to the Prime Minister (1988 – 1989), the Socio-Economic Strategy Council at the Council of Ministers
(1994 – 1998). Since 1997 Member of the Committee of Economics at the Polish Academy of Sciences.
In 2001 – 2004 he was a member of the Group of Economic Policy Advisors to the President of the EU
Commission. From 2003 to 2005 Rector of Lazarski University in Warsaw.
In years 2004 – 2009 and 2014 - 2019 Member of the European Parliament. Member of Parliament of the
Republic of Poland of 7th term in 2011 – 2014 – he was the Chairman of the Public Finance Committee
– and of 9th term, elected in 2019.
Since 27 May 2004 Member of the Supervisory Board of Bank Millennium S.A.
Author of over 250 scientific and journalistic works, including eight books on topics related to economic
policy and finance.
4. Miguel de Campos Pereira de Bragança – Member of the Supervisory Board
Mr Miguel de Campos Pereira de Bragança has a Degree in Management and Administration from the
Catholic University of Portugal and an MBA from INSEAD (France).
Started his career in 1989 in capital markets and investment banking, being since 1993 executive board
member of Financial Institutions in Portugal, Brazil (Santander Brazil) and Great Britain (Abbey
National). Between 2008-2012 he was Director, responsible for the Financial, Accounting and
Management Control, Marketing and Products Areas, at Banco Santander Totta and Banco Santander de
Negócios (Portugal). Since 2012 is Chief Financial Officer, board member and Vice-Chairman of the
Executive Committee of Banco Comercial Português (BCP), Portugal.
Since 20 April 2012 he has been a Member of the Supervisory Board of Bank Millennium S.A. and since
2019 Vice-Chairman of the Board of Directors of Activobank.
Since 2018 Non-executive Director of SIBS, SGPS, SA and of SIBS Forward Payment Solutions, SA and
Non-executive Director of the BofD of UNICRE- Instituição Financeira de Crédito, SA, as representative
of Banco Comercial Português, SA.
5. Olga Grygier-Siddons – Member of the Supervisory Board (independent member)
Ms Olga Grygier-Siddons graduated from the University of Manchester, Computer Science and
Accounting. She is also Fellow Chartered Accountant, Institute of Chartered Accountants of England
and Wales.
After having graduated in Great Britain, she pursued her professional career in the advisory sector. In
1991, she joined PwC in the Corporate Finance area. In 1998, she was promoted to the position of
Partner and was responsible for the delivery of diverse projects for the public and private sectors
around the world. In 2004, she decided to relocate to Poland and in 2014, she assumed the position
of Managing Partner for Central and Eastern Europe at PwC. For 15 years she was responsible for
business development and overseeing projects in 29 countries, in a company with 12,000 employees.
She became the first female member of the PwC Strategy Council which comprises 20 top leaders of
the PwC Network.
She retired from PwC in 2019 and currently serves as a strategic advisor and Mentor.
Moreover, until today she performs among other the following functions: Member of the Council of
the Silesian University, Member of the Supervisory Board of Zabka Group; founder and CEO of the
Experiential Learning Hub - Villa Poranek.
Since 24 March 2021 Member of the Supervisory Board of Bank Millennium S.A.
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6. Anna Jakubowski - Member of the Supervisory Board (independent member)
Ms Anna Jakubowski graduated with a Bachelor of Business Administration (1990) from Wilfrid Laurier
University, Waterloo, Ontario. Canada.
Her professional career started with Procter & Gamble Canada (1991 – 1993), where she was the
National Account Manager. Between 1993 and 1998 she held different positions, from Pharmacy
Channel Manager to Trade Marketing Manager and Area Sales Manager in P&G Poland. In 1998 she
became Regional Customer Business Development Manager in P&G Central Eastern Europe while
between 1999 and 2007 she was New Business Development Manager and (from 2002) Strategy,
Business Development Director in P&G Western Europe. She continued her career in Switzerland in
the P&G the Fabric Care Division (2007 – 2009) as an Associate Director: Marketing. Between 2011 and
2016 she connected her professional career with The Coca-Cola Company where she held the following
positions: the International Group Marketing/Strategy Director in Coca-Cola Hellenic Bottling
Company (2011 – 2013), Business Capability Director in the Coca-Cola Company (2013) and from 2013
– 2016 Management Board Member – Managing Director in Coca-Cola Poland Services Sp. z o.o. and
Franchise General Manager – Poland/Baltics in The Coca-Cola Company, Management Board Member
in Multivita Sp. z o. o, Management Board Member – Managing Director in Coca-Cola Balti Jookide AS.
In 2018 she held the role of General Manager for Poland and Baltics for Marie Brizard Wine & Spirits
Sp. z o.o. In 2019-2020, she held the role of General Manager of Avon Cosmetics Polska Sp. z o.o.. In
2023-2024 was the interim CEO at a biotech start up - FamicordTx S.A.. She is currently co-
investor/owner in Life Institute Sp. z o.o. Sp. k. She is an independent Supervisory Board member of
Artic Paper S.A.
She has also been involved with the following organizations and associations: Women’s International
Networking Leadership Forum - Board of Advisors (2004 – 2012), Organization of Women in
International Trade - Board of Directors (2005 – 2010) and in 2008 as an Executive Vice President as
well as in 2009 as the President (2005 – 2010) in Geneva Women in International Trade, across 2015 –
2016 she served also as a Member of the Board of Directors of the American Chamber of Commerce
in Poland, 2015 – 2018 as a Management Board Member, Vice President International Association of
Advertising (IAA) in Poland (Warsaw, Poland). Currently is a Member of the Board of the Polish -
Canadian Chamber of Commerce, an Adviser and Mentor in the Global Shapers – Mentor4Starters
initiative, and a mentor of the CFA Society Poland.
In 2011 she was awarded the TIAW – The World of Difference 100 Award (Recognizes individuals whose
efforts have advanced the economic empowerment of women) and in 2016 she was awarded Woman
of Charisma: Business & Social Enterprise Award (Poland).
Since 21 May, 2015 Member of the Supervisory Board of Bank Millennium S.A. From 31 May 2019 to
the day of merger with Bank Millennium S.A. i.e. 1 October 2019, also Member of the Supervisory
Board of Euro Bank S.A.
7. Grzegorz Jędrys – Member of the Supervisory Board (independent member)
Mr Grzegorz Jędrys graduated from the Production Economics Faculty of the Warsaw School of
Economics and from a post-graduate course at the Warsaw School of Economics in Strategic Marketing
Management as well as real estate agency operation. Moreover, Mr G. Jędrys attended many courses
and training sessions, i.a. for candidates for members of supervisory boards of State Treasury
companies (2008).
He began his professional career in 1994 in the Housing Finance and Municipal Advisory Programme
for Poland/PADCO – a joint Poland-USAID programme. In 1996 he worked as Manager of the Building
Projects Financing Team in Polsko-Amerykański Bank Hipoteczny S.A. From 1997 to 1999 he was
employed in Jedenasty Narodowy Fundusz Inwestycyjny S.A., initially as an Investment Analyst, then
as Project Director. Between 1999 and 2005 he was Investment Director in Trinity Management Sp. z
o.o. – a company which managed the assets of Jupiter NFI S.A. as well as Pekao Fundusz Kapitałowy
Sp. z o.o. From 1997 to 2005 he was a Member of Supervisory Boards of many companies. Starting
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from 2005 he has been Head of the Poland’s Representative Office of the Polish American Freedom
Foundation, and since beginning of 2023 he is also acting as Foundation’s Chief Operating Officer.
Since 11 April 2013 Member of the Supervisory Board of Bank Millennium S.A. From 31 May 2019 to
the day of merger with Bank Millennium S.A., i.e. 1 October 2019, also Member of the Supervisory
Board of Euro Bank S.A. Since July 9, 2020, acting as a Member of the Supervisory Board of Millennium
Bank Hipoteczny S.A.
8. Alojzy Nowak – Member of the Supervisory Board (independent member)
Mr Alojzy Nowak in 1984 graduated from the Warsaw School of Economics; earned a Ph.D. in 1991
and Habilitation in 1995. Moreover in 1992 – as part of an annual scholarship from the A. Mellon
Foundation - he studied economics at the University of Illinois at Urbana-Champaign, USA; n 1i93, as
a scholarship holder of the United Kingdom Government under the Know-How Fund, he studied
banking, finance and capital markets at the University of Exeter; in 1996, as part of a semester
scholarship from the German Government, he stud9ed economics at Freie Universitat in Berlin, and
in 1997 as part of a semester scholarship of the Belgian Government, he studied international
economics at the RUCA University in Antwerp.
In 2002 he became Professor of Economics.
He has won a number of prestigious awards, including the Rector’s Award for Scientific Achievements
(annually since 1997), Award of the Minister of Education for the book “Integracja europejska. Szansa
dla Polski?” and the book „Banki a gospodarstwa domowe - dynamika rozwoju”. Member of many
scientific organizations and professional editorial boards of periodicals, among others “Foundations
of Management” (member of the editorial board), “Journal of Interdisciplinary Economics” (editor-
in-chief), “Yearbook on Polish European Studies”, “Mazovia Regional Studies”, “Gazeta Bankowa” and
a reviewer in PWE SA Warszawa publishing company. For many years committee member of “Teraz
Polska” Award and scientific council member of “Studia Europejskie”. Author of over 300 publications
in Poland and abroad.
He gained his professional experience working among others as Head of the International Business
Relations Section at the Management Faculty, University of Warsaw, Head of National Economy Chair
at the Management Faculty UW, Director of European Center at the University of Warsaw, Deputy
Dean in charge of foreign cooperation at the Management Faculty, University of Warsaw, next as Dean
at the Management Faculty, University of Warsaw and Vice-Rector for Research and Liaison, University
of Warsaw. Since September June 2020 he has become the Rector of the University of Warsaw. He is
a lecturer at the University of Warsaw, and also in France, UK, USA, Russia, China and Korea.
Further, he worked and still works as: advisor to the Prime Minister, to the Minister of Agriculture,
CEO of the University Sports Association in Poland and at the University of Warsaw, member of the
NewConnect advisory committee at the Management Board of the Warsaw Stock Exchange, member
of the Foundation Council of the National Bank of Poland, chairman of the Council of the Scientific of
the National Bank of Poland. Over the years he sat on supervisory boards of various institutions,
including among others: PZU S.A, PTE WARTA S.A., PKO BP S.A., Cyfrowy Polsat S.A., ZE PAK S.A.,
JSW S.A., Chairman and Deputy Chairman of the Supervisory Board in EUROLOT S.A.
He was a member of the National Development Council appointed by President Andrzej Duda.
Currently in the Council for Higher Education, Science and Innovation within the NRR. Since December
2018 he has been a member of the Scientific Council of the Institute of New Structural Economics at
the University of Beijing, where he is among 22 outstanding scientists from around the world, including
4 Nobel laureates in the field of economic sciences.
Since 26 March 2018 Member of the Supervisory Board of Bank Millennium S.A.
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9. José Miguel Bensliman Schorcht da Silva Pessanha – Member of the Supervisory Board
Mr José Miguel Bensliman Schorcht da Silva Pessanha has a Master’s Degree in Economics from
Université Catholique de Louvain and a Master’s Degree in Operational Research (academic portion)
from Instituto Superior Técnico and also has a Licentiate Degree in Economics, Universidade Católica
Portuguesa. He attended the PADE (Corporate Senior Management Programme) at Associação de
Estudos Superiores de Empresa (AESE), the Eureho Program in INSEAD, he had a Scholarship from
Invotan (NATO) and received a scholarship linked to the Award Joseph Bech, granted by tke
Government of Luxembourg for commitment to the European Union.
From 1982 to 1989 he worked as a financial services advisor - Banco Português do Atlântico, Banco
Nacional Ultramarino, Banco Espírito Santo, Manufacturers Hannover Trust, between 1982 – 1995 he
was Professor in charge of the courses of Statistics I and II and Econometrics - Universidade Católica
Portuguesa. He was responsible for risk control, ALM, financial markets research and capital markets
areas in the Financial Division – Banco Português do Atlântico, S.A. from 1989 to 1995 and Advisor to
the Chairman of the Plan National Council from 1990 to 1993. Between 1993 and 2002 he was a
Member of the Board of Directors of Corretora Atlântico - Soc. Financeira de Corretagem S.A. and of
Servimédia – Sociedade Mediadora de Capitais, S.A. and Chairman of the Board of Directors of
Servimédia - Sociedade Corretora S.A. and Head of the Assets and Liabilities Management Division of
BPA (1995 – 1998), and of BCP (1998 – 2000). At Banco Comercial Português, S.A. he was Head for the
"Year 2000" Project of Group BCP (1999 – 2000) and was responsible for the design, development and
launching of the "cidadebcp" bank website (2000 – 2002). From 1998 to 2003 he coordinated the
Investment Products Unit of Banco Comercial Português, S.A. From 2003 to 2015 he was the Group
Risk Officer of Banco Comercial Português, S.A. In 2014 he was a lecturer responsible for the banking
in a global context course at Universidade Católica Portuguesa.
Currently he is a Member of the Board of Directors and of the Executive Committee of Banco Comercial
Português, S.A. ,Member of the Board of Directors of ActivoBank, Vice-Chairman of the Board of
Directors and Chairman of the Audit Board of Millennium bcp Ageas Grupo Segurador, SGPS, S.A.,
Vice-Chairman of the Board of Directors and Chairman of the Audit Board of Ocidental - Companhia
Portuguesa de Seguros de Vida, S.A. and Vice-Chairman of the Board of Directors and Chairman of the
Audit Committee of Ageas – Sociedade Gestora de Fundos de Pensões, S.A. (formerly Ocidental –
Sociedade Gestora de Fundos de Pensões, S.A.).
He is also Member of the Board of Directors and Chairman of the Audit Committee of BIM – Banco
Internacional de Moçambique, S.A.(Mozambique) and Vice-Chairman r of the Board of Directors and
Chairman of the Audit Committee of Banco Millennium Atlântico, S.A.(Angola). Since 26 March 2018
Member of the Supervisory Board of Bank Millennium S.A.
10. Miguel Maya Dias Pinheiro – Member of the Supervisory Board
Mr Miguel Maya Dias Pinheiro graduated from Instituto Superior das Ciências do Trabalho e da
Empresa (ISCTE) with a bachelor’s degree in Business Organization and Management, having also
completed a Senior Management Programme (PADE) at AESE, an Advanced Management Programme
at INSEAD and a Corporate Governance Programme also at AESE.
From 1987 to 1990 he held commercial and financial functions in a SME company. Joined Banco
Português do Atlântico in 1990, institution where he assumed functions in the corporate banking area
and led the coordination of the Economic and Financial Research.
Between 1996 and 2007 he assumed several senior management positions within Banco Comercial
Português (BCP) Group both in Portugal and Spain, namely head of the Corporate Banking Marketing
Division of BCP, Coordinator of the Retail Banking network of NovaRede, CEO of Manager Land in
Barcelona, head of Innovation and Commercial Division of BCP. From 2007 to 2009 he was Chief of
Staff of the Chairman of the Executive Board of Directors of BCP.
In 2009 Mr Miguel Maya was appointed Member of the Executive Board of Directors of BCP, Member
of the Board of Directors of Fundação Millennium BCP and Chairman of the Board of Directors of Banco
ActivoBank, S.A.
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Between 2012 and 2016 he was Chairman of the Board of Directors of Banco Millennium Angola, S.A
and in 2016, following the merger of this institution with Banco Privado Atlântico, S.A. which resulted
in the creation of Banco Millennium Atlântico, S.A., Mr Miguel Maya was appointed Vice-Chairman and
Member of the Board of Directors of the new entity – position that he held until 2022.
From 2012 to 2019 Mr Miguel Maya was Chairman of the Board of Directors of Interfundos - Gestão de
Fundos de Investimento Imobiliário, S.A.
Currently Mr Miguel Maya holds the following positions in BCP’s Group governing bodies: Chief
Executive Officer (CEO) and Vice-Chairman of the Board of Directors of BCP, Chairman of the Board
of Directors of ActivoBank, S.A., Manager of BCP Africa, SGPS, Lda. and Member of the Board of
Directors of Banco Internacional de Moçambique, S.A.
Since 21 May 2015 he has been a Member of the Supervisory Board of Bank Millennium S.A.
11. Beata Stelmach – Member of the Supervisory Board (independent member)
Ms Beata Stelmach is a graduate of the Finance and Statistics Faculty at the Warsaw School of
Economics, she also holds an MBA from Calgary University and an MBA at INSEAD.
For many years she was involved with the capital and financial markets - from the start of economic
transformation she worked in the Securities and Exchange Commission, then she held management
functions in capital market entities, including MCI Capital TFI SA, Intrum Justitia TFI SA, she stood at
the head of the Polish Association of Listed Companies (currently chairing the supervisory board). Ms
B. Stelmach also has management experience in other industries: during 2001 – 2005 she sat on the
governing bodies of Prokom Software SA; in 2013 she became the CEO and Director General of General
Electric (Poland and Baltics). During 2018 – 2020 she was the President of PZL Świdnik SA.
Moreover she held advisory functions in the World Bank and also sat on the Supervisory Boards i.a. of
Bank BPH SA and HSBC BANK POLSKA SA; currently also an independent member of Supervisory Board
of KRUK SA, and Stalexport Autostrady S.A.
During 2011 – 2013 she was Undersecretary of State in the Ministry of Foreign Affairs, responsible for
global economic policy as well as public and cultural diplomacy.
Ms B. Stelmach was decorated with the Knight's Cross of Polonia Restituta Order for outstanding
contribution in the Foreign Service and work achievements undertaken for the benefit of the country
and diplomatic activity.
Since 24 March 2021 Member of the Supervisory Board of Bank Millennium S.A. Ms Beata Stelmach
resigned from the position of Member of the Bank's Supervisory Board with effect from January 31,
2025 – Current Report No. 2/2025 of January 22, 2025.
12. Lingjiang Xu – Member of the Supervisory Board
Mr Lingjiang Xu has a Bachelor's Degree in German from the Foreign Studies University of Beijing, a
Master’s Degree in World Economics from the Nan Kai University, Tianjin and a Master’s Degree in
Finance from the London Business School.
From July 1993 to February 1995 he worked as Desk Officer at the European Affairs Department of
the Chinese Ministry of Foreign Trade and Economic Cooperation in Beijing. He was Third Secretary
of the Commercial Office of the Chinese Consulate General in Hamburg from February 1995 to October
1998. Between October 1998 and February 2006 he was the Division Director of the European Affairs
Department of Chinese Ministry of Commerce in Beijing. From February 2006 to January 2010 he was
the First Secretary of the Commercial Office of the Chinese Embassy in London. In September 2011
he was elected Associate Director of Vermilion Partner LLP (London) (to March 2012). From March
2012 to December 2013 was Partner to RH Regent Investment Management Co Ltd (Shanghai). During
the years of 2015 to 2017, he was Non-Executive Director of Luz Saúde, S.A. and Non-executive
Director of Multicare – Seguros de Saúde, S.A., as well as Non-executive Director of the Board of
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Directors of Fidelidade Assistência – Companhia de Seguros S.A. From 18 October 2016 to 31 March
2017 he held the position of Non-executive Member of the Board of Directors of Chiado (Luxembourg)
S.à.r.l. From November 2019 to December 2023, he held position as Non-executive Member of the
Board of Directors of Luz Saude, S.A. Currently he is Non-executive Member of the Board of Directors,
Member of the Committee for Nominations and Remunerations and Member of the Committee for
Corporate Governance, Ethics and Professional Conduct of Banco Comercial Português, S.A. He is also
Non-executive Member of the Board of Directors of Fidelidade - Companhia de Seguros, S.A., Chairman
of the Board of Directors of Longrun Portugal, SGPA,S.A. Mr Lingjiang works as non-executive chairman
of the board of the directors at Longrun Portugal SGPA, S. A. from 23 November 2020 to 26 September
2024.
Since 26 March 2018 Member of the Supervisory Board of Bank Millennium S.A.
Standing Committees of the Supervisory Board
The Supervisory Board may establish standing or ad hoc committees, composed of members of the
Supervisory Board, to carry out specific supervisory tasks. The Standing Committees of the Supervisory
Board are: the Audit Committee, Personnel Committee, Strategic Committee and Committee for Risk
Matters.
Detailed information regarding the composition of the committees and the issues raised during the
meetings of the Committees in 2024 is to be found in the “Annual Report of the Supervisory Board for
the financial year 2024”, published on Bank Millennium’s website.
Audit Committee
The Audit Committee is a standing committee of the Supervisory Board, established in 2000 and
supporting the Supervisory Board in supervision over the execution of the internal audit function in
the Bank. Furthermore, the Audit Committee focuses on financial reporting, internal control and risk
management at the Bank.
Pursuant to the Act of 11 May 2017 on statutory auditors, audit firms and public oversight the Audit
Committee consists of at least three Members. The Members of the Audit Committee have knowledge
and skills in accounting or auditing of financial statements, as well as in the banking sector, which is
confirmed by the history of their professional career and the duties hitherto performed by them. The
majority of the Members of the Audit Committee, including its Chairman, are independent of the
Bank. The Audit Committee meets on a regular basis (once every quarter) upon the initiative of the
Chairman of the Committee and in the extraordinary mode it is convened by the Chairman of the
Supervisory Board on his own initiative or at the request of a Member of the Supervisory Board or a
Member of the Management Board.
The main responsibilities of the Audit Committee include specifically:
(I) monitoring the process of financial reporting,
(II) monitoring the effectiveness of the internal control systems and risk management systems, and
internal audit, including in the area of financial reporting,
(III) monitoring financial audit activities,
(IV) preparing for the Supervisory Board opinions providing the basis of performing by the Supervisory
Board assessments of the adequacy and effectiveness of the internal control system, including
the annual review of the adequacy and effectiveness of the control function, Compliance
Department and Internal Audit Department, and
(V) controlling and monitoring the independence of a statutory auditor and audit firm, particularly in
the case when other services than audit of financial statements are provided for the Bank by an
audit firm.
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In 2024 eight meetings of the Audit Committee of the Supervisory Board took place, at the following
dates:
1Q24: 26.01.2024, 27.02.2024,
2Q24: 06.05.2024,
3Q24: 25.07.2024, 09.08.2024 (by circulation),
4Q24: 04.10.2024, 25.10.2024, 13.12.2024.
Detailed information regarding the issues raised during the meetings of the Committee in 2024 is to
be found in the „Report on activities of the Supervisory Board of Bank Millennium S.A. in 2024” in the
chapter „Activities of the Audit Committee in the reporting period”.
In the period from 01.01.2024 to 31.12.2024 the Audit Committee of the Supervisory Board of Bank
Millennium S.A. functioned in the following composition:
Chairman of Committee: Mr. Grzegorz Jędrys independent member
Member of Committee: Mr. Miguel de Campos Pereira de Bragança
Member of Committee: Ms. Olga Grygier-Siddons independent member
Member of Committee: Ms. Anna Jakubowski independent member
Member of Committee: Mr. Alojzy Nowak independent member
Member of Committee: Mr. José Miguel Bensliman Schorcht da Silva Pessanha
The composition of the Audit Committee satisfied the criteria stipulated in Art. 129 section 1 and 3
of the Act of 11 May 2017 on Statutory Auditors, Audit Firms and Public Oversight.
Personnel Committee
The Personnel Committee has existed at the Bank since 2000. Its responsibilities include in particular:
(I) evaluating candidates for Members of the Bank’s Management Board,
(II) defining and conditions of employment of newly appointed Members of the Bank’s Management
Board,
(III) negotiating change of terms and conditions of employment of Members of the Bank’s Management
Board,
(IV) with respect to Members of the Management Board defining evaluation criteria, evaluating work
as well as deciding on annual bonuses,
(V) determining terms and conditions of termination of employment of Members of the Bank’s
Management Board,
(VI) evaluating policy on variable components of remuneration, and issuing recommendations
regarding:
a) remuneration amount and components, guided by prudential and stable risk, capital and
liquidity management as well as long-term benefit of the Bank,
b) variable remuneration of persons occupying management positions in the Bank involved with
risk management and with compliance of the Bank’s activity with legal and internal
regulations.
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During the period from 1 January 2024 to 31 December 2024 the composition of the Committee was
as follows:
1. Alojzy Nowak – Chairman
2. Miguel de Campos Pereira de Bragança
3. Bogusław Kott
4. Olga Grygier-Siddons
5. Anna Jakubowski
Strategic Committee
The Strategic Committee has existed at the Bank since 2013. The tasks of the Strategic Committee
are in particular:
(I) study of macroeconomic trends,
(II) study new trends, developments and new solutions in the banking industry,
(III) analyse Bank competitive position and benchmarking,
(IV) analyse and recommend long-term strategy, goals and objectives for the Bank.
During the period from 1 January 2024 to 31 December 2024 the Committee worked in the following
composition:
1. Bogusław Kott – Chairman
2. Nuno Manuel da Silva Amado
3. Miguel de Campos Pereira de Bragança
4. Anna Jakubowski
5. Miguel Maya Dias Pinheiro
6. Dariusz Rosati
7. Lingjiang Xu
Committee for the Risk Matters
The Committee for the Risk Matters was set up on 4 December 2015. Its competences include the
tasks stipulated for such committee in the Banking Law and allocated to it in other regulations
applicable to banks as well as supervisory recommendations implemented by the Bank ,in particular:
(I) provision of opinions on overall, current and future readiness of the Bank to undertake risk,
(II) provision of opinions on the strategy of management of risk inherent in the Bank operations, as
developed by the Bank Management Board and on information regarding implementation of the
said strategy, as submitted by the Bank Management Board,
(III) provision of support to the Bank Supervisory Board in supervision of implementation of the risk
management strategy relative to the Bank operations by the Bank’s senior management staff,
(IV) provision of opinions on the assessment Risk Management Function and Validation Function as well
as on exceptional transactions that may impact the Bank risk profile;
(V) provision of opinion on whether incentives provided by the remuneration policies and practices
take into consideration the institution’s risk, capital and liquidity and the likelihood and timing
of earnings.
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(VI) verification whether prices of assets and liabilities offered to Clients fully take into account the
Bank’s business model, its risk strategy and in case the prices fail to reflect types of risk
appropriately and in keeping with the said model and strategy, submission of proposals to the
Bank Management Board to ensure adequacy of prices of assets and liabilities relative to relevant
types of risk.
During the year 2024, the composition of the Committee was as follows:
1. Mr. Dariusz Rosati – Chairman,
2. Mrs. Beata Stelmach,
3. Mr. Miguel de Campos Pereira de Bragança,
4. Mr. Grzegorz Jędrys,
5. Mr. José Miguel Bensliman Schorcht da Silva Pessanha.
According to the „Policy of Remuneration of Members of the Supervisory Board of Bank Millennium
S.A.”, adopted by the General Meeting, members of the Supervisory Board of the Bank are entitled
to monthly remuneration for sitting on the Supervisory Board. The amount of the remuneration is
defined by a resolution adopted by the General Meeting with the consideration of the principles
stipulated in the Policy, including the principle of its adequacy to the scale of the Bank’s operation.
The remuneration may be diversified in view of the function performed in the Supervisory Board and
should be correlated with the involvement in the work of the Supervisory Board and the level of
remuneration received by members of supervisory bodies of institutions with a similar scope and scale
of operation. Irrespective of the remuneration for sitting on the Supervisory Board, members of
standing committees of the Supervisory Board are entitled to separate remuneration in connection
with the tasks performed by them as part of these committees. If the Supervisory Board delegates its
member to individually exercise supervision on a permanent basis, the Supervisory Board may assign
to such Supervisory Board member additional remuneration for the duration of the delegation,
however its monthly amount cannot exceed 100% of the base remuneration for sitting on the
Supervisory Board. In case of standing committees of the Supervisory Board the remuneration is
payable for participation in their meetings. The total remuneration due to a Supervisory Board
member for participation in meetings of committees of the Supervisory Board in a given accounting
year cannot exceed 100% of his base remuneration for sitting on the Supervisory Board of the Bank.
In connection with remuneration paid, the Bank shall make appropriate deductions under relevant
legal regulations. Each of the Supervisory Board members may make a declaration to refrain from
collection of all or part of the remuneration. Declarations to such effect shall be submitted to the
Chairman of the Supervisory Board.
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Remuneration paid to members of the Supervisory Board in 2024 (in PLN thousand):
Name and surname
Remuneration
for serving on
the Supervisory
Board
Remuneration
for participation
in Committee
Other
benefits
Total
Bogusław Kott
240
65
25.89
330.89
Nuno Manuel Da Silva Amado
120
25
145
Dariusz Rosati
120
75
195
Miguel De Campos Pereira De
Bragança
120
95
215
Olga Grygier-Siddons
120
45
165
Anna Jakubowski
120
75
195
Grzegorz Jędrys
120
85
205
Alojzy Nowak
120
65
185
José Miguel Bensliman
Schorcht da Silva Pessanha
120
60
180
Miguel Maya Dias Pinheiro
120
25
145
Beata Stelmach
120
25
145
Lingjiang Xu
120
25
145
TOTAL
1 560
665
25.89
2 250.89
Remuneration from other entities of the Bank Millennium SA Group (in PLN thousand)
Name and surname
Remuneration
for serving on
the
Supervisory
Board
Remuneration
for
participation
in Committee
Other
benefits
Total
Grzegorz Jędrys
120
20
0
140
In 2024, Grzegorz Jędrys received remuneration for his membership in the Supervisory Board of
Millennium Bank Hipoteczny.
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The Bank’s shares held by Supervisory Board Members (performing their functions on
31 December 2024):
Name and surname
Function
Number of
shares
31.12.2024
Number of shares
31.12.2023
Bogusław Kott
Chairman of the
Supervisory Board
1 000
1 000
Nuno Manuel da Silva Amado
Deputy Chairman of the
Supervisory Board
0
0
Dariusz Rosati
Deputy Chairman and
Secretary of the
Supervisory Board
0
0
Miguel de Campos Pereira de
Bragança
Member of the
Supervisory Board
0
0
Olga Grygier-Siddons
Member of the
Supervisory Board
0
0
Anna Jakubowski
Member of the
Supervisory Board
0
0
Grzegorz Jędrys
Member of the
Supervisory Board
0
0
Alojzy Nowak
Member of the
Supervisory Board
0
0
BoardJosé Miguel Bensliman
Schorcht da Silva Pessanha
Member of the
Supervisory Board
0
0
Miguel Maya Dias Pinheiro
Member of the
Supervisory Board
0
0
Beata Stelmach
Member of the
Supervisory Board
0
0
Lingjiang Xu
Chairman of the
Supervisory Board
0
0
13.4. MANAGEMENT BOARD
The Management Board is the management body of the Bank and manages the entirety of the Bank’s
operations. In legal terms, the Management Board operates pursuant to the Code of Commercial
Companies and other regulations, the Bank’s Articles of Association, resolutions of the General
Meeting of Shareholders and the Supervisory Board, as well as provisions of the “Bank Millennium S.A.
Management Board’s Operations bylaws” adopted by the Supervisory Board, which is available from
the Bank’s website on the ”About the Bank > Corporate Bodies and Governance” tab, link to website
https://www.bankmillennium.pl/about-the-bank/corporate-bodies-and-governance.
The competences of the Management Board include all matters that are not reserved for other bodies
of the Bank.
The Management Board makes decisions collectively. Resolutions of the Management Board are adopted
by ordinary majority of votes of the Management Board Members participating in the voting. In the
case of equal votes the Chairman of the Management Board has a decisive vote. Resolutions of the
Management Board may be adopted, if at least half of the Management Board Members participate in
the voting.
The following persons are authorized to make declarations of will regarding the Bank's property rights
and obligations and to sign documents on behalf of the Bank:
(I) the Chairman of the Management Board individually,
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(II) two other Members of the Management Board acting jointly or one Member of the Management
Board acting jointly with a registered proxy or two registered proxies.
Attorneys-in-fact may be appointed to perform specified activities, and shall act individually within
the scope of their authorization.
The Management Board of the Bank is composed of at least three persons, including the Chairman of
the Management Board. At least half of the Members of the Management Board should be Polish
nationals. The Management Board is appointed by the Supervisory Board. The term of office of a
Management Board is 3 years. A Member of the Management Board may be recalled by the Supervisory
Board at any time.
The Bank’s Management Board during the period from 1 January 2024 to 31 December 2024 remained
unchanged and consisted of the following persons:
1) Joao Nuno Lima Bras Jorge – Chairman of the Management Board
2) Fernando Maria Cardoso Rodrigues Bicho – Deputy Chairman of the Management Board
3) Wojciech Haase – Member of the Management Board
4) Andrzej Gliński – Member of the Management Board
5) Wojciech Rybak – Member of the Management Board
6) António Pinto Júnior – Member of the Management Board
7) Jarosław Hermann – Member of the Management Board
Members of the Bank's Management Board met the requirements set out in Article 22aa of the Banking
Law.
1. Joao Bras Jorge – Chairman of the Management Board
Mr Joao Nuno Lima Bras Jorge, graduate of the Management Studies at
Universidade Catolica Portuguesa, PADE Advance Management Programme under
AESE and International Director Programme IDP-C from INSEAD.
He started his professional career as a stockbroker in 1990. In the ensuing 10 years
he worked in investment banking, inter alia, as Member of the Management Board
at an investment bank. He also sat on the Board of the Lisbon Stock Exchange.
During the 5 years prior to his move to Poland he held the position of Head of the Retail Banking
Customer Division and Coordinator of the Retail Network at Millennium bcp. Since 19 July 2006 -
Member of the Management Board of Bank Millennium S.A., in the years 2006-2008 Head of the
Retail Banking Division and from 2009 – Head of the Corporate Banking Area. From 22 April 2010 –
Deputy Chairman of the Management Board and since 24 October 2013 – Chairman of the
Management Board of Bank Millennium S.A.
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2. Fernando Bicho – Deputy Chairman of the Management Board
Mr Fernando Maria Cardoso Rodrigues Bicho graduated from the Economic
Department at Universidade Catolica Portuguesa in 1984. In 1993 he obtained an
MBA from Universidade Catolica Portuguesa.
He gained his professional experience inter alia in the Portuguese Foreign
Investment Institute, Lloyds Bank Plc in Lisbon and Uniao de Banco Portugueses
(UBP), later renamed to Banco Mello. He performed duties as fund manager and
later in the bank, as Head of the Financial Division, he was in charge of inter alia
the treasury and capital markets, securities operations, asset and liabilities management, issues on
international capital markets, capital management and investor relations. After the purchase of
Banco Mello by Banco Comercial Portugues (BCP) in 2000, Mr Fernando Bicho worked in the BCP
Corporate Centre and from June 2001 he was Head of the Asset and Liabilities Management
Department of the BCP Group.
Since 1 August 2002 Member of the Management Board of Bank Millennium S.A. (CFO – Chief Financial
Officer) and since 20 April 2012 Deputy Chairman of the Management Board. From 3 June 2019 until
the day of merger with Bank Millennium S.A., i.e. 1 October 2019, also Deputy Chairman of the
Management Board of Euro Bank S.A.
Since 17 September 2020, Chairman of the Supervisory Board of Millennium Bank Hipoteczny S.A.
He supervises treasury, accounting, financial reporting and control, taxes, capital investments,
relations with investors and financial institutions, management information and central acquisition,
as well as coordination of Group entities (other than leasing, brokerage, related to investment funds
and startups).
3. Wojciech Haase – Member of the Management Board
Mr Wojciech Haase graduated from the Faculty of Production Economics at Gdańsk
University.
He worked at the National Bank of Poland in Gdańsk to be then transferred to the
group organising Bank Gdański S.A. In 1989-1997 he worked at Bank Gdański S.A. -
first in the Credit Department and then in the Treasury Department. From 1993 he
was Deputy Chairman of the Management Board of Bank Gdański S.A. and, next,
acting Chairman of the Management Board of that Bank.
Since 27 June 1997 Member of the Management Board of Bank Millennium S.A. Since 4 December
2015 the Bank’s material risk management supervisor. Moreover, he supervises risk management,
risk models, credit and ratings processes, liabilities collection and treasury control.
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4. Andrzej Gliński – Member of the Management Board
Mr Andrzej Gliński graduated from the Poznań University of Technology (1994) and
completed his post-graduate studies in banking and finance at the Warsaw School
of Economics. In 2024, he completed the Advanced Management program (AMP) at
IESE Business School, one of the world's leading executive development programs.
From the beginning of his professional career associated with the financial sector:
in 1994 he started working at Bank Handlowy S.A. in Warsaw – initially in the Capital Operations
Center, from 1995 in the part of the Bank responsible for servicing enterprises, then in managerial
positions as a branch director and sales director in the Asset Financing Department. In the years
2001-2004 he was the Vice-President of the Management Board of Handlowy Leasing S.A. Since 2004
he has been associated with the Bank Millennium S.A. Capital Group, initially as the Chairman of
Millennium Leasing Sp. z o.o., and then as the Head of the Corporate Banking Area of Bank Millennium
S.A.
Member of the Management Board of Bank Millennium S.A. since 22 April 2010.
6. Wojciech Rybak – Member of the Management Board
Mr Wojciech Rybak graduated in economics from the University of Szczecin (1993)
and Tempus – Portassist Programme of the University of Antwerp (1992).
Since the beginning of his professional career, he has been associated with
banking.
Since May 1996 he has been working in the Bank Millennium S.A. Group.
From August 2003 he was a Member of the Management Board of Millennium
Leasing Sp. z o.o., supervising, inter alia, the sales network and from June 2009 until June 2016 –
Chairman of the Management Board of Millennium Leasing Sp. z o.o. In 2011 - 2016 a member of the
Executive Committee of the Polish Leasing Association, including its Chairman in 2015 – 2016.
Member of the Management Board of Bank Millennium S.A. since 6 June 2016. From 3 June 2019 until
the day of merger with Bank Millennium S.A., i.e. 1 October 2019, also Deputy Chairman of the
Management Board of Euro Bank S.A.
He supervises the retail sales network, its optimization and support, private banking and direct
banking.
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6. António Pinto Júnior – Member of the Management Board
Mr António Pinto Júnior graduated in Economics (1985-1990) from Oporto
University and Corporate Finance from Minho University (1993-1994).
He started his professional career in Banco Português do Atlântico (1990), since
1994 part of Millenniumbcp Group, gaining experience in Retail and Corporate
Banking by holding managerial positions in the marketing and sales support areas.
Between 2002 and 2011 he worked in Bank Millennium, S.A., as Head of
Departments in charge of Marketing, Quality, Processes and Operations, and, from April 2010, as a
Member of the Management Board. In the following 7 years he held the position of Head of Retail
Banking Marketing Department in Millenniumbcp in Portugal, and between July 2016 and May 2018
was also a non-executive Member of the Management Board of ActivoBank.
Since 20 April 2018 Member of the Management Board of Bank Millennium S.A. From 3 June 2019
until the day of merger with Bank Millennium S.A., i.e. 1 October 2019, also Deputy Chairman of the
Management Board of Euro Bank S.A.
He supervises electronic banking, sales campaigns, retail and corporate banking marketing,
processes support management, administration and infrastructure, complaints and quality of
services, coordination of Group entities from the area of investment funds and startups.
7. Jarosław Hermann - Member of the Management Board
Mr Jarosław Hermann graduated from the Applied Mathematics and Physics Faculty
at the Warsaw University of Technology in 1994 and Carlson School of Management
MBA program in 2002.
He gained broad IT & Operations practice working on managerial positions in
PepsiCo, Pioneer Financial Services and Accenture, where he conducted mid / large
scale projects in the banking sector in Poland and CEE countries.
Between 2005-2010 he was Board Member of First Data Poland responsible for providing IT and
operational services for card acquiring and financial solutions business lines.
Between 2010-2016 he was Board Member of AXA companies in Poland responsible for IT &
Operations.
From 2016 to 2018 he was Vice President of Polskie ePłatności, emerging card acquirer.
Since 1 August 2018 Member of the Management Board of Bank Millennium S.A. He supervises IT,
products operations, settlement and cash management, evidencing, control and settlement of
treasury transactions, security and business continuity.
The organisational structure of the Bank is consistent with the strategy, modern approach to business
and complies with the principles of corporate governance for financial institutions. The division of
the tasks between the members of Management Board of the Bank is presented on the following
diagram:
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• Treasury
• Accounting
• Financial reporting and
control,
• Taxes
• Capital investments
• Relations with investors
and financial institutions
• Management information
• Central acquisition
• Group entities co-
ordination (other than
leasing, brokerage ,from
the area of investment
funds and startups)
• Private banking
• Retail sales network, its
optimization and support
• Direct banking
Separate position to
supervise the management
of significant risk in Bank s
activity
• Corporate banking and
its support
• Factoring and trade
financing
• Structured finance
• Custody
• Brokerage
• Coordination of the
Group's entity
conducting leasing
• Electronic banking
• Sales campaigns
• Retail marketing and
corporate marketing
• Processes support
management
• Administration and
infrastructure
• Complaints and quality
of service
• Group entity co-
ordination from the area
of investment funds and
startups
Fernando Bicho
Deputy Chairman of
the Mgt Board
Wojciech Rybak
Member of the Mgt
Board
Wojciech Haase
Member of the Mgt
Board
Andrzej Gliński
Member of the Mgt
Board
Antonio Pinto
Junior
Member of the Mgt
Board
• Management Board works
• Internal audit
• Compliance
• Legal support
• Marketing communication and public
relations
• Human resources
• Personal data protection
• Sustainability
Joao Bras Jorge
Chairman of the Management
Board
• Risk management
• Risk models
• Credit and ratings
processes
• Liabilities collection
• Treasury control
• IT
• Products operations,
settlements and cash
management
• Evidencing, control and
settlement of treasury
transactions
• Security and business
continuity
Jarosław Hermann
Member of the Mgt
Board
The principles of remuneration of the Management Board Members with the amount of salaries,
bonuses and other benefits received in 2024 can be found in chapter 12 of this report, part 12.3
entitled "Remuneration policy".
In accordance with the above-mentioned principles of remuneration, in 2024 Members of the Bank's
Management Board were not granted Bank's shares as part of the implementation of the incentive
program. Therefore, the status of shares owned by the Management Board Members who performed
their functions on 31 December 2024 was as follows:
Name and surname
Function
Number of shares
31.12.2024
Number of shares
31.12.2023
Joao Bras Jorge
Chairman of the
Management Board
380 259
380 259
Fernando Bicho
Deputy Chairman of the
Management Board
176 252
176 252
Wojciech Haase
Member of the
Management Board
151 107
151 107
Andrzej Gliński
Member of the
Management Board
10 613
113 613
António Pinto Júnior
Member of the
Management Board
13 613
143 613
Wojciech Rybak
Member of the
Management Board
113
43 613
Jarosław Hermann
Member of the
Management Board
0
6 000
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13.5. INTERNAL CONTROL SYSTEM AND EXTERNAL AUDITOR
Internal Control System
The Bank’s internal control system is organised in the framework of the so-called three independent
lines of defence, which comprise:
• 1
st
line – the Bank’s operating units not belonging to the 2
nd
and 3
rd
line of defence,
• 2
nd
line – Compliance Department and units designated by the Management Board (mainly
units managing risk),
• 3
rd
line – Internal Audit Department.
The internal control system covers all organisational units of the Bank and subsidiaries belonging to
the capital group.
The main objectives of the internal control system are to ensure:
• effectiveness and efficiency of the Bank’s operations,
• credibility of financial information (including: completeness, correctness and
comprehensiveness of administrative and accounting procedures and fair and true internal
and external reporting),
• observance of risk management principles at the Bank,
• compliance of the Bank’s activity with laws, internal regulations and market standards.
Based on the developed selection criteria the Bank identified material processes, and then linked
them to the general and specific objectives of the internal control system. For material processes the
Bank selected controls (control mechanisms) functioning within such processes and selected out of
them certain controls of key importance for achieving the objectives of the internal control system
assigned to a given process. Key controls have been covered by the monitoring of their observance,
such monitoring performed independently by organisational units belonging to the 1
st
and the 2
nd
line
of defence in the internal control system.
The linking of the general objectives of internal control and specific objectives isolated as part of
them with material processes functioning at the Bank and key controls and principles of independent
monitoring of their observance is documented in the form of the Control Function Matrix. The Bank
in the Matrix also specified the responsibility of particular organizational units for employing control
mechanisms, as well as their independent monitoring.
The Bank has a formalized path of reporting about the results of monitoring controls, ascertained
irregularities and status of implementing remedial and disciplining measures. From time to time this
information is also transferred to the Internal Audit Department, the Bank’s Management Board and
Audit Committee of the Supervisory Board.
The Bank’s Management Board is responsible for the implementation and functioning of an adequate,
effective and efficient internal control system.
The Bank’s Supervisory Board exercises supervision and performs an annual assessment of adequacy
and effectiveness of internal control system (including the control function, Compliance Department,
Internal Audit Department).
Internal Audit (3rd line of defence)
The Internal Audit Department is within the internal control system a specialized unit of the 3rd line
of defence which carries out an independent review of processes and internal control in the Bank and
the capital group, verifying the implementation of tasks assigned to the 1st and 2nd line of defence.
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The aim of the activities is providing the Bank's management with an assessment of the effectiveness
and adequacy of the risk management system and the internal control system, as well as adding value
and streamlining processes in the Bank and the capital group. When implementing its mission Internal
Audit takes into account the strategic objectives and tasks of the organization, as laid down by the
Management Board and Supervisory Board of the Bank. The audit process is performed according to
the Audit Charter and Internal Audit Methodology, fostering international standards of internal audit
and good banking practices.
The Internal Audit Department is an independent unit, directly reporting to the Chairman of the
Management Board of the Bank and the results of its activities are reported to the Management Board,
Audit Committee of the Supervisory Board and the Supervisory Board of the Bank.
The activity of Internal Audit is a planned and continuous activity, resulting from the implementation
of the mission and objectives, as well as the adopted Department Strategy and based on an annual
audit plan. The basis of the planning process is the assessment of the risk of particular areas and
processes of the Bank in order to identify increased risk and support the specification of priorities and
resources for the implementation of tasks. The planning process takes into account consultations with
senior management and owners of key processes. The annual audit plan is approved by the Bank’s
Supervisory Board and implemented on a quarterly basis by experienced and highly qualified
professionals.
Internal Audit performs independent and objective assurance and consulting activities. Assurance
activity is carried out as part of process audits, independent review function, branch audits,
preventive audits and investigations. Assurance activity includes assessment of the adequacy and
effectiveness of the risk management system and internal control system in all areas of banking
activity. Advisory services are aimed at supporting the organization in achieving its goals and are
provided, as far as their nature does not put under threat the independence, effectiveness and
objectivity of Internal Audit’s assurance activity, nor is related to the designing of control mechanisms
and risk management system.
In 2024 Internal Audit Department performed audit tasks in the Bank, its subsidiaries, external entities
to which the Bank, to the extent permitted by regulations, outsourced banking and bank-related
operations, as well as within the BCP Capital Group. The planned activity of the Department covered
among others audits of key business and support processes and also branch audits and those of
compliance with external regulatory requirements. The tasks performed by the Internal Audit
Department also included investigations and prevention audits.
The results of the review of the functioning of the entire internal control system as well as its selected
components, carried out by the Compliance and Internal Audit Departments in cooperation with the
External Auditor, are presented cyclically and are subject to evaluation by the Audit Committee of
the Bank's Supervisory Board and once a year to the Bank's Supervisory Board.
Internal Control System with respect to the Process of Preparing Financial Reports
Implemented solutions regarding the internal control system protect to a significant extent the Bank
from financial reporting errors and provide the Bank’s Management with information which helps
evaluate the correctness, efficiency and security of the functioning of the process of preparing
financial reports, also in order to ensure the highest possible effectiveness in managing identified
types of risks accompanying the process.
The internal control system, introduced by the Management Board of the Bank and incorporating the
financial report preparation process, has been designed to facilitate the control of process risk while
maintaining appropriate supervision over the correctness of gathering, processing and presentation
of data necessary for the preparation of financial reports in keeping with effective laws.
An important element of the internal control system in the process of preparing financial reports is
the cooperation of the Audit Committee of the Bank's Supervisory Board with an audit firm providing
financial audit services. The Bank prepared the policy of selecting an audit firm for carrying out an
audit and policy for providing by an audit firm carrying out an audit, by entities connected with such
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audit firm and by a member of an audit firm network - permitted services not being an audit. The
above-mentioned policies are captured in the document „Policy of Selecting and Cooperation with
Audit Firms”, which was approved by the Audit Committee of the Supervisory Board. The policy
specifies:
1) The principles of selecting the audit firm to conduct statutory audit and voluntary audit,
2) Principles of providing permitted services not being a statutory or voluntary audit by Audit Firm,
entities connected with Audit Firm or member of an Audit Firm network,
3) Procedure of accepting performance by Other Audit Firms of services other than the statutory
audit and the voluntary audit,
4) Principles of the Bank’s cooperation with audit firms, entities connected with an audit firm or
members of the audit firm network with respect to conducting statutory or voluntary audits and
providing permitted services.
The external auditor is selected by the Supervisory Board on the basis of a recommendation issued by
the Audit Committee of the Supervisory Board. In addition, in the interest of the quality of financial
data presented in the remaining published quarterly reports, the Bank, together with the external
auditor, has implemented cooperation procedures ensuring – on an on-going basis - the consultation
of important issues connected with the recognition of economic events in the books and financial
reports. At meetings of the Audit Committee of the Supervisory Board the external auditor presents
key findings relative to financial reporting, consults with the Audit Committee of the Supervisory
Board draft reports and proposes an approach to the audit of the annual financial report.
The Bank is covered by the consolidated financial report of the Millennium BCP capital group. In this
connection, the annual review of the Bank’s internal control system supporting the process of
preparing and disclosure of financial information is also subject to the terms and requirements of
consolidated supervision, which is performed by the Bank of Portugal and the European Central Bank.
The external auditor of the Millennium BCP capital group participated in 2022 in review of the
adequacy and effectiveness of the part of the Bank's internal control system supporting the process
of preparing and disclosure of financial information (financial reporting) and issued an appropriate
opinion in this respect.
Information on the agreements with the entity authorised to audit financial reports
On December 11, 2023, the Supervisory Board of the Bank approved the selection of Deloitte
Assurance Polska spółka z ograniczoną odpowiedzialnością sp. k. (former: Deloitte Assurance sp. z
o.o.) as an entity authorized to audit the financial statements of Bank Millennium S.A. and the Bank's
Capital Group for the years 2023 and 2024. The audit agreement was concluded on December 13,
2023.
Remuneration received by the auditor on account of services provided to the Capital Group of Bank
Millennium S.A. in accordance with the service agreement for the year covered by the financial
statement audit.
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Auditor’s Remuneration*
2024
2023
(in PLN’000)
Bank
Subsidiaries
Bank
Subsidiaries
Statutory audit within the
meaning of art. 2 point 1 of the
Act on Statutory Auditors
1,578
721**
1,416
654**
Other assurance services
2,771
252**
1,830
250**
Tax advisory services
-
-
-
-
Other services
-
-
-
-
*The indicated remuneration amounts do not include additional cost surcharges incurred by the auditor up to a total limit of
3% for the supervision fee (in the amount resulting from the Act on Statutory Auditors, Audit Firms, and Public Oversight)
and other costs resulting from the provision of services.
**The data does not include the remuneration for Millennium Bank Hipoteczny S.A., which is audited by another audit firm
Services other than statutory audit:
• a review of the stand-alone and consolidated interim condensed financial reports of Bank
Millennium S.A. drawn up as at June 30, 2024,
• review of the interim condensed financial reports of Millennium TFI SA investment funds
prepared as at June 30, 2024,
• review of the reporting package of Millennium Leasing sp. z o.o., prepared for the period of
6 months, ended on 30 June 2024,
• review of the reporting package of Millennium Bank Hipoteczny S.A., prepared for the 6
months, ended on 30 June 2024,
• review of the consolidation documentation and the reporting package of Bank Millennium S.A.
capital group for the period of 6 months, ended on 30 June 2024, prepared in accordance
with instructions and group rules of BCP capital group,
• audit of the consolidation documentation and the reporting package of Bank Millennium S.A.
capital group for the period of 12 months, ended on 31 December 2024, prepared in
accordance with instructions and group rules of BCP capital group,
• procedures for verification of consolidation documentation and the reporting package of the
Bank Millennium S.A. capital group for the period of 3 months, ended on 31 March 2024,
prepared in accordance with group principles,
• procedures for verification of consolidation documentation and the reporting package of the
Bank Millennium S.A. capital group for the period of 9 months, ended 30 September 2024,
prepared in accordance with group principles,
• assurance service concerning requirements for safekeeping of customers' assets for 2024 for
Bank Millennium S.A.,
• assurance service concerning evaluation of adequacy of the risk management system in 2024
in Millennium TFI S.A.,
• assurance service concerning verification of the internal control system of Bank Millennium
S.A. and Millennium Leasing, in accordance with instructions of the group auditor for the
period from 1 December 2023 to 30 November 2024,
• assurance service in accordance with KSUA 3000, concerning verification of the remuneration
report of Bank Millennium S.A. for 2024,
• assurance service in accordance with KSUA 3000 on non-financial elements with regard to
sustainability reporting
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• Issuance of Comfort Letter in accordance with the National Standard on Related Services 4401
“Engagements to perform agreed-upon procedures regarding transactions in securities which
require preparation of a prospectus”
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14. ADDITIONAL INFORMATION
Other information regarding:
▪ Guarantees and sureties granted,
▪ Transactions with related companies,
▪ List of the relevant court cases, arbitration proceedings before an authority or public
administration,
can be found in the Annual Consolidated Report of the Bank Millennium S.A. Capital Group for the 12-
month period ending 31st December 2024.
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II. SUSTAINABILITY REPORTING
15. GENERAL DISCLOSURES (ESRS 2)
15.1. BASIS OF PREPARATION
[BP-1] This statement has been prepared under:
• the provisions of Chapter 6c of the Accounting Act of September 29, 1994 (Journal of Laws
2023, item 120, as amended) (the “Accounting Act”),
• sustainability reporting standards as defined in Commission Delegated Regulation (EU)
2023/2772 of July 31, 2023 supplementing Directive 2013/34/EU of the European Parliament
and of the Council with regard to sustainability reporting standards (“ESRS”), including the
requirement that the process carried out to identify reported information is consistent with
its description in sustainability reporting,
• the reporting requirements contained in Article 8 of Regulation (EU) 2020/852 of the European
Parliament and of the Council of 18 June 2020 on establishing a framework to facilitate
sustainable investment, amending Regulation (EU) 2019/2088 (“Regulation (EU) 2020/852”).
The scope of companies covered by this statement does not differ from the scope of companies
covered by financial reporting and is presented in part I of the report in section 1. Brief characteristics
of Bank Millennium and the Bank Millennium Group. As is the case with the financial statements, this
statement also takes into account any and all changes in the structure of the Bank Millennium Group.
No such changes occurred in 2024. This statement does not take into account any adjustments to the
information on minority interests. The information presented herein is for the period from 1 January
2024 to 31 December 2024 unless stated otherwise. This statement also considers direct upstream
and downstream relationships within the Bank Millennium Group’s value chain in terms of material
impacts, risks and opportunities. Due to the absence of information on indirect relationships within
the value chain (such as information on our customers’ suppliers), these have not been included in our
analysis.
In formulating this statement, the option to omit specific information pertaining to intellectual
property, know-how or the outcomes of innovations has not been exercised, nor has the exemption
from the obligation to disclose information related to expected events or matters under negotiation
provided for in Article 63x(7) of the Accounting Act of 29 September 1994 been used. [BP-2] No special
circumstances have affected the scope and content hereof.
[BP-2] The timeframes adopted in this statement have been defined in accordance with European
Sustainability Reporting Standards (ESRS 1 section 6.4 Definition of short-, medium- and long-term
for reporting purposes), namely:
1. short-term time horizon – reporting period (1 year),
2. medium-term time horizon – up to 5 years,
3. long-term time horizon – more than 5 years.
For the purpose of preparing this report, selected metrics related to the Bank Millennium Group’s
value chain have been estimated. These metrics are described in the Environment part hereof in
section 16. Climate Change (ESRS E1), subsection 16.3 Metrics and targets.
Due to the reporting period being the first year of application of sustainability reporting standards, it
has not been possible to identify any changes in the preparation and presentation of sustainability
information compared to the previous reporting period, and no material errors have been identified
in previous periods.
Some of the disclosures have been incorporated by reference in accordance with ESRS 1 section
9.1 Incorporation by reference. A table listing these is provided below:
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List of references
No.
ESRS requirement
ESRS data
point
Document to which the reference is applied
1.
BP-1 – General basis for
preparation of the
sustainability statement
BP-1: 5
Part I. MANAGEMENT REPORT ON ACTIVITY
Section 1. Brief description of Bank Millennium
and the Bank Millennium Group
2.
SBM 1 – Description of the
business model and value
chain
SBM-1: 42
Part I. MANAGEMENT REPORT ON ACTIVITY
Section 1. Brief description of Bank Millennium
and the Bank Millennium Group
Section 2. Summary of consolidated BM Group
results in 2024
Section 8. Financial situation
Section 9. Presentation of business activity
3.
SBM-1 - Strategy,
business model and value
chain
SBM-1: 40b
Part I. MANAGEMENT REPORT ON ACTIVITY
Section 2. Summary of consolidated BM Group
results in 2024
Section 8. Financial situation
15.2. CORPORATE GOVERNANCE
[GOV-4] In all its business operations, the Bank Millennium Group is guided by the principles set out
in the UN International Guiding Principles on Business and Human Rights and the OECD Guidelines for
Multinational Enterprises. The Group is guided by the regulations applicable to the banking sector,
including the Act of 29 August 1997 entitled “Banking Law” and the recommendations issued by the
Polish Financial Supervision Authority. Accordingly, due diligence is maintained in all processes and
with respect to sustainability matters.
Core elements of due diligence
Core elements of due diligence
Area
Pharagraph
Embedding due diligence in
governance, strategy and business
model
E, S i G
15.3. Sustainability management
G
20. Business conduct (ESRS G1)
Engaging with affected stakeholders in
all key steps of the due diligence
E, S i G
15.4.1. Description of the process for
identifying and assessing material impacts,
risks and opportunities
15.4.2. Key stakeholders
S
17.1.1. Interests and views of stakeholders
18.2. Management of impacts, risks and
opportunities
19.1.1. Interests and views of stakeholders
19.2. General customer engagement
processes
19.4.2. General customer engagement
processes in terms of the safety of
deposited funds
19.5.2. Customer engagement processes in
terms of privacy
19.1.1. Customer engagement processes in
terms of access to information
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Core elements of due diligence
Area
Pharagraph
19.9. Remediation of negative impacts
G
20. Business conduct (ESRS G1)
Identifying and assessing adverse
impacts
E, S i G
15.4.1. Description of the process for
identifying and assessing material impacts,
risks and opportunities
15.4.3. Identified impacts, risks and
opportunities
S
17.1. Strategy for the workforce area
19.2. General customer engagement
processes
19.9. Remediation of negative impacts
G
20. Business conduct (ESRS G1)
Taking actions to address those adverse
impacts
E
16.2. Management of impacts, risks and
opportunities
S
17.1.2. Material impacts, risks and
opportunities and their interaction with
strategy and business model
19.1.2. Material impacts, risks and
opportunities and their interaction with
strategy and business model
19.4.3. Measures to ensure the safety of
deposited funds
19.5.3. Measures related to privacy
19.6.3. Measures related to access to
information
G
20. Business conduct (ESRS G1)
Tracking the effectiveness of these
efforts and communicating
E, S i G
15.3.1. Governance structure
15.3.3. Sustainability reporting
E
16.3. Benchmarks and objectives
S
17.1.2. Material impacts, risks and
opportunities and their interaction with
strategy and business model
19.4.4. Objectives related to the pursuit of
the policies and activities
19.5.4. Objectives related to the pursuit of
the policies and activities
19.6.4. Objectives related to the pursuit of
the policies and activities
G
20. Business conduct (ESRS G1)
15.2.1. BUSINESS MODEL AND VALUE CHAIN
Business model
[SBM-1] Bank Millennium and its subsidiaries constitute the Bank Millennium. The Bank Millennium
Group offers services in the retail segment, that is to individual customers and micro-enterprises,
and, within corporate banking, to small, medium-sized and large companies. The Bank Millennium
Group successfully competes in all segments of the financial market.
The Bank and its subsidiaries operate in the Republic of Poland, treated as the Group’s area of
business, and therefore all disclosures included in this statement refer to Poland. With 6,836
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employees (as at 31 December 2024), the Group operates throughout Poland and has no branches
outside of its borders. No changes occurred in the markets or customer groups served during the
reporting period.
The Bank Millennium Group achieves its economic goals while striving to balance the needs of key
stakeholders, in accordance with the Group’s growth strategy, taking into account the principles
declared in the Code of Ethics. Information on the structure of costs and revenues generated by the
Bank’s Group, along with the results posted by each segment, is provided in part I in section
8. Financial standing.
The Bank Millennium’s mission is to support its customers 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.
The Bank’s business model rests on the following six pillars:
1. Superior customer service and a broad offering for the retail customer.
2. Bank of first choice for business customers (micro-enterprises).
3. Strategic development partner for corporate customers.
4. Innovative solutions with a leading User Experience in electronic channels (with a leading role
for the mobile application).
5. Sustainable organisation on the path towards climate neutrality.
6. Friendly workplace for existing employees and talent.
Details of the Bank’s business model are described in part I of this report in section 1. Brief
characteristics of Bank Millennium and the Bank Millennium Group. The information on the business
model is expanded in section 9. Description of business in part I, containing an explanation of the
customer service channels and the product offering for retail and corporate banking customers.
Value chain
A significant element of our business model is the core value chain. The Bank Millennium Group’s core
business is banking and therefore the key value chain for the Group primarily consists of the Bank’s
customers. In the course of our analyses, we have also classified into the Bank’s key value chain our
employees and business partners (franchisees).
A detailed description of our business model and value chain is provided in part I. MANAGEMENT
REPORT ON ACTIVITY, section 1. Section 2. Section 8. Section 9. The following key areas have been
identified while examining the Group’s value chain:
Key areas of the value chain
Value chain
and tier
Identified value chain element and its key areas
Suppliers
Upstream
Suppliers of material categories of goods and services
purchased by the Group examined within the following
subcategories:
- Administration
- ICT & cyber resilience
- Marketing and advertising
- Key sources of financing
Own operations
Bank’s Head Office:
- Marketing
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Value chain
and tier
Identified value chain element and its key areas
- Sales
- Risk management
- ICT & cyber resilience
- HR
- Administration
Own branches
Subsidiaries:
- Millennium Leasing
- Millennium Bank Hipoteczny
- Millennium TFI
Bank Millennium Foundation
Recipients
Downstream
Corporate banking customers
Retail banking customers
Millennium Leasing customers
Distribution channels (brokerage and franchise
network)
Millennium TFI:
- Investors
- Unit distributors
- Transfer agents
- Investee companies
Potential impacts, risks and opportunities and their possible interconnections with our own business
model and value chain are presented in section 15.4.3. Identified impacts, risks and opportunities
and in section 8.2. Results of business segments.
15.2.2. SUSTAINABILITY STRATEGY
[SBM-1] Sustainability plays a significant role in our strategy and has served as one of its pillars for
years. ESG matters were included in the Group’s Strategy for 2022-2024 entitled Millennium 2024:
People Inspire Us, and further developed and elaborated in more detail in the Bank Millennium Group
ESG Strategy for 2022-2024 adopted in 2022. Currently, they also drive the pursuit of our new Strategy
for 2025-2028 entitled Strategy 2028: Value and Growth, published in October 2024, as one of its
success factors. The Strategy addresses all major groups of our products and services, that is those
offered to both retail and corporate customers.
[SBM-1] As a socially responsible institution, we emphasise the significance not only of the
achievement of the objectives provided for in our Strategy, but also of the means by which such
achievement is materialised – with a commitment to society and the environment, in line with
stringent standards of quality and ethics in the sales process and the services offered. In our Strategy,
business objectives and ESG goals form a coherent whole. One of the most important aspects of our
efforts is the fact that we are engaged in pursuing them together as the Bank Millennium Group.
We act jointly with our stakeholders: employees, customers, business partners and shareholders.
Based on the goals set out in the Strategy, we will support our customers in the transition to a low-
carbon economy (PLN 5 billion to finance sustainable investments). We will also achieve the objectives
adopted in our Strategy by investing appropriately in our key assets: people and technology, and will
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continue to build our position as the most attractive employer for top talent in our strategically vital
areas.
Our sustainability-related activities in the new Strategy 2028: Value and Growth have been
categorised into the following three areas:
• Environmental (E)
• Social (S)
• Governance (G)
In the environmental area, our objectives are:
• Moving towards ’net zero’ emissions, that is to achieve climate neutrality in scopes 1 and 2
by 2030
2
and to achieve full climate neutrality, including in scope 3, by 2050.
We will gradually reduce our carbon footprint by continuing our energy and water efficiency
initiatives across our branches, increasing the share of zero-emission vehicles in our fleet,
maintaining 100% electricity with guarantees of origin and adopting a transition plan
(including decarbonisation targets and actions) by 2026.
• Sustainable financing, that is supporting customers’ transition and growth by providing
sustainable financing – we have planned to provide PLN 5 billion in financing for
sustainability projects.
We intend to achieve this goal by providing sustainable financing to companies, raising
awareness and expertise on public programs/green projects, maintaining a policy of providing
no financing to the mining and carbon-based energy generation sectors, expanding the green
retail offering and portfolio of sustainable assets at Millennium TFI, and continuing initiatives
to raise customer awareness of sustainability.
In the social area, our objectives are:
• Top employer, that is maintaining the well-being and professional development of our
employees as well as promoting diversity, equity and inclusion across our business operations
and beyond. We will ensure that we continuously improve employee satisfaction and maintain
our Top Employer certification.
Our planned activities in this area include implementing initiatives that respond to the
outcomes of the Employee Satisfaction Survey, further developing a transparent remuneration
policy, continuing to narrow down the gender pay gap, promoting a culture of lifelong
learning, continuously improving initiatives that affect the well-being of our people, and
strengthening the culture of diversity, equity and inclusiveness (DEI) in our organisation.
• Inclusive and accessible banking that provides secure access to financial services for all
customers, embracing their diversity. We will expand our offering and, with a view to
maintaining the high quality of service accessibility, we will continue to work with external
expert institutions.
The activities we have planned in this area include the continuation of improvement in
ensuring the accessibility of services and education for customers, promotion of regular
savings and investments, deployment of dedicated solutions for young customers, and
provision of financial education to children through the Bank Millennium Foundation’s
initiatives.
• Community engagement, that is supporting local businesses by financing and providing
business tools and engaging employees in local community activities as well as promoting
cultural development.
We will pursue this objective by developing a financing program for micro and small
companies, offering educational initiatives for micro and small companies, further developing
the Bank Millennium Foundation’s employee volunteerism grant program and maintaining our
2
Emission reduction activities will continue, but offsets may be applied for the remaining emissions.
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position as an ambassador of culture in Poland (including by continuing to support the
Millennium Docs Against Gravity film festival).
In the governance area, we will focus on the following objectives:
• ESG risk management, by developing a methodologies for measuring the financial effects of
ESG risks and refining ESG risk management processes with contribution to the transition plan.
We will ensure the successful completion of the European Banking Authority’s and our own
climate stress tests within specify dates as well as the deployment of a framework for
assessing anticipated financial impacts by 2025.
For the pursuit of this goal, we have scheduled specific actions: refining ESG risk assessment
and management coupled with further integration in the credit decision process, further
developing ESG risk metrics in the Risk Appetite Statement (RAS), monitoring climate risk
exposures, developing methodologies and conducting climate stress tests with scenario
analysis, and supporting the transition plan through ESG risk management.
• Maintaining best-in-class governance through the strong pillars of an organisation built on
high ethical standards and mature ESG governance to support sustainable growth and
regulatory compliance, including by timely implementation of new ESG regulations and
further enhancement of ESG reporting in keeping with evolving requirements.
We will strive to achieve this goal through implementation of new regulatory requirements,
alignment of our internal processes, ongoing review and application of existing ESG
regulations, further development of ESG data management and comprehensive ESG
awareness-building initiatives.
The pursuit of the Bank’s Strategy, including the key success factors of which sustainability is a pillar,
is subject to a continuous monitoring process under the Bank’s internal management system. Our
progress in going after the strategic ESG initiatives is monitored on an ongoing basis by the
Sustainability Committee. This process is described in more detail in section 15.3. Sustainability
management.
Our Strategy 2028: Value and Growth is available on the Bank’s website at:
https://www.bankmillennium.pl/documents/d/guest/bankmillennium_strategy2025_2028?mv=3mv.
Currently, our sustainability-related products account for less than 10% of the Bank’s revenues and
are unrelated to the Bank’s material actual impacts or material potential negative impacts. The share
of sustainable financing in the Bank’s assets, in accordance with the GAR, is specified in section
21. Disclosure of information in accordance with EU Taxonomy (Art. 8 of Regulation (EU) 2020/852).
15.3. SUSTAINABILITY MANAGEMENT
15.3.1. GOVERNANCE STRUCTURE
[GOV-1] [GOV-2]
Sustainability management
The basis for defining the approach to sustainability managing is an agenda formulated by the United
Nations that includes 17 goals, 169 targets and 304 indicators.
Bank Millennium has signed the Declaration for the UN Sustainable Development Goals in 2017 and is
guided by all 17 goals. However, the Bank focuses predominantly on the pursuit of the following goals:
3. Good health and well-being
4. Quality education
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5. Gender equality
8. Decent work and economic growth
9. Industry, innovation and infrastructure
13. Climate action
17. Partnering for the goals
In Bank Millennium, actions taken with sustainability in mind form an integral part of our business
strategy. The ESG area is also included in the new Group Strategy for 2025-2028 adopted by the
Management Board and approved by the Supervisory Board. This is discussed in detail in subsection
15.2.2. Sustainability strategy.
Sustainability policies
Bank Millennium has laid down the fundamental sustainability-related principles at the level of the
whole Bank Millennium Group in the Sustainability Policy of Bank Millennium S.A. adopted by the
Bank’s Management Board, of which the following documents, published on the Bank’s website
(https://www.bankmillennium.pl/o-banku/esg#zasady-esg), form an integral part:
• Policy on sustainability principles
• Anti-corruption policy
• Social impact policy
• Human rights policy
• Diversity management policy
• Corporate volunteering policy
• Environmental policy
• Responsible financing policy
Moreover, the Bank has published the following document for suppliers on its website:
▪ Supplier Sustainability Guidelines (approved by a member of the Bank’s Management Board).
Sustainability policies integrate environmental, social and governance dimensions, including:
▪ Aligning decision-making, in all areas of the Bank Millennium Group, with the pursuit of the
United Nations Sustainable Development Goals (“UN Sustainable Development Goals”) as well
as universally applicable laws and national and international sustainability standards.
▪ Taking into account the UN Sustainable Development Goals in the development and offering
of financial products.
▪ Transparency of disclosures regarding the conduct of sustainability activities by the Bank
Millennium Group.
▪ Building awareness among employees, customers and other stakeholders of the Group in the
sustainability area.
▪ Adherence to the highest standards of operation, including the Corporate Governance
Principles for Supervised Institutions and the Best Practices for WSE Listed Companies, and
striving to continuously ensure full compliance with generally applicable laws and business
standards.
▪ Building partnerships and an ongoing commitment to working with communities – both
external and internal – in the search for opportunities to create social value by supporting
cultural, educational and financial literacy initiatives as well as employee volunteerism
activities.
Based on the UN Sustainable Development Goals, the commitments arising from the Bank’s signature
Diversity Charter, internal policies and best practices, we have made the following commitments:
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▪ Integrate environmental and social risks into our customer risk assessment process and include
ESG risk factors in sector policies for corporate customers.
▪ Define a list of sectors and activities to which no financing will be provided by the Bank
Millennium Group – the Group identifies business sectors or projects the financing of which is
incompatible with the Bank Millennium Group’s commitment to protect the environment,
promote sustainability, combat climate change and preserve biodiversity. For this reason, the
Bank Millennium Group has identified sectors excluded from financing or sectors that may
receive only conditional financing (the financing of activities or projects in these sectors may
be granted only if additional conditions have been fulfilled).
▪ Finance environmentally friendly and energy-efficient projects, including projects related to
the replacement of coal-fired generation with low-carbon energy sources.
▪ Carry out activities aimed at reducing the carbon footprint.
▪ Respect for human rights – the Bank Millennium Group takes into account and promotes the
fundamental principles of human rights by applying ethical business practices towards various
stakeholder groups, including employees, customers, shareholders, suppliers and local
communities. Such practices are clearly defined in the Bank Millennium Group’s pertinent
internal regulations.
▪ Develop sustainability competencies – we offer training and initiatives for employees to grow
their sustainability competencies.
▪ Promote a culture of responsible consumption – the Bank Millennium Group has adopted, as
part of its Supplier Sustainability Guidelines, a set of requirements for suppliers where
sustainability matters are covered.
▪ Influence society – promote a culture of social responsibility, develop activities for and with
various stakeholder groups, while directly or indirectly supporting social development.
The foregoing Sustainability Policy commitments apply to all activities and business relationships
of the Bank Millennium Group.
Sustainability management [GOV-1] [GOV-2] [G1 GOV-1]
The Bank’s Management Board is responsible for the effective management of the Bank’s
sustainability area, in terms of environmental, social and governance issues, including responsibility
for developing, approving and updating the organisation’s sustainability-related goals, values,
mission, strategies, policies and targets. The Bank’s Supervisory Board oversees this process. The
governance arrangements adopted in the Bank Millennium Group do not involve assigning
responsibilities, tasks or powers in respect of one-off impacts, risks and opportunities identified in
the double materiality analysis.
The Management Board approves sustainability reporting and sustainability-related policies.
Sustainability-related policies are approved by the Management Board in accordance with the
schedule for updating such documents, but not less frequently than once every two years.
Sustainability reporting is also adopted and subsequently approved by the Supervisory Board.
Within the Management Board, the sustainability area is overseen by the President of the Management
Board, while ESG risk management is overseen by the Bank’s Management Board member responsible
for risk.
The Management Board is provided with information to control and oversee the processes aimed at
identifying and managing its economic, environmental and social impacts, including periodic reports
on the achievement of targets in all key areas of the Bank’s operations. To this end, the Management
Board’s control activities are also carried out by committees established within the Bank’s structures.
In this process, information obtained from the Bank’s stakeholders is also taken into account, such as
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that regarding employee matters or issues arising from complaints or customer service surveys. For
instance, the Process and Operational Risk Committee prepares reports on customer complaints and
actions taken by the Bank on issues identified in the complaint handling process and reports on the
quality of the customer service process and studies of customer needs. The Sustainability Committee
also plays a key role in this regard.
The Supervisory Board also receives, on a quarterly basis, in some instances through its committees,
information on key aspects of the Bank’s business, including aspects related to its economic,
environmental and social impacts. Moreover, a 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 annual reports. They are analysed and presented to 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.
Bearing in mind the growing significance of sustainability matters for the Bank Millennium Group’s
business, the Bank has established within its structures the Sustainability Committee and the
Sustainability Department.
The Bank’s Management Board participates in the process of managing sustainability matters through
its full representation in the work of the Sustainability Committee. 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 Group. The Sustainability Committee is
chaired by the President of the Management Board. The Committee meets at least quarterly.
The Committee’s scope of work includes participation in the development of proposals for the Bank’s
strategic initiatives in the area of sustainability, adoption of operational plans related to the
execution of strategic sustainability initiatives, monitoring and evaluation of the pursuit of planned
activities in terms of their completeness and quality, meeting the required deadlines and the planned
budget, approving and monitoring metrics related to strategic sustainability initiatives. Committee
meetings also discuss the most relevant ESG matters on an ongoing basis, including those related to
the management of identified material impacts, risks and opportunities.
The Sustainability Department is overseen directly by the President of the Management Board. The
purpose of the Sustainability Department is to oversee and coordinate the observance of sustainability
principles within the Bank and the Bank Millennium Group. The scope of tasks of the Sustainability
Department includes coordination of work related to the sustainability strategy, cooperation with
other units of the Bank and Group entities in the pursuit of sustainability principles, ensuring
identification of risks related to climate change in the Bank’s activities, cooperation with other units
of the Bank in the roll-out of sustainable products, conducting activities aimed at promoting
sustainability principles among the Bank’s employees.
The Risk Department is responsible for integrating ESG risks into the Bank’s risk management system.
The Risk Department’s key tasks include consideration of ESG risk within the risk appetite, analysis
of the materiality of the impact of ESG risk on the Bank’s risk profile, development of ESG risk
assessment methodologies within the framework of existing risk assessment methodologies and
processes, and monitoring the impact of ESG risk on the area of capital adequacy.
The Bank has also established a Risk Committee, which is responsible for risk control, including for
reviewing the principles, policies, rules and practices related to risk management, also by managing
ESG risks and making decisions on key elements of lending policy, including those related to ESG risks.
The Risk Committee, which comprises all members of the Management Board, prepares quarterly
summary information and materials for the Supervisory Board Risk Committee and the Supervisory
Board, addressing key issues related to the impact of risks – including ESG risks – on the Bank’s overall
risk profile. The Committee meets at least quarterly.
Moreover, sustainability activities (including the management, control and monitoring of impacts and
related activities) in the distinct areas of competence are the responsibility of other units of the Bank
and the Bank Group in accordance with their areas of responsibility, forming an integral part of the
business, with each area of business assigned to specific senior managers (that is individuals reporting
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directly to the President of the Management Board or members of the Management Boards of either
the Bank or Group companies).
The Bank’s Management Board and Supervisory Board
Information on the composition of the administrative, management and supervisory bodies, their roles
and responsibilities and their access to expertise and skills, including a description of the powers of
members of the Bank’s Supervisory Board and the Bank’s Management Board relevant, among other
aspects, to the management of the company’s economic, environmental and social impact, are
described in part I of this report in sections 13.3 Supervisory Board and 13.4 Management Board as
well as on the Bank’s website:
https://www.bankmillennium.pl/o-banku/wladze-banku-i-lad-korporacyjny/zarzad
Annually, Bank Millennium conducts a comprehensive appraisal of the performance of each member
of its corporate bodies and evaluates the collective suitability of those bodies, based on the provisions
of the Banking Law, the EBA and ESMA Guidelines (EBA/GL/2021/06) on assessing the suitability
of members of the management body and persons performing key functions, the methodologies for
assessing the suitability of members of the bodies supervised by the Polish Financial Supervision
Authority and the policies in force in the Bank for selecting and appraising the suitability
of Supervisory Board members and Management Board members.
Supervisory Board
The Supervisory Board has 12 members, of which currently 3 are women and 9 are men, meaning that
the average ratio of women to men among the Supervisory Board members is 33.3%. There are
currently 5 independent members in the Supervisory Board (42%). There are no employee
representatives on the Supervisory Board. According to the Commercial Company Code and the
Banking Law, the Supervisory Board is a non-executive body (the number of its non-executive
members is 12).
In the course of the appraisal, the individual and collective competence profiles of the Supervisory
Board members were examined and it was concluded that the Supervisory Board members – both
individually and collectively – meet the expected competence requirements. In particular, the
diversity of the composition of the Supervisory Board in terms of age, gender, professional experience,
knowledge and skills and the fact that it includes both business representatives and academics reflect
due care in ensuring that the Supervisory Board’s views on the performance of the Management Board
are as diverse as possible. Among the required competencies of the Supervisory Board members, those
related to sustainability were also evaluated. The Methodology for assessing the suitability of
members of corporate bodies of supervised entities – Polish Financial Supervision Authority is applied
to evaluate such competences. Moreover, the level of competence is appraised using a scale that
takes into account factors such as knowledge, experience and practical skills in the respective area.
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 Bank’s Management Board
The Bank’s Management Board consists of 7 members. There is currently no gender diversity in the
composition of the Bank’s Management Board – all members of the Management Board are men.
However, this aspect will be taken into account as one of the factors when making changes to the
composition of the Management Board. As part of the appraisal, the competence profile of the
Management Board in terms of general management, risk management, knowledge of business lines
and soft skills was evaluated. The individual profiles and the collective competence profile were
compared and it was concluded that the Management Board meets the expected competence
requirements. The composition of the Management Board fulfils the diversity criteria in terms
of professional experience, in particular in terms of experience gained in different markets (Polish
and Portuguese markets), as well as in terms of education and age, thus enabling different views to
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be presented while managing the Bank. Four members of the Management Board are Polish citizens.
There is currently no gender diversity in the composition of the Management Board.
Members of the Bank’s Management Board and members of the Management Boards of Bank
Millennium Group companies undergo training, consistent with their roles, knowledge and experience.
Such training is also designed to enhance their knowledge, skills and experience in the sustainability
area.
All members of the Management Boards of Bank Millennium Group companies participated in
a comprehensive ESG training program held in 2023, the topics of which included key ESG regulations,
sustainable financing, ESG risk management, organisation of the ESG process and supervisory
requirements in this area.
In the first half of 2024, members of the Bank’s Management Board and members of the Management
Boards of Bank Millennium Group companies participated in a workshop on sustainability reporting
consistent with the CSRD and ESRS requirements, including in terms of double materiality analysis.
In the second half of 2024, they participated in a workshop on preparing a transition plan.
Information provided to administrative, management and supervisory bodies and sustainability
matters pursued by them
The Sustainability Committee is responsible for monitoring sustainability-related matters. The
Committee’s powers are described in subsection 15.3.1. Governance structure. The Sustainability
Committee meets at least quarterly.
During the Committee’s meetings, the range of issues discussed includes the progress made in
implementing the Sustainability Strategy and ongoing activities carried out by the Bank in this area.
The Bank’s Management Board, through the direct participation of all Management Board members in
the Sustainability Committee meetings, is provided with relevant information about all sustainability
matters.
In 2024, key sustainability matters were presented at the Sustainability Committee meetings. The
topics covered during the reporting period covered all relevant risks, impacts and opportunities,
including matters related to the monitoring and execution of the ESG strategy, including:
• Striving for climate neutrality
• Reduction of resource consumption
• Product offering to support sustainability
• Responsible lending policy
• Development of sustainable finance – partnerships with organisations
• Educational activities
• Employee development and support
• Promotion of gender equality and diversity
• Supporting customers in growing their business and finance
• Banking without barriers
• Education and security
• Charity and cultural support
• Organisational excellence – continuous organisational improvement in the ESG area
• Corporate governance and compliance policy
• Reporting and disclosures
• Climate risk management
• Sustainable supply chain policies
• Plain-language communication
Furthermore, other topics discussed during the Committee’s meetings included current relevant issues
related to the ESG area, such as the issuance of green bonds, ongoing ESG risk management activities,
interactions with regulators in the ESG area, preparation of the transition plan, and changes in
internal sustainability-related regulations.
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In 2024, members of the Sustainability Committee and members of the Management Boards of the
Bank’s Group companies, participated in a workshop on the preparation of a double materiality
analysis. Committee members discussed the material risks, impacts and opportunities identified as
a result of the double materiality assessment process and then validated the results of the analysis.
Sustainability-related matters are also addressed at the quarterly Risk Committee meetings the
participants of which include all members of the Bank’s Management Board.
In 2024, key ESG risk management issues were presented at the Risk Committee meetings, including
the following:
• The Risk Materiality Assessment for 2023/2024 was approved, including in respect
of the impact of ESG factors.
• ESG factors were included in the taxonomy of risks.
• Changes were made to the sector policy in the micro-enterprise segment (ESG risks were
taken into account in the new lending policy and excluded sectors were defined on this basis).
• Amendments were made to the lending policy for the corporate segment (principles for
integrating ESG matters into the lending policy were defined).
The Risk Committee periodically reports to the Bank’s Management Board on key issues related to the
impact of risk – including ESG risk – on the Bank’s overall risk profile.
In January 2025, the Bank’s Management Board approved the results of the double materiality
analysis. It also actively participated in the preparation of strategic ESG initiatives in the Bank’s
Strategy for 2025-2028 and approved the Strategy. The Management Board also approved the Risk
Strategy, a component of which is a materiality analysis of risks that also takes into account the
materiality of climate-related and environmental factors.
In 2024, the Supervisory Board Audit Committee received information on sustainability, including
sustainability reporting. Furthermore, the Supervisory Board Audit Committee took note of the results
of the double materiality analysis approved by the Bank’s Management Board. While meetings are
held on a quarterly basis, the said matters related to the ESG area were discussed in Q4 2024 and in
Q1 2025.
The Supervisory Board Risk Committee recommended the Risk Strategy (including in respect of ESG
risks) for approval by the Supervisory Board and received information on risk appetite metrics,
including those related to the ESG area, on a quarterly basis. The Committee meets once every
quarter.
In 2024, the Supervisory Board participated in the oversight of the sustainability area through the
Committees mentioned above as well as by adopting the ESG Report of Bank Millennium and the Bank
Millennium Group for 2023 and approving the Bank’s Strategy 2025-2028 – Value and Growth and the
Risk Strategy for 2025-2028. On a quarterly basis, the Supervisory Board also received information on
Risk Appetite Statement (RAS) metrics, including those related to the ESG area.
15.3.2. INTEGRATION OF SUSTAINABILITY-RELATED PERFORMANCE
IN INCENTIVE SCHEMES
[GOV-3] Sustainability-related performance is taken into account by the Bank in the incentive
schemes applied as part of the Bank’s employee compensation policies. Such incentive schemes apply
to members of the Bank’s Management Board and key managers involved in the pursuit of strategic
initiatives in the ESG area.
The rules for compensating members of the highest governance bodies are set forth
in the Compensation Policy for Bank Millennium S.A. Management Board and Supervisory Board
Members. Senior management (employees identified as exerting a material impact on the Group’s
risk profile, also known as Risk Takers) are subject to the provisions of the Compensation Policy for
Risk Takers in the Bank Millennium Group. The policy aims to provide a formal framework for
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determining the compensation of all the Group’s employees from the perspective of corporate
governance, institutional safety and the suitability of compensation to the Group’s standing, scale of
operation and growth potential, by defining fixed and variable compensation elements. The terms
and conditions of employee compensation, including incentive schemes, are updated and approved
by the President of the Management Board on an annual basis. In turn, the terms and conditions
of compensation payable to Management Board members are approved by the Supervisory Board
Personnel Committee.
The compensation principles put in place have been formulated in such a manner as to avoid creating
incentives that might incline people to engage in activities and take decisions that pose a threat to
the Bank’s long-term welfare and transcend the acceptable risk profile, to take actions at odds with
the best interests of the Group’s customers and investors and to introduce risks to sustainable
development in the activity of Group companies.
Such (and amendments thereto) are approved by the Bank’s Supervisory Board.
[E1 GOV-3] [GOV-3] As regards members of the Management Board and senior management, their
performance is appraised in relation to all adopted strategic sustainability objectives. For 2024, the
benchmarks were set in the form of objectives defined in the Bank Millennium Group ESG Strategy
for 2022-2024
(www.bankmillennium.pl/documents/d/guest/bankmillennium_strategy2025_2028?mv=3mv).
The aspect assessed is the degree of delay in the pursuit of the strategic initiatives implementing
specific goals. The assessment is made with reference to the adopted benchmarks (% of delays). In
2024, among the initiatives assessed in terms of the timeliness of their implementation were climate-
related issues such as the pursuit of climate neutrality, the reduction in resource consumption, and
the development of sustainability-supporting product offerings. These goals were unrelated to the
reduction in greenhouse gas emissions.
Moreover, in the case of the Management Board members, the achievement of the objective
Initiatives with social impact in PLN millions is also evaluated in relation to the value threshold
adopted.
The Management Board evaluation is based on the financial and business performance of the Bank as
a whole, combined with an assessment of qualitative and quantitative indicators related to principles
and behaviours that foster prudent risk management as well as an assessment of the Bank’s risk
profile. The assessment of sustainability activities is included in the qualitative assessment process
through which the initial bonus value may be modified. For senior management, the ESG criterion
accounts for 10% of the assessment factors. Timely implementation of sustainability initiatives means
that this component of the bonus is awarded. The assessment of the progress of the initiative is
carried out by the head of the Sustainability Department.
15.3.3. SUSTAINABILITY REPORTING
[GOV-5] The principles related to the management and control of the ESG area at the level of the
whole Bank Millennium Group are governed by the document entitled ESG – Principles of Management
and Control adopted by the Management Board. The main objective of these principles is to provide
the Bank Millennium Group with a robust framework for the management and control of the ESG area
(including the management and control of ESG risks) in full compliance with legal and regulatory
requirements, applicable internal regulations and best market practices. The document also describes
the responsibility of the Sustainability Department for ESG reporting.
Bank Millennium has internal guidelines in place that govern the sustainability reporting process.
These guidelines include rules for obtaining and verifying data and preparing the report in accordance
with the applicable standards.
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The Sustainability Department, as the unit responsible for the sustainability reporting process,
is responsible for:
• Coordinating data acquisition activities from other competent areas,
• Ensuring that the report complies with legal and regulatory requirements,
• Verifying the completeness and integrity of the data provided by the various substantive
units.
The sustainability reporting process is designed to be transparent and reliable. It includes the
following stages:
• Defining the content of the report,
• Acquiring data,
• Verifying data,
• Preparing the final content of the sustainability reporting,
• External validation,
• Approval by the Bank’s competent authorities.
The process of preparing sustainability reporting involves cooperation with various organisational units
of the Bank Millennium Group. All participants in the process have had the opportunity to familiarise
themselves with the new reporting requirements in accordance with the European Sustainability
Reporting Standards (ESRS) as part of the ongoing Double Materiality Analysis (DMA) process.
Identifying and managing sustainability reporting risks is an important part of responsible governance.
As part of our responsible approach to managing these risks, we regularly identify and evaluate risks
that may affect the completeness, reliability and compliance of our sustainability reporting with the
applicable regulations.
The risks identified in this regard in the Bank Millennium Group are:
• Risk of data completeness and integrity – potential omission of material information or
misrepresentation of data,
• Risk of accuracy of estimated results – potential deviations due to the methodology or
assumptions used in the estimate,
• Value chain data availability risk – limited availability or absence of data from suppliers
and/or other value chain partners,
• Timeliness risk – delays in the provision of key data that may affect the timeline for
sustainability reporting.
• Regulatory risk – non-compliance with the applicable laws or regulations.
The assessment of these risks is carried out by the Sustainability Department using an expert method
of discussing the risks during regular department meetings, prioritising them and planning actions to
address them. Due to the rapid development of sustainability reporting regulations as well as
increasing data requirements, currently all risks listed above are assessed as having equivalent
weights. For this reason, we integrate the findings from the risk assessment and internal controls with
regard to the sustainability reporting process into the relevant internal processes on an ongoing basis
by adding appropriate provisions in the relevant policies and procedures applied to the Group’s
operations.
To effectively manage these risks, we have implemented the following solutions:
• Internal regulations – we have prepared internal procedures governing the reporting process
which define the roles, responsibilities and data quality standards.
• Control activities related to data verification at the source level, checking data consistency
and compliance with regulations.
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• Awareness building within the bank on reporting obligations and responsibility for the
completeness and accuracy of the reported data (meetings, workshops).
• Source documentation – all data presented in the report are appropriately documented,
enabling their verification.
• Process automation – work is underway in the Bank Millennium Group to deploy
a comprehensive data management system in order to reduce the risk of errors to
a minimum.
• Subjecting sustainability reporting to an independent assurance service.
The process of preparing sustainability reporting described above has been discussed at the meetings
of the Sustainability Committee and the Supervisory Board Audit Committee.
15.4. DOUBLE MATERIALITY ASSESSMENT
15.4.1. DESCRIPTION OF THE PROCESS FOR IDENTIFYING AND ASSESSING
MATERIAL IMPACTS, RISKS AND OPPORTUNITIES
[IRO-1] In accordance with the requirements of the sustainability reporting standards, serving as the
basis for determining the scope of the disclosures and the related application requirements has been
a process for identifying the impacts, risks and opportunities, and assessing which of them are
material. This process has been carried out taking into account the principle of double materiality,
that is both the environmental and social impacts of the Bank Millennium Group have been taken into
account (impacts on the external environment, also referred to as impact materiality) and the impact
of external factors: environmental, social and governance-related on the Bank Millennium Group
(impact of the environment on the Bank Millennium Group, also referred to as financial materiality).
[IRO-1] [BP-1] In both identifying and assessing materiality, we have taken into account the impacts
arising from our own operations and business relationships in the value chain. The starting point of
the process has been an understanding of the Group’s own operations, business model, products,
services and data management and a mapping of the whole value chain (upstream and downstream),
as part of which we have identified the issues to be further analysed for materiality.
The Group’s core business is banking and, as such, a crucial area of our value chain to be analysed
has been the loan portfolio by business segment (retail and corporate), including in the context of
financed sectors. Due to the business carried out by the Bank Millennium Group (financial/service
activities) in the area of resource dependency, we have primarily identified dependency on human
resources. The assessment of financial materiality has been carried out from the perspective of those
users of the Bank Millennium Group’s financial statements who make decisions (if need be) taking into
account all available information, including in the area of sustainability. Accordingly, and any such
information is omitted or distorted, this may affect the user’s decision. This is the case for risks and
opportunities causing or likely to cause significant financial impacts for the Group in the future.
[IRO-1] The outcomes of the double materiality assessment have been subjected to input from all
stakeholders (interested parties) of the Bank Millennium Group, identified in the course of the
analyses and appropriately involved in the process of identifying and assessing specific impacts, risks
and opportunities. Stakeholder engagement has been driven by a desire to understand how the Group
affects the stakeholders. The main forms of stakeholder engagement have been surveys, workshop
sessions and, in the case of the environment, desktop studies, that is analyses of selected studies and
reports made available by organisations representing environmental interests, such as WWF Poland
and Climate Strategies Poland. A survey of stakeholders’ interests and views on ESG matters identified
in the ESRS was conducted in December 2023. The survey covered all employees of the Bank
Millennium Group and selected external stakeholders (specifically, customers and business partners).
Additional surveys were conducted in June 2024 and targeted our key business partners: mortgage
brokers and franchisees. The results of the double materiality assessment were also determined by
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the responses given by employees in the Bank's satisfaction survey. The Voice of Customer (VOC)
complaint root cause elimination program has also been analysed for ESG matters raised by customers
requiring action on the Bank’s part. Internal dialogue sessions were also held in June 2024 with
representatives of selected Bank departments and subsidiaries in order to identify the value chain
and plan stakeholder engagement, among other issues. The information collected from stakeholders
has been used to complete the list of actual and potential impacts and has been taken into account
in the final assessment of the identified impacts concerning the respective stakeholder group.
The Sustainability Department was responsible for conducting the double materiality assessment. The
identified impacts, risks and opportunities as well as the proposals for their assessment have been
subject to verification with internal documentation and confirmation with the responsible units,
primarily the Risk Department and the Compliance Department. The outcomes of the double
materiality analysis have been subject to approval by the Sustainability Committee and by the Bank’s
Management Board and subsequently presented to the Bank’s Audit Committee.
For the purpose of ensuring appropriate knowledge of sustainability reporting requirements, training
sessions and workshops have been held with management and staff involved in the double materiality
analysis process, including representatives of Bank Millennium Group subsidiaries.
[IRO-1] [BP-1] For the identification of impacts, risks and opportunities, we have resorted to multiple
sources of information, including reputable external sources, such as the UNEP FI Portfolio Impact
Analysis Tool for Banks and the SASB Materiality Finder tool. In particular, these tools have been used
to identify impacts in relation to the Group’s core business, that is the Group’s loan portfolio.
[E1 IRO-1] Information regarding identified climate-related impacts, risks and opportunities can be
found in section 15.4.3. Identified impacts, risks and opportunities, in the part: Climate related
impacts, risks and opportunities – identification and assessment.
[E2 IRO-1] Actual and potential impacts, risks and opportunities related to pollution of air, water and
soil (excluding greenhouse gas emissions and waste), microplastics and substances of concern, as well
as dependence on ecosystem services within the Millennium Bank Group's own operations and
upstream and downstream value chain were identified using the UNEP FI Portfolio Impact Analysis
Tool and SASB Materiality Finder. The Bank did not consult on pollution, as no significant
concentration of the Group's operations and its value chain in the sectors identified by the
aforementioned sources as having a significant impact on pollution was identified. Nor were the local
communities affected by such activities identified.
[E3 IRO-1] Actual and potential impacts, risks and opportunities related to water and marine
resources within the Millennium Bank Group's own operations and upstream and downstream value
chain were identified using the UNEP FI Portfolio Impact Analysis Tool and SASB Materiality Finder.
The Bank did not consult on water and marine resources, as no significant concentration of the Group's
operations and value chain was identified in the sectors identified by the aforementioned sources as
having a significant impact on water and marine resources. Nor have local communities been
identified as being affected by such activities.
[E4 IRO-1] Actual and potential impacts, risks and opportunities related to biodiversity and
ecosystems within the Millennium Bank Group's own operations and upstream and downstream value
chain were identified using the UNEP FI Portfolio Impact Analysis Tool and SASB Materiality Finder.
Direct impact factors on biodiversity loss, impacts on the status of species, and impacts on the extent
and condition of ecosystems were analysed. The Bank did not consult on biodiversity and ecosystems,
as no significant concentration of the Group's operations and value chain was identified in the sectors
identified by the aforementioned sources as having a significant impact on biodiversity and
ecosystems. Nor were the local communities affected by such activities identified.
The Bank has not identified and assessed dependencies on biodiversity and ecosystems and related
services in its own upstream and downstream locations and value chain, nor has it considered systemic
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risk and conducted scenario analyses. The Bank assesses the scope and level of detail of the analyses
carried out as tailored to its operations across the value chain.
The Bank has no locations in or near biodiversity-sensitive areas. No need to implement biodiversity
loss mitigation measures, such as those set forth in:
• Directive 2009/147/EC of the European Parliament and of the Council on the conservation of
wild birds;
• Council Directive 92/43/EEC on the conservation of natural habitats and wild fauna and flora;
• Environmental Impact Assessment (EIA) as defined in Article 1(2)(g) of Directive 2011/92/EU
of the European Parliament and of the Council (76) on the assessment of the effects of certain
public and private projects on the environment.
[E5 IRO-1] Actual and potential impacts, risks and opportunities related to resource use (input and
output resources) and the circular economy (waste management, including hazardous waste and non-
hazardous waste) within the Millennium Bank Group's own operations and upstream and downstream
value chain were identified using the UNEP FI Portfolio Impact Analysis Tool and SASB Materiality
Finder. The Bank did not consult on resource use and the circular economy, as no significant
concentration of the Group's operations and its value chain were identified in the sectors identified
by the aforementioned sources as having a significant impact on resources and the circular economy.
Nor were the local communities affected by such activities identified.
[G1 IRO-1] The process of identifying material impacts, risks and opportunities in the area of
corporate governance was conducted in accordance with the methodology adopted by the Bank and
described in Section 15.4. The criteria used in the process took into account the specifics of the Bank's
banking and leasing activities in Poland, including the Group's applicable laws and regulations, as well
as the significant impacts, risks and opportunities previously identified by the Group or its parent
company.
[IRO-1] The double materiality assessment process was conducted in 2024 for the first time. The
double materiality analysis carried out in accordance with the ESRS is subject to approval by the
Management Board each time new, previously unidentified impacts, risks and opportunities are
identified or their assessment changes. Such situations may arise from significant changes in the
Group’s business activities or significant external factors. When events are identified that may change
the outcomes of the double materiality analysis, and at least annually regardless of the occurrence
of such events, the double materiality analysis gets reviewed.
15.4.2. KEY STAKEHOLDERS
Key stakeholders
Engagement with interested parties (stakeholders) affected by the entity plays a fundamental role in
the ongoing due diligence process carried out by the entity. Stakeholders are parties that may affect
or be affected by the Bank Millennium Group’s actions. Stakeholders are broken down into two the
following main groups:
(a) stakeholders affected by the Bank Millennium Group: individuals or groups whose interests
are or may be affected, positively or negatively, by our activities and the Group’s direct and
indirect business relationships across the value chain, and
(b) users of sustainability statements: primary users of financial reporting for general purposes
(existing and potential investors, lenders and other creditors, including asset managers, credit
institutions, insurance companies) as well as other users of sustainability statements,
including our business partners, trade unions and social partners, civil society, NGOs,
governments, analysts and academics.
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[SBM-2] The Bank Millennium Group conducts its business taking into account the views, interests and
rights of the key stakeholders it impacts, which include:
1. Employees and the trade unions that represent them,
2. Key business partners (franchisees, brokers, product and service providers),
3. Our customers (corporate and retail),
4. Investors holding more than 5% of Bank Millennium shares, including our major shareholder
Banco Comercial Português (BCP),
5. Natural environment (also referred to as a silent stakeholder represented by environmental
organisations).
The identification of our material stakeholders has been carried out in the course of a double
materiality analysis taking into account the analysis of the Bank Millennium Group’s operational
activities and based on interviews with employees.
Employees of the Bank Millennium Group
[SBM-2] A significant pillar of our business model is creating a welcoming workplace for existing
employees and talent. We see employee engagement and satisfaction as key prerequisites for
achieving the goals we set and the success we achieve as well as for the long-term development of
our organisation. We conduct annual satisfaction surveys of our employees. Their outcomes are
meticulously examined in order to make necessary changes to the relevant processes. Employees may
also report irregularities through dedicated online channels and an email address. They may share
their comments and opinions via the Viva Engage social network and the Millennium World corporate
intranet. Additionally, under the agreements in place, the Bank and the trade unions agree on internal
regulations relevant to employees, such as compensation regulations, bonus regulations, remote work
regulations and the social fund spending plan. The Bank also consults with the trade unions on case-
by-case employee issues.
These communication channels enable us to obtain information from all employees – our own
personnel (head office and own branches) and those working in the value chain (employees of
franchise branches). Any information so obtained regarding interests, views and rights is then
thoroughly analysed and used to make adjustments to our business model and strategy.
Our customers
[SBM-2] Bearing in mind our business model in which we focus on a tailored offering to our customers
and the highest quality of customer service, the identification of customer needs is an ongoing, initial
element of every project. Research is carried out on samples of retail, corporate and micro (small
business) customers. In 2024, Bank Millennium conducted quantitative and qualitative research in the
area of market trends and specific assumptions in the area of products and service quality. This
information is supplemented by projects using the Service Design methodology, in which a full
understanding of customer needs plays a key role. The results of the research are presented to the
relevant business units as well as at a special meeting – the CX Forum, which is held every two weeks
with selected members of the Management Board. The purpose of these meetings is to show current
information on how the Bank’s customers evaluate products and services as well as to make decisions
on how to improve the customer experience. Customer research is used both to improve the quality
of service and to develop the product offering. Such an approach allows us verify and then modify a
process, product, communication or customer service model. Regularly performing this research
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. In order to continuously improve the
product offering and the quality of customer service, the Bank also analyses customer requests and
complaints; details related to this form of cooperation with customers is presented in sections 19.2.
General customer engagement processes and 19.9. Remediation of negative impacts.
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The analyses also take into account key business partners, which include franchisees, brokers, product
and service providers. Franchisees, as an important distribution channel for banking services,
constitute the group of business partners most significantly affected by the Group and are described
in detail in the section about employees in the value chain.
In the group of investors holding more than 5% of Bank Millennium’s shares, the stakeholder
engagement process has taken into account the interests and opinions of the Bank Millennium Group’s
main shareholder, BCP, through direct communication with its representatives, OFE PZU Złota Jesień
through the analysis of the Sustainable Investment Policy of PZU SA and PZU Życie SA (2024), Allianz
Polska OFE through the analysis of the Sustainability Report 2023 and Nationale-Nederlanden OFE
through the analysis of the NN Responsible Investment Framework Policy (2024).
The natural environment has been identified as a stakeholder affected by environmental impacts.
NGOs and research and scientific institutions speak on behalf of the environment. Among the reports
taken into account have been the following: Zero Emission Poland 2050 – WWF (2020) and Reporting
alone will not protect the climate. Decarbonising your business – climate competitiveness 2.0 –
Climate Strategies Poland Foundation (2024).
Stakeholder engagement in the double materiality assessment process
[SBM-2] The key stakeholders we impact through our operations have also been involved in the process
of identifying impacts, risks and opportunities and assessing their materiality. The process serves as
a basis for identifying the scope of this statement. Through participation in surveys and workshop
meetings, stakeholders have been given the opportunity to provide their views on topics of importance
to them, related to the Millennium Group’s activities. As regards the specific stakeholder in the form
of the natural environment, which we impact through our value chain, we have used the opinions and
studies of selected organisations representing environmental interests in our analyses.
Engagement of Bank Millennium Group corporate bodies in dialogue with stakeholders
The opinions of the stakeholders we impact are analysed in depth and communicated at all levels of
management in the Bank. The outcomes of customer needs surveys are discussed twice a month at
the CX Forum – a meeting organised with selected Board Members and representatives of pertinent
business units. In terms of other forms of communication with stakeholders and gathering information
on stakeholder opinions, dedicated workshop meetings are organised with representatives of relevant
areas. Sustainability matters are given special attention by the Sustainability Committee at its regular
meetings. The extent of involvement of the Management Board, the Supervisory Board Audit
Committee and the Sustainability Committee in the double materiality analysis process carried out in
the preparation of this statement (including: communicating the views and interests of the Bank’s
affected stakeholders) is described in section 15.4.3. Identified impacts, risks and opportunities.
15.4.3. IDENTIFIED IMPACTS, RISKS AND OPPORTUNITIES
[SBM-3] As part of the double materiality analysis on the basis of which the list of issues considered
in this sustainability statement has been determined, we have examined the impacts, risks and
opportunities in all areas of sustainability: environmental, social and governance, and we have
evaluated them in terms of materiality across the Bank Millennium Group’s value chain.
As a result of our analysis, we have identified the following material impacts and risks within the
sustainability themes covered by the ESRS. We have not identified any material opportunities.
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Identified impacts and risks (in accordance with ESRS)
Area
ESRS
Thematic
unit
Sub-theme
Impacts
Risks
Description
Classification
Description
Classification
Environment
E1 Climate
change
Climate
change
mitigation
-
Not identified
Risks to the corporate loan
portfolio arising from the
financing of customers in
high-emission sectors and
related to potential
reduction targets for
scope 3 of category 15
Risks in the
downstream value
chain in the medium
to long term
Risks associated with the
transition of corporate
customers towards a low-
carbon economy
Risks in the
downstream value
chain in the medium
to long term
Social
S1 Own
workforce
Working
conditions of
own
workforce
Work-life balance
Impact resulting from measures
in place to support employees’
work-life balance
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Not identified
Job security
Impact related to ensuring job
security for employees through
stable forms of employment,
programs dedicated to employees
approaching retirement age and
a broad range of fringe benefits
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Working time
Impact resulting from strictly
defined working hours and
overtime monitoring
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Adequate
compensation
Impact related to measures taken
to ensure adequate
compensation
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Freedom of
association,
existence of
works councils
and employees’
rights to
information,
consultation and
participation
Impact through ensuring freedom
of association of employees and
cooperation with trade unions
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
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Area
ESRS
Thematic
unit
Sub-theme
Impacts
Risks
Description
Classification
Description
Classification
Social dialogue
Impact through establishing
effective channels of
communication with employees
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Occupational
health and safety
Impact related to ensuring a safe
working environment
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Impact related to potential
exposure to acts of violence
among branch employees (due to
handling of cash)
Potential negative impact in
own operations across all
timeframes
Equal
treatment
and equal
opportunities
for all
Gender equality
and equal pay for
work of equal
value
Impact related to the promotion
of gender neutrality, including in
the area of employee
compensation
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Not identified
Training and skills
development
Impact related to attention to
the development of employees’
skills, including through training
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Measures to
prevent violence
and harassment in
the workplace
Impact related to taking
measures to prevent violence
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Diversity
Impact related to the promotion
of diversity
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Other work-
related rights
Privacy
Impact related to the protection
of privacy and personal data of
the Group’s own workforce
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Not identified
S2 Workers in
the value
chain
Working
conditions
Job security,
Working time,
Adequate
compensation,
Social dialogue,
Freedom of
Impact related to the
commitment of suppliers and
business partners to respect the
ethical principles and working
conditions that apply in the Bank
Millennium Group
Actual (within the timeframe
corresponding to the reporting
period) positive impact in the
upstream value chain
Not identified
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Area
ESRS
Thematic
unit
Sub-theme
Impacts
Risks
Description
Classification
Description
Classification
association,
including the
existence of
works councils,
Collective
bargaining, Work-
life balance,
Occupational
health and safety
Impact related to the
commitment of suppliers and
business partners to respect the
ethical principles and working
conditions that apply in the Bank
Millennium Group
Actual (within the timeframe
corresponding to the reporting
period) positive impact in the
downstream value chain
S4
Consumers
and end-
users
Information-
related
impacts on
consumers or
end-users
Access to (high-
quality)
information
Impact resulting from taking
numerous actions to ensure that
customers have access to reliable
information about product
offerings across all sales channels
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Risks arising from
increasing consumer
protection
Risks in own
operations across all
timeframes
Impact on retail customers due
to potential under-information of
customers
Potential negative impact in
own operations across all
timeframes
Privacy
Impact resulting from measures
to ensure privacy and
confidentiality and security of
customer data as well as
processes for handling data
breaches and ensuring
transparent information about
data breaches
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Not identified
Impact resulting from exposure
to potential leaks of personal
data and bank secrecy, including
as a result of a cyber attack
Potential negative impact in
own operations across all
timeframes
Social
inclusion of
consumers or
end-users
Responsible
marketing
practices
Impact related to providing clear
and understandable information
about the Bank’s products and
services
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Non-
discrimination
Impact related to ensuring
inclusiveness of products and
services.
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
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Area
ESRS
Thematic
unit
Sub-theme
Impacts
Risks
Description
Classification
Description
Classification
Corporate governance
G1 Conduct
of business
Corporate
culture
-
Impact resulting from the
principles of corporate culture
implemented in our policies,
procedures, rules and
regulations, and embedded in all
processes within the Group
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Not identified
Whistleblower
protection
-
Impact related to the
whistleblower protection
procedures in place and the
anonymous channel for reporting
violations
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Corruption
and bribery
-
Impact related to anti-corruption
measures taken
Actual (within the timeframe
corresponding to the reporting
period) positive impact in own
operations
Impact on our suppliers resulting
from their commitment to
comply with the Bank Millennium
Group’s anti-corruption policy.
Actual (within the timeframe
corresponding to the reporting
period) positive impact in the
upstream value chain
Moreover, in the course of our analysis, we have identified additional material impacts and risks specific to the Bank Millennium Group. We have not
identified any material opportunities.
Identified (sector-specific) impacts and risks
Area
Thematic unit
Sub-theme
Impacts
Risks
Description
Classification
Description
Classification
Sector
-specific
Theme specific to the Bank
Millennium Group:
S4 Impacts on consumers or end users
related to the safety of deposited
funds
Impact related to the security
exposure of deposited funds due to
cyber attacks
Potential negative impact
in own operations across all
timeframes
Risk of data leakage, loss of trust
and financial losses due to cyber
attacks
Risks in own operations
across all timeframes
Impact resulting from cybersecurity
measures taken
Actual (within the
timeframe corresponding to
the reporting period)
positive impact in own
operations
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[SBM-3] In light of the limited availability of data and quantitative applicable criteria, the assessment
of the current financial effects from material risks and opportunities in 2024 has been carried out in
an expert-like manner, based on qualitative criteria.
Corporate and retail customer financing provided in the form of loans, advances or leases forms the
basis of our business model. This business is primarily funded through deposits from customers
accepted by Bank Millennium. As such, the Bank recognises that to understand the resilience of the
Bank’s business model to climate risk it is critical to determine the materiality of the impact of
climate risk on the Bank’s credit and liquidity risk profile.
In 2024, the Bank Millennium Group conducted a comprehensive materiality assessment of the impact
of climate and environmental risks on the Bank’s traditional risks, that is credit, operational, market,
liquidity, strategic, reputational and economic risks. The conclusions of this assessment will be used
as a background to a full-scale resilience analysis which will be the part of the Transition Plan.
The impact of climate risk on credit risk:
The materiality assessment covered the following portfolios:
Portfolio of financing provided to companies (corporations and small business):
● Transition risk assessment: As part of the materiality assessment, the Bank has conducted a
review of its portfolio in terms of emission intensity. This analysis has demonstrated that the
Bank has a low exposure to industries exposed to medium or high transition risk
(approximately 5% of the Bank’s total loan portfolio). The Bank Millennium Group refrains
from financing new coal mines and coal-fired power generation projects, except for new
projects related to pollution reduction. New financing in the energy sector is only possible if
it serves the commitment to non-carbon based energy sources and the energy transition to
non-carbon based energy sources. Actions in this area reflect the stated strategy to integrate
climate risk into the Bank Millennium Group’s risk management policies as well as to promote
innovation and the transition to a low-carbon economy.
● Physical risk assessment: the Bank has no concentration of exposures in sectors typically
characterised by higher exposure to physical risks related to climate change (such as
agriculture). In addition, based on its analysis of climate risk maps for Poland (Klimada 2.0
database), the Bank concludes that it has a negligible volume of exposures in regions with
elevated physical risk (about 1% of the Bank's total credit portfolio).
Portfolio of consumer mortgage loans:
● Transition risk assessment: based on its estimates, the Bank currently has a marginal
exposure to loans financing properties that fall into the two lowest/worst energy efficiency
classes. The Bank monitors on an ongoing basis legislative changes regarding the introduction
of criteria for specific classes of energy efficiency in Poland and the development of the
regulatory environment in terms of possible restrictions on the possibility of selling/renting
energy inefficient properties.
● Physical risk assessment: the Bank’s portfolio is dispersed and geographically diversified
across Poland. The Bank does not have a concentration of financed properties in areas with
higher physical risk. Geographic diversity provides greater resilience to physical risks
associated with climate change, such as flooding or inundations. The regulations implemented
by the Bank are designed to minimize the Bank's exposure to potential damage and loss, while
enhancing operational and financial stability.
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Portfolio of (unsecured) consumer loans extended to consumers:
● Transition risk assessment: as estimated by the Bank, it does not identify in its portfolio a
concentration of exposures related to sectors significantly exposed to transition risk.
● Physical risk assessment: the Bank’s portfolio is dispersed and geographically diversified
across Poland, and as a result there is no concentration of financing for consumers residing in
regions with higher physical risk.
The impact of climate risk on liquidity risk:
● Transition risk assessment: the Bank has implemented and applies concentration limits on
deposits accepted from individual businesses as part of its risk management strategy, thereby
minimising the potential risk of over-reliance on financing from single large depositors,
thereby enhancing the Bank’s financial stability. As part of its analysis of the materiality of
transition risk in liquidity risk, the Bank has reviewed the twenty largest corporate depositors
– none of the companies operate within emission intensive sectors and therefore higher
exposure to transition risk.
● Physical risk assessment: The dispersed geographical distribution of depositors across Poland
(both corporates and consumers, whose deposits account for the majority of the Bank’s
financing) means lack of concentration in locations with higher physical risk. The Bank does
not currently identify a material risk of deterioration in the Bank's liquidity due to physical
risk.
The Bank intends to implement a methodology and process for conducting climate stress tests, which
will provide a complementary and more sophisticated quantitative approach to assessing the
resilience of the Bank’s business model to climate change under pre-set climate change scenarios and
time horizons.
Assessment of social and governance impacts and risks:
The Bank believes that its strategy and business model are resilient to negative impacts. Details of
the measures building our resilience are described in the sections below:
• 17.6 Health and safety of employees
• 19.4 Safety of deposited funds
• 19.5 Privacy
• 19.6 Access to (high-quality) information
The Group, in the first year of preparation of the statement, uses the exemption provided by Appendix
C of ESRS 1 and does not present disclosures on the anticipated financial effects from material physical
and transition risks and potential climate-related opportunities (ESRS disclosure requirement E1-9).
Due to the first year of preparing the statement in accordance with the applicable European
Sustainability Reporting Standards (ESRS), the Group does not disclose an indicator on the change in
material impacts, risks and opportunities compared to the previous reporting period.
Materiality of impact
[IRO-1] The identified impacts have been classified by their nature, as positive or negative, and type,
as actual or potential. Following our internal methodology for assessing the materiality of impacts,
based on the European Sustainability Reporting Standards, we then assessed each identified impact
against a set of qualitative criteria. The assessment was based on expert judgement and included
components such as the scale of the impact and its scope, the likelihood for potential impacts, and
irremediability . A summary of the assessment components used is presented below:
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Summary of assessment components
Type of impact
Scale
Scope
Irremediability
Likelihood
Negative actual
+
+
+
Negative potential
+
+
+
+
Positive actual
+
+
Positive potential
+
+
+
The assessment is based on a 5-point scale in which the maximum number of points corresponds to
the greatest strength of impact. The criteria adopted for awarding the sub-assessments are based on
the following assumptions:
● the scale for environmental impacts reflects the degree of exposure of the environment,
people and organisms (from imperceptible to catastrophic/very positive), while for social
impacts and internal governance, the degree of impact on human health or quality of life or
internal governance;
● the scope of environmental impacts is linked to the size of the geographical area (global or
local impact) and, for social impacts and internal governance, to the size of the affected
population (number of social groups affected and percentage of the population within these
groups);
● the irremediability of the negative impact, that is the lack of possibility of restoring the
baseline given the necessary efforts, resources and time horizon;
● the likelihood of potential environmental, social and internal governance impacts.
Particular attention has also been paid to verifying whether the impact assessed is related to human
rights. Where a potential negative impact on human rights has been identified, an assessment of the
severity of the impact takes precedence over its likelihood.
In order to determine which impacts are material to the Bank Millennium Group’s operations, based
on the rating scale adopted, we have selected a cut-off point below which we considered our impacts
to be immaterial. This threshold was set based on expert judgement so that the percentage of
material impacts among all identified impacts would allow for transparency and relevance of
disclosures to the audience.
The process of identifying, assessing, prioritising and monitoring the potential and actual impacts of
the Bank Millennium Group on people and the environment has been carried out based on the due
diligence process set out in the international instruments of the UN Guiding Principles on Business and
Human Rights and the OECD Guidelines for Multinational Enterprises.
Financial materiality
As part of the financial materiality assessment process, we have analysed the Bank Millennium Group’s
dependencies on natural, human and social resources, which may act both a source of financial risks
or opportunities. The analysis has covered both:
• matters under our control (in line with the adopted consolidation), related to our own
operations and arising mainly from the identified impacts and the Strategy of the Bank
Millennium Group,
• matters arising from our business relationships.
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The starting point of the assessment is a list of identified environmental and social impacts of the
Bank Millennium Group, which we have analysed for possible links and dependencies with the risks
and opportunities that may arise from these impacts.
The assessment of financial materiality includes a scale of financial impacts and probability (from
1 to 5, similarly to impacts), where the maximum number of points corresponds to the highest scale
and the highest probability of occurrence. The sub-assessments of risks and opportunities in 2024 have
been based on qualitative criteria, due to the limited availability of quantitative criteria that might
be applied. From a financial perspective, we have considered sustainability matters that cause, or
may reasonably be expected to cause material financial effects due to their influence on our Group’s
development, financial position, financial performance, cash flows, access to finance or cost of
capital in the short, medium or long term. As with the impact assessment, in order to identify risks
and opportunities that are material to the operations of the Bank Millennium Group, we have set
a quantitative cut-off point below which we consider a risk or opportunity to be immaterial. The
threshold has been determined based on expert judgement with a view to maintaining transparency
and relevance of disclosures to the audience.
An important role in the materiality assessment process has been played by the Bank Millennium Risk
Department, which is responsible for managing the traditional risks identified in the operations of the
Bank Millennium Group, that is credit, concentration, market, liquidity, operational (including
reputational) and strategic risks. In accordance with supervisory guidelines, environmental and social
issues are taken into account as factors affecting the level of traditional risk categories. For this
purpose, the Risk Department has established a process for periodically assessing the materiality of
the impact of environmental and social risk factors and has developed a methodology for climate and
environmental risk materiality assessment. For material climate and environmental risks Bank
Millennium identifies their transmission channels to traditional banking risks. At present, the Bank
considers that the implementation of detailed solutions to identify, measure, control and report ESG
risks is relevant for credit and liquidity risk. The Bank has also started developing climate scenario
analysis and coordinating this analysis with the overall internal stress testing framework.
The Bank Millennium Group also recognises business potential related to sustainability, primarily
related to financing the transition to a low-carbon and climate-resilient economy, as outlined in
section 16. Climate change (ESRS E1) of this statement.
Climate-related impacts, risks and opportunities – identification and assessment
[E1 IRO-1] The Bank has identified and assessed climate-related impacts, risks and opportunities in
accordance with the adopted methodology outlined above and taking into account the current level
of greenhouse gas emissions from our own operations (scope 1 and 2) and value chain (scope 3), with
a particular focus on our loan portfolio and lease activities. Information on GHG emissions for all
relevant scopes and categories is presented in sections 16.3.1 Climate-related targets and
16.3.3. Gross Scopes 1, 2, 3 and Total GHG emissions. We have also included in the analysis planned
activities – both those that may act as a source of new GHG emissions and those related to their
reduction for the planned achievement of climate neutrality from all Group operations (Scopes 1-3)
by 2050, a list of which will be expanded as a result of the development of the Transition Plan.
Potential future greenhouse gas emissions in the Bank Millennium Group will come from new financing.
Physical risk
Climate-related physical risks result from climate change, can be event-driven (acute) or from longer-
term shifts (chronic) in climate patterns.
Acute physical risks arise from particular hazards, especially weather-related events such as storms,
floods, fires or heatwaves. Chronic physical risks arise from longer-term changes in the climate, such
as temperature changes, and their effects on rising sea levels, reduced water availability, biodiversity
loss and changes in land and soil productivity.
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Bearing in mind that the Group’s financial activities relate to Poland, from the broad list of physical
risk factors defined in the EU Taxonomy (in Appendix A of the Delegated Climate Regulation, which
defines the technical criteria for considering an activity as environmentally sustainable), we have
selected for analysis the physical risk factors relevant to the geographical scope of our financial
activities based on the Intergovernmental Panel on Climate Change (IPCC) study, in the short, medium
and long term. The factors relevant to the region in which we conduct our financial activities are:
• floods / inundations,
• droughts / water stress,
• heat waves.
The Group’s assets and business activities exposed to physical risks include the loan portfolio to the
extent that it finances physical assets. Due to the nature of the Bank Millennium Group’s business,
which covers the whole country and a broad cross-section of business sectors, the analysis of climate
risk has been performed on a geographical basis for physical risk (at postal code level) and at PKD
code level of the main corporate customer business.
For the identification and assessment of physical risks, the climate scenarios defined in the most
recent IPCC report (the latest version of the report from March 2023) have been used:
• RCP 8.5 (SSP5-8.5) – the scenario assumes very high greenhouse gas emissions and an increase
in the Earth’s average temperature by more than 4°C relative to the pre-industrial era,
leading to increased materialisation of physical climate risks.
• RCP 4.5 (SSP2-4.5) – the scenario assumes a relatively ambitious reduction in greenhouse gas
emissions with an initial small increase until around 2040, followed by a 50% reduction in
global emissions by 2080. This scenario is broadly consistent with the GHG emissions profile
that will result from the implementation of the 2030 Sustainable Development Goals and will
keep temperature increases below 3°C relative to the pre-industrial era (but will not meet
the 2°C cap agreed under the Paris Agreement).
The above scenarios refer to the following time horizons:
1. short and medium term – 2021-2030 horizon,
2. long-term – 2041-2050 horizon.
We have not identified any material physical risks in relation to our own operations or within our
value chain, particularly at downstream, covering our business and retail customers (mortgage and
consumer loans).
For the 2024 financial reporting, quantitative data calculated or estimated using climate scenarios
have not been used. The analyses for 2024 are qualitative in nature.
Transition risk
Transition risks arise from the transition to a low-carbon and climate-resilient economy. They typically include policy risks,
legal risks, technology risks, market risk sand reputational risks. For the Bank Millennium Group, we have recognised
the following factors/events related to the downstream value chain (loan portfolio) and own operations – assessed in the short,
medium and long term:
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Scope of transition factors
Categories of transition
risk factors
Climate-related transition events
Political and legal
Introducing regulations on:
• reducing greenhouse gas emissions, mandatory purchase
of greenhouse gas emission allowances,
• carbon footprint tax mechanisms, banning the production
of certain goods (e.g., combustion cars).
Technological
• Technological changes related to energy efficiency, low-carbon
transportation and increasing use of non-fossil fuels or other
technologies,
• Existing business models of companies may rely on technologies
that may be replaced or on the use of energy sources that may
become more expensive as a result of policy actions (whether
through higher efficiency standards or the introduction of
carbon taxes).
Market-based
• Investor preferences and changing expectations with regard to
climate change, which require climate risk issues to be taken
into account,
• Consumer preferences changing towards more climate-friendly
consumption. For this reason, retail customers may expect their
savings or investments to go toward climate-friendly causes.
Increased awareness and clear demand for climate-friendly
financial products and investments provide a potential
incentive for companies and banks to adjust their business
strategies, regardless of potential regulatory or supervisory
approaches.
Reputation-related
Unfavourable perception of financing for energy-intensive or
carbon-intensive (CO
2
) sectors.
The analysis carried out considers the climate scenarios developed by The Network for Greening the
Financial System (NGFS):
• Net Zero 2050 – the scenario assumes curbing the increase in the Earth’s average temperature
to 1.5°C relative to the pre-industrial era by strengthening policies and introducing
innovations to achieve net zero CO
2
emissions in 2050. The scenario assumes that climate
policies will be swiftly implemented and there will be rapid technological change to support
the transition.
• Current Policies – the most pessimistic climate scenario assuming a continuation of the current
rate of growth of greenhouse gas emissions (“business as usual”) and an increase in the Earth’s
average temperature by 2.9°C relative to the pre-industrial era, leading to an increased
materialisation of physical climate risks. The scenario assumes that only current climate
policies will be implemented (climate policy ambitions will not be increased) and that
technological change to support the transition will take place slowly.
• Delayed transition – the scenario assumes that global annual emissions will not decrease until
2030 due as no new climate policies will be introduced until that year. It is therefore only
after 2030 that a reduction in temperature increase below 2°C relative to the pre-industrial
era may be expected. The scenario assumes that climate policies will be implemented with
a delay, while technological changes supporting the transition will occur at a varying pace,
depending on the region.
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The above transition risk scenarios refer to the following time horizons and their endpoints:
1. short-term – reporting period (1 year) – 2025.
2. medium-term – up to 5 years – 2030
3. long-term – more than 5 years – 2040.
The findings from the transition risk assessment have been used in our double materiality analysis. As
material transition risks we assessed the impact of the transition to a climate-neutral economy on
customers in the corporate portfolio (including SMEs) from energy-intensive or carbon-intensive
sectors, including:
• insolvency risk – increased risk of insolvency if changes in regulation, the market or customer
preferences affect the ability to and/or way of conducting business,
• collateral risk – collateral may be devalued if it is linked to industries susceptible to transition
risk,
• liquidity risk – sudden changes in legislation or the market may lead to increased liquidity
needs and the ability to meet debt obligations.
Scale of financial impact: Sectors with high exposure to transition risk (such as energy production,
automotive, land and air transport, cement, lime and gypsum production, metal production, rubber
and plastic products and chemicals) account for around 24% of our corporate portfolio. According to
estimates by the European Central Bank (2023), the transition to climate neutrality will reduce the
profitability of EU companies by an average of 2 to 3 percentage points, and double that for energy-
intensive sectors. Debt will also go up (with a leverage ratio increased by 3-4 percentage points, with
up to 3 to 4 times more for energy-intensive sectors). The Bank Millennium Group is not significantly
exposed to oil and gas mining, service activities supporting this sector or to the production and
processing of oil and gas mining products. Financing for these activities represents 0.2% of the
corporate portfolio and less than 0.1% of the total portfolio.
Likelihood: Energy-intensive and CO
2
e-intensive sectors are facing tighter regulations to reduce
carbon emissions. It is assumed that regulations will become more stringent over time to meet EU and
Polish decarbonisation targets. Most targets are set for 2030 and 2040. We estimate that these risks
may materialise in the medium to long term.
Time horizon: Medium and long-term horizon.
• The risk of having to reduce the customer base and, as a consequence, a decline in
profitability resulting from the withdrawal of financing from customers in carbon-intensive
sectors.
Scale of financial impact: The Bank Millennium Group’s exposure to corporate customers operating in
the coal and mining sectors is already very low, and the Bank Millennium Group has implemented
a strict policy on new financing for these sectors. This notwithstanding, the expected increase in
materiality of the impact of transition risk factors may potentially result in the need to reduce
financing for customers failing to take transition actions, especially in high-emission sectors (mainly
power generation, CRE, cement, steel and aluminium, transport, manufacturing), which may affect
the revenues and consequently the profitability of the Bank Millennium Group.
Likelihood: Increasing pressure from the Bank Millennium Group’s stakeholders and the adoption of
the Transition Plan including reduction targets for financed emissions, might reduce some revenues
in the absence of appropriate actions to transform the financing offer. We estimate that this risk may
only materialise in the long term.
Time horizon: Medium and long-term horizon.
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Climate-related changes may also bring business potential, especially in the context of developing
a portfolio of financial assets that support the green transition of the economy and sustainable
development. In our double materiality analysis, we have not identified any material climate change-
related opportunities for our business (above the adopted materiality threshold).
The Group is in the process of identifying assets where the transition to a climate-neutral economy
has not been taken into account or where significant efforts are required to take this into account
(for example, due to significant locked-in greenhouse gas emissions or failure to meet Taxonomy-
aligned compliance requirements under Commission Delegated Regulation (EU) 2021/2139).
15.4.4. LIST OF REQUIREMENTS
[IRO-2] For a list of disclosure requirements fulfilled in the preparation of the sustainability statement
following a materiality assessment, see section 22. Attachments.
A list of the data points contained in the cross-cutting standards and thematic standards that derive
from other EU legislation is presented in section 22. Attachments.
The starting point for determining the scope of information disclosed within the sustainability
statement is the assessment of impact materiality and financial materiality. Sustainability matters
are considered “material” if they meet the double materiality principle, that is the criteria defined
for either impact materiality or financial materiality, or both. Irrespective of the outcome of the
materiality assessment, the scope of the statement also includes all the information and data points
required under ESRS 2 General disclosures and as set out in the thematic ESRSs related to the
disclosure requirement IRO-1 Description of the process to identify and assess material impacts, risks
and opportunities (including in their data points).
For the purpose of determining which detailed data points require disclosure, the Sustainability
Reporting Standards and EFRAG Implementation Guidance 3: Detailed ESRS Datapoints have been
relied upon.
In addition to the application of the disclosure requirements defined for the environmental, social
and governance areas for disclosures related to impacts, risks and opportunities specific to the Bank
Millennium Group, guidance has been applied for disclosures not covered or insufficiently detailed by
the ESRS standards.
Due to the qualitative nature of the disclosures, no materiality threshold has been applied at the
stage of selecting material information requiring disclosure in relation to impacts, risks and
opportunities considered material by the Bank during the double materiality analysis. The exception
is the estimation of carbon dioxide and other greenhouse gas emissions, as detailed in section 16.3.3.
Gross Scopes 1, 2, 3 and Total GHG emissions.
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16. CLIMATE CHANGE (ESRS E1)
In this chapter, the Bank Millennium Group discloses information about the sub-topic “Climate Change
Mitigation”, which was identified during the double materiality analysis. The other sub-topics of the
environmental area have not been assessed as material.
[E1 GOV-3] Disclosure regarding Integration of sustainability-related performance in incentive
schemes. is described in chapter 15.3.2 Integration of sustainability-related performance in incentive
schemes.
16.1. STRATEGY
[E1 SBM-3] The sub-topic “Climate change mitigation” is recognized as material based on an
assessment of identified impacts, risks and opportunities, the following of which are considered to be
material:
1. Risk associated with the portfolio of corporate loans resulting from financing customers from
high-emission sectors and related to potential objectives for reducing emissions in Scope 3,
category 15 – climate-related transition risk;
2. Risk associated with corporate customers’ transition towards low-carbon economy – climate-
related transition risk.
In Q4 2024, the Bank Millennium Group, with regard to the key element of the value chain, which is
the credit portfolio, conducted a comprehensive analysis, as required by prudential regulations, of
materiality of the impact of climate risk on traditional banking risks, i.e. credit, operational, market,
liquidity, strategic, reputational and economic risks. The analysis did not cover own operations and
other elements of the value chain than the credit portfolio. The analysis was based on internally
prepared methodology for assessment of the materiality of climate and environmental risks (updated
in 2024 to take into account the regulatory guidelines). The analysis easures the exposure of the
Bank’s portfolio and traditional risk categories to climate and environmental risk factors, including
climate-related transition risk and climate-related physical risk. No material physical risks and
transition risks were excluded from the analysis. The sensitivity analysis was carried out for various
climate scenarios and time horizons correlated with periods of preparing strategic plans by the Bank
Millennium Group. In particular, for the needs of materiality assessment of the climate-related
transition risk, climate scenarios were used recommended by the Network for Greening the Financial
System, i.e. Net Zero 2050, Current Policies, Delayed Transition. The scenarios define critical
assumptions about how the transition to a low-emission and sustainable economy will impact the
prevailing macro-economic trends, consumption of energy and energy mix as well as assumptions for
using technologies. Due to limited availability of data and quantitative applicable criteria, the
assessment of the anticipated financial effects from material physical risks and transition risks was
based on expert judgement and qualitative criteria.
Detailed results of materiality assessment of the impact of climate and environmental risks on the
Bank’s traditional risks can be found in chapter 15.4.3. Identified impacts, risks and opportunities,
and the GHG reduction targets can be found in chapter 16.3.1. Climate-related targets.
As of 2024 the findings are qualitative in nature and constitute one of the factors taken into account
in updating the strategy and shaping our credit policy, which determines, among other things,
activities excluded from financing or subject to the system of limits. The assumptions and conclusions
of the materiality assessment will serve as a background for a comprehensive resilience analysis of
the Bank's strategy and business model to climate change with regard to the physical risk and the
transition risk.
In addition to the results of the climate and environmental materiality assessment, credit decisions
are also shaped by the exclusion policy. We identify areas of uncertainty related to the materiality
assessment, based on the data availability, and we expect improvement in the methodologies and
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risk maps in the future. Based on analysis conducted we have not identified a negative impact of
climate-related transition risk on our ability to correct the strategy and business model, access to
financing or the opportunity to change the product portfolio. We did not consider the time horizon in
terms of our ability to adjust or adapt our strategy and business model to climate change in the short,
medium and long term.
[E1-1] At present, the Bank Millennium Group is preparing to develop the Transition Plan for climate
change mitigation (Transition Plan). The document, including objectives for emissions reduction and
decarbonisation measures, is planned to be adopted by 2026.
16.2. MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES
Disclosure Requirement related to ESRS 2 IRO-1 – Description of the processes to identify and assess
material climate-related impacts, risks and opportunities – can be found in Chapter 15.4.3 Identified
impacts, risks and opportunities.
Policies related to climate change mitigation and adaptation
[E1-2] Environmental matters, apart from social and managerial issues, have an important role to
play in the management of the Bank Millennium Group, making up a significant part of our strategic
actions and a material element of our organizational culture.
Bank Millennium defined fundamental sustainability principles at the level of the entire Bank
Millennium Group in the policies related to climate change mitigation and adaptation adopted by the
Bank’s Management Board. The policies are generally available documents published on Bank
Millennium’s website and on the corporate site for employees and include:
• Policy on Sustainability Principles,
• Environmental Policy,
• Responsible Financing Policy,
• Supplier Sustainability Guidelines.
Responsibility for the implementation of the commitments resulting from the above policies is
allocated in accordance with the allocation of the responsibilities of individual organizational units
and their managers. The correctness of the implementation of the policies is supervised by the Bank
Millennium’s Management Board Members in accordance with the division of their powers.
Issues of climate change mitigation and adaptation are also taken into account of in the Bank’s
Strategy.
Strategy of Bank Millennium and the Bank Millennium Group
The basic initiatives in the environmental area are defined in the Strategy of Bank Millennium and the
Bank Millennium Group 2025-2028 Strategy 2028 – Value and Growth and include the implementation
of measures supporting the transition to an environmentally sustainable economy, which means,
among others, taking into consideration environmental factors in the risk management process at the
Bank and preparation of the offer of products and services as well as actions supporting
decarbonisation of our own business activities.
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Policy on Sustainability Principles
The policy refers to, among others, issues related to climate change mitigation and adaptation. In
accordance with its assumptions, promoting measures for climate change mitigation and adaptation,
protection of natural resources, biodiversity and the natural environment is an integral part of
a responsible business model of the Bank Millennium Group.
Based on the principles, best practices and the UN’s Sustainable Development Goals, in the Policy for
sustainability principles, we have committed ourselves to:
• include environmental risks (physical risk and transition risk) and social risks to the risk
assessment process,
• define a list of sectors and business activities not financed by the Bank Millennium Group,
• create sustainable solutions – financing environmentally-friendly and energy-saving projects,
• stimulate sustainable growth and achievement of environmental goals,
• take measures aimed to reduce our own carbon footprint,
• develop sustainability-related competences,
• promote a responsible consumption culture.
The policy is made available to the Group’s employees on the intranet site and to customers and
external entities on Bank Millennium’s website.
We have also undertaken to ensure the right sustainability management process at Bank Millennium
S.A., setting up a Sustainability Committee and the Sustainability Department, responsible, among
other things, for issues of environmental protection (including climate-related ones).
Environmental Policy
The policy supplements the Group’s Code of Ethics, strategies and business policies as well as the
sustainability policy, in which the Group undertakes to be responsible for environmental protection,
management and monitoring of adverse impact, both direct and indirect, of its own activity, products
and services, by adding, among other issues, those related to climate change mitigation and
adaptation.
The Environmental policy includes the fundamental principles of the Group’s own pro-ecological
measures, development of pro-ecological products and responsible financing as well as undertaking
to provide ecological education, covering promotion of the culture of environmental responsibility
and counteracting climate change.
Responsible Financing Policy
The responsible financing policy refers to offering by the Bank Millennium Group sustainable financial
products and conducting a responsible credit policy.
The document defines both exclusions and limitations in view of the assumed obligations regarding
promotion of sustainability and counteracting climate change, which the Bank takes into consideration
when making a decision to grant financing or engage in a project or an investment transaction on its
own account.
In the Policy, we declare that we do not finance projects or perform investment transactions on our
own account for, among others:
• Extraction of petroleum and coal mining
• Coal-based energy production.
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Also, in accordance with the Supplier Sustainability Guidelines approved by the Bank’s Management
Board Member the Bank Millennium Group encourages its business partners (upstream of the value
chain) to, among others, responsibility for the environment, using of innovative and clean
technologies and reducing the consumption of natural resources.
Climate change mitigation actions which have been taken
[E1-3] Matters related to climate change for years are an integral part of the Bank Millennium Group’s
business strategy. In the Strategy of the Bank and the Bank Millennium Group for years 2025-2028
Strategy 2028 – Value and Growth adopted and published in 2024, we have planned actions for climate
change mitigation. The table below presents climate-friendly measures taken in 2024 by the Bank
Millennium Group.
Climate change mitigation actions taken in 2024
Measure
Scope
Description
Purchase of energy
from renewable
sources
Action referring
to the natural
environment as a
stakeholder
covered by the
action, taken
within the Bank
Millennium
Group’s own
operations.
● 100% of electrical energy purchased by the
Bank Millennium Group comes from renewable
sources, to which zero GHG emissions rate may
be attributed.
Energy efficient
buildings of the
Bank’s head office
in Warsaw, Wrocław
and Gdańsk
Action referring
to the natural
environment as a
stakeholder
covered by the
action, taken
within the Bank
Millennium
Group’s own
operations.
● The Warsaw head office buildings have the
BREEAM certificate, the ones in Wrocław were
awarded the LEED GOLD certificate. The
modernized building in Gdańsk at Al.
Grunwaldzka 19/23 received the LEED GOLD
certificate.
● At the Bank’s head offices located in Warsaw
and Wrocław, smart building management
systems (BMS) are installed, which support our
efforts to optimize the consumption of
utilities.
● In 2024, due to the photovoltaic system
installed in 2023, 22.64 MWh of electrical
energy was produced.
● Our entire head office space is equipped with
LED lighting; we replaced nearly 14,000
fixtures (the total number for the head office
buildings in Gdańsk, Warsaw and Wrocław)
using the old fluorescent technology with
modern LED lighting, thereby reducing lighting
energy consumption by 54%.
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Measure
Scope
Description
Reduction of the
operating time of
technical
equipment
Action referring
to the natural
environment as a
stakeholder
covered by the
action taken
within the Bank
Millennium
Group’s own
operations.
● In 2024, the optimization of the operating time
of the installations in the buildings progressed.
To this effect, the settings and technical
parameters of various devices, for example,
operating time of office lighting, operating
time of ventilation and air conditioning and
temperature settings in individual areas, were
changed. These optimizations have helped
minimize electricity consumption at the Bank's
head offices.
Energy savings in
branches
Action referring
to the natural
environment as a
stakeholder
covered by the
action, taken
within the Bank
Millennium
Group’s own
operations.
● In all the branches, we use energy-saving LED
advertising banners.
● Time control of advertising banner lighting
using astronomical clocks.
● We have consistently increased the number of
branches with LED lighting. At the end of 2024,
210 branches used LED lighting. LED lighting is
standard in all modernized Corporate Centres.
● All the outlets have restricted air conditioning
operation by installing timers to regulate the
running time of air conditioning units.
Rational
management of
energy consumption
Action referring
to the natural
environment as a
stakeholder
covered by the
action, taken
within the Bank
Millennium
Group’s own
operations.
● 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.
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Measure
Scope
Description
Utility consumption
control
Action referring
to the natural
environment as a
stakeholder
covered by the
action, taken
within the Bank
Millennium
Group’s own
operations.
● Performed 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. In 2024, the education
campaign for network employees regarding
social spaces was continued – in all locations
that have not yet been equipped with light
sensors and air conditioning. The campaign
encouraged employees to consume electricity
rationally.
Infrastructure and
activities supporting
ESG objectives
Action referring
to the natural
environment and
own employees
as stakeholders
covered by the
action, taken
within the Bank
Millennium
Group’s own
operations.
• In order to promote measures reducing CO
2
emissions, the Bank encourages employees to
ride bicycles instead of using public transport
and cars. In each location of the Bank’s head
office, the Bank has built parking spots for
cyclists and sanitary facilities.
• By installing a parcel machine at the Warsaw
head office, the Bank promotes the reduction
of CO
2
emissions, because employees no longer
have to drive to get parcels. A single parcel
machine reduces CO
2
emissions by almost
14,000 kg.
• The Bank Millennium Group organizes an
employee volunteerism program Our
People’24: Save the Planet. Cash collected in
the project have been earmarked for various
kinds of ecological initiatives.
Hybrid vehicles
Action referring to
the natural
environment as a
stakeholder covered
by the action, taken
within the Bank
Millennium Group’s
own operations.
• Gasoline combustion cars in the Bank’s fleet
have been replaced with new hybrid vehicles,
which translated into even greater reductions
in exhaust emissions into the environment. The
percentage of plug-in hybrid or fully electric
vehicles is gradually increased.
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Measure
Scope
Description
Limiting the amount
of business travel
Action referring to
the natural
environment as a
stakeholder covered
by the action, taken
within the Bank
Millennium Group’s
own operations.
• In order to minimize business travel, limits are
used for respective types of transportation (air
travel is limited and the low-carbon railway is
recommended, as shown by the increased
number of railway kilometres travelled) and
remote communication methods are used, such
as: e-learning courses, tele- and
videoconferencing.
Planned climate change mitigation actions
Measure
Scope
Description
Reduction of the
carbon footprint
Action referring to
the natural
environment and
corporate and retail
banking customers
as stakeholders
covered by the
action, taken within
the Bank Millennium
Group’s own
operations and in
the credit portfolio
(a lower level value
chain).
• Further initiatives for energy and water
efficiency in the branches (medium-term
horizon).
• Increase in the share of low-emission
vehicles (medium-term horizon).
• Maintenance of 100% of electricity with
guarantees of origin (long-term horizon).
• Adoption of a climate-related Transition
Plan (including objectives and actions for
decarbonisation) up to 2026.
Sustainable
financing
Action referring to
the natural
environment and
corporate and retail
banking customers
as stakeholders
covered by the
action, taken within
the credit portfolio
and managed assets
(a lower level value
chain).
● Ensuring financing of sustainable transition
of companies (long-term horizon).
● Increasing awareness and expertise with
respect to public programs / green projects
(medium-term horizon).
● Continuation of the policy of no financing
for the coal sector and coal-based energy
(long-term horizon).
● Expanding the green retail offering and the
portfolio of sustainable assets in Millennium
TFI (long-term horizon).
● Continuation of initiatives increasing ESG
awareness of customers (medium-term and
long-term horizon).
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[E1-3] The Bank assesses that the currently taken and planned climate change mitigation actions do
not require significant monetary amounts. Actions aimed to grant sustainable financing do not require
incurring capital expenditures or considerable operational expenses and are a part of the Bank’s basic
business activity related to granting loans. A budget of PLN 5 billion is however planned to grant new
sustainable financing in 2025-2028.
Actions aimed to reduce own Scope 1 and 2 emissions (accounting for 0.15% of the Bank’s total
emissions) are also a part of operational activities related to the maintenance of buildings and
purchase of utilities.
The effects of the actions taken to date for climate change mitigation in the perspective of the
Strategy for 2022-2024 involved: reduction of Scope 2 GHG emission by 36% using the location-based
method and by 33% using the market-based method as compared to 2022. Expected effects of the
planned measures involve further reduction of emissions until the achievement of net zero emissions
in Scopes 1 and 2. With respect to Scope 3 emissions, it will be possible to quantify expected effects
after adopting the Group’s Transition Plan.
The capability to complete the actions included in the Strategy 2025-2028 is embedded in the context
of macroeconomic perspectives and assumptions for the situation of the banking sector in these
timeframes. In our Strategy, we have taken into consideration forecasts and risks specific for the
banking sector in Poland, which may affect the financial standing and thus the possibility of financing
the planned actions by the Group. The Group’s dependence on the availability of resources is limited.
16.3. METRICS AND TARGETS
16.3.1. CLIMATE-RELATED TARGETS
[E1-4] The Bank Millennium Group set simplified climate-related targets concerning reduction of
emission of greenhouse gases. In accordance with the adopted Strategy for 2025-2028, we aim to
achieve net zero emissions in 2050 both in our own operations (Scopes 1 and 2) and in our own value
chain (Scope 3). By 2030, we are planning to achieve climate neutrality in our direct operations
(Scopes 1 and 2) by reducing GHG emissions in conjunction with a possible use of compensation of
residual emissions.
The objectives concerning reductions are set by us taking into account the present volumes of
emissions in our operations (Scopes 1 and 2) and in business relations (selected categories from Scope
3). Organizational limits for reduction targets are coherent with those adopted for the calculation of
emission of greenhouse gases (more in Chapter 16.3.3 Gross Scopes 1, 2, 3 and total GHG emissions.
The adopted targets for reducing GHG emissions are absolute and progress in their achievement will
be measured in tonnes of CO
2
e.
The targets set in previous years do not meet some of the current requirements for GHG emission
reduction targets and do not take into account the value chain. The Group has not set targets meeting
the ESRS E1-4 requirements because it does not have a fully prepared Climate-related Transition Plan.
The update of the targets, including the inclusion of emissions consistent with the organizational
limits described below in the section on emissions, as well as expressing them in values that do not
include compensation for the residual emissions, will take place as part of the preparation of the
climate-related Transition Plan.
Specific GHG emission reduction targets for individual sectors will be set with the involvement of
relevant stakeholders at the stage of preparing the Transition Plan.
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16.3.2. ENERGY CONSUMPTION AND MIX
[E1-5] Consumption of energy from processes performed or managed by the Bank Millennium Group
are calculated with the use of the same organizational boundaries as for the calculation of Scopes 1
and 2 GHG emissions (disclosure E1-6).
Energy consumption from fuel combustion in stationary and mobile sources was calculated based on
physical fuel consumption data. The above consumption does not include the use of the Group’s
vehicles for private purposes.
Electricity consumption was calculated in about 70% of the locations based on physical data from the
energy supplier, and in 30% of the locations consumption was estimated based on expenses. The
electricity consumption by plug-in hybrid vehicles is calculated together with the electricity
consumption of the office building (internal charging) or is invoiced by the supplier of cards that allow
for charging at external stations. For the entire volume of electricity consumed in 2024 (at all outlets),
guarantees of origin have been purchased and redeemed, certified by the Polish Power Exchange
(Towarowa Giełda Energii) through Certificates provided by the energy supplier for Bank Millennium
and Millennium Leasing. Accordingly, using the market-based method, all of the electricity purchased
in 2024 was classified as coming from renewable sources. In addition, Bank Millennium has its own
photovoltaic system on the roofs of Bank Millennium Group’s buildings in Gdańsk. The energy
generated from the PV plant is consumed on-site for our own needs.
The calculation of heat consumption was based on physical data or was estimated based on expenses.
The Bank Millennium Group did not acquire steam, while the purchase of cooling was determined to
be immaterial in the calculation of energy consumption for 2024. No limitations to the estimation
methods used were identified.
The Group does not operate in sectors with a significant impact on the climate and does not consume
fuels as raw materials in its operations – all raw materials consumed are burned to produce energy.
Neither does it consume energy from nuclear sources. The consumption of self-generated renewable
energy by the Group refers only to energy produced without fuel. The Group does not offset energy
consumption even if the energy produced on site is sold to and used by a third party. Energy acquired
within organizational limits is not calculated as purchased or acquired energy. Steam, heat or waste
cooling from industrial processes are not extracted. The Group does not use hydrogen as an energy
source.
Energy consumption data has not been subjected to external attestation or validation by the third
party other than the assurance service provider.
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Energy consumption and mix in 2024
Energy consumption and mix of the Bank Millennium Group
Year 2024
1) Total consumption of energy from fossil fuels [MWh]
25,786.2
Share of fossil fuels in the total consumption of energy [%]
60.2
2) Consumption of purchased or acquired electricity and heat from
renewable sources [MWh]
17,022.0
3) Consumption of self-generated non-fuel renewable energy [MWh]
22.6
4) Total consumption of renewable and low-emission energy [MWh]
17,044.6
Share of renewable sources in the total consumption of energy [%]
39.8
Total energy consumption [MWh]
(calculated as the sum total of lines 1 and 4)
42,830.8
16.3.3. GROSS SCOPES 1, 2, 3 AND TOTAL GHG EMISSIONS
[E1-6] The Bank Millennium Group is presenting for the first time GHG emissions in accordance with
the ESRS standards. To this end, we have conducted an analysis of the materiality process of all Scope
3 categories, and as a result we present greenhouse gas emissions in this report in categories: 1 -
Purchased goods and services, 3 - Fuel and energy-related activities (not included in Scope 1 or Scope
2) - by location-based and market-based approach, 13 - Downstream leased assets and 15 -
Investments.
Below is presented information on the amount of GHG emissions in 2024 for Scope 1 and 2 and for the
above-mentioned Scope 3 categories assessed as material, as well as information on the calculation
methodology. Greenhouse gas emissions were reported separately for Bank Millennium S.A. (as the
entity responsible for most of the Group's emissions) and for all companies of the Bank Millennium
Group.
Carbon footprint
GHG emissions in tonnes of CO
2
equivalent for Bank Millennium in 2024
Scope of GHG emissions
Emissions [tCO
2
e] in 2024
Scope 1 GHG emissions
Total Scope 1 GHG emissions
2,218.09
Percentage of Scope 1 GHG emissions from regulated
emissions trading schemes
-
Scope 2 GHG emissions
Total location-based Scope 2 GHG emissions
14,035.57
Total market-based Scope 2 GHG emissions
5,187.61
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Scope of GHG emissions
Emissions [tCO
2
e] in 2024
Significant Scope 3 GHG emissions (material categories**)
Total indirect (Scope 3) GHG emissions (location-based)
4,972,496.48
Total indirect (Scope 3) GHG emissions (market-based)
4,969,570.24
Cat. 1 Purchased goods and services
44,694.19
Cat. 3 Fuel and energy-related activities (not included
in Scope 1 or Scope 2) (location-based)
4,080.84
Cat. 3 Fuel and energy-related activities (not included
in Scope 1 or Scope 2) (market-based)
1,154.60
Cat. 13 Downstream leased assets
0.00
Cat. 15 Investments, including:
4,923,721.45
Business loans – general purpose
1,566,237.09
Equity investments and corporate bonds
2,105.48
Project finance
0.00
Commercial real estate
21,022.44
Mortgages
439,091.12
Sovereign debt***
2,895,265.32
Total GHG emissions
Total GHG emissions (location-based)
4,988,750.14
Total GHG emissions (market-based)
4,976,975.94
*Bank Millennium does not conduct activities reported under the European Emissions Trading Scheme
(EU ETS).
** Scope 3 categories assessed as material in 2024 based on the materiality assessment process of the
Bank Millennium Group.
*** Sovereign debt emissions including land use, land use change and forestry (LULUCF). Emissions
excluding this sector amounted to 3,046,814.46 tCO
2
e.
GHG emissions in tonnes of CO
2
equivalent for the Bank Millennium Group in 2024
Scope of GHG emissions
Emissions [tCO
2
e] in 2024
Scope 1 GHG emissions
Total Scope 1 emissions
2,462.82
Percentage of Scope 1 emissions from regulated
emissions trading schemes
-
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Scope of GHG emissions
Emissions [tCO
2
e] in 2024
Scope 2 GHG emissions
Total location-based Scope 2 emissions
14,924.05
Total market-based Scope 2 emissions
5,395.96
Significant scope 3 GHG emissions (material categories**)
Total indirect (Scope 3) emissions (location-based)
6,101,114.67
Total indirect (Scope 3) emissions (market-based)
6,097,963.48
Cat. 1 Purchased goods and services
46,762.52
Cat. 3 Fuel and energy-related activities (not included
in Scope 1 or Scope 2) (location-based)
4,416.95
Cat. 3 Fuel and energy-related activities (not included
in Scope 1 or Scope 2) (market-based)
1,265.76
Cat. 13 Downstream leased assets
1,095,704.32
Cat. 15 Investments, including:
4,954,230.88
Business loans – general purpose
1,566,237.09
Equity investments and corporate bonds
2,105.48
Project finance
0.00
Commercial real estate
21,022.44
Mortgages***
469,600.55
Sovereign debt****
2,895,265.32
Total GHG emissions
Total GHG emissions (location-based)
6,118,501.54
Total GHG emissions (market-based)
6,105,822.26
* Entities of the Bank Millennium Group do not conduct activities reported under the European
Emissions Trading Scheme (EU ETS).
** Scope 3 categories assessed as material in 2024 based on the materiality assessment process of the
Bank Millennium Group.
*** 6% of emissions from this asset class are generated by the operations of Millennium Bank
Hipoteczny S.A.
**** Sovereign debt emissions including land use, land use change and forestry (LULUCF). Emissions
excluding this sector amounted to 3,046,814.46 tCO
2
e.
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GHG emission intensity in tonnes of CO
2
e per million PLN of net revenue for Bank Millennium
Scope of GHG emissions
Total GHG emissions / million PLN of net
revenue [tCO
2
e/million PLN] in 2024
Total GHG emissions (location-based) per net
revenue
510.82
Total GHG emissions (market-based) per net
revenue
509.61
The amount of net income (denominator) for Bank Millennium was determined using the table
below
Revenue item – standalone [million PLN]
01.01.2024-31.12.2024
Net revenues used to calculate GHG intensity:
Interest income and other of similar nature
8,658.94
Fee and commission income
917.83
Dividend income
38.74
Result on financial assets and liabilities held for trading
(6.57)
Result on non-trading financial assets mandatorily at fair value
through profit or loss
18.13
Result on exchange differences
(179.40)
Other operating income
318.50
Total
9,766.18
GHG emission intensity in tonnes of CO
2
e per million PLN of net revenue for the Bank Millennium
Group
Scope of GHG emissions
Total GHG emissions / million PLN of net
revenue [tCO
2
e/million PLN] in 2024
Total GHG emissions (location-based) per net
revenue
606.25
Total GHG emissions (market-based) per net
revenue
605.00
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and the Bank Millennium S.A. Group in 2024
The amount of net revenues (denominator) for the Bank Millennium Group was determined using the
table below:
Revenue item – consolidated [million PLN]
01.01.2024-31.12.2024
Net revenues used to calculate GHG intensity:
Interest income and other of similar nature
8,823.13
Fee and commission income
1,058.32
Dividend income
3.63
Result on financial assets and liabilities held for trading
(7.21)
Result on non-trading financial assets mandatorily at fair value
through profit or loss
19.13
Result on exchange differences
(178.87)
Other operating income
374.20
Total
10,092.33
Calculation methodology used
The calculations of Scope 1, 2 and 3 greenhouse gas emissions have been prepared in accordance with
the ESRS standards (Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing
Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability
reporting standards) and taking into account the principles, requirements and guidelines provided by
the GHG Protocol Corporate Standard (The Greenhouse Gas Protocol A Corporate Accounting and
Reporting Standard Revised Edition, GHG Protocol Scope 2 Guidance, GHG Protocol Corporate Value
Chain (Scope 3) Accounting and Reporting Standard). In addition, as the Bank Millennium Group
includes entities that are financial institutions, Scope 3 emissions for category 15 (Investments) are
disclosed, taking into account the requirements of the Standard developed by the Partnership for
Carbon Accounting Financials (PCAF): GHG Accounting and Reporting Standard for the Financial
Industry – part A "Financed issues" (version as of December 2022).
Sometimes the Group did not have enough data to estimate emissions in accordance with the adopted
methodology. In such cases, it was not decided to use metrics with a high level of measurement
uncertainty – the Group refrained from such estimates. In no case did this lead to an underestimation
of the level of estimated emissions.
Greenhouse gas emissions were calculated for all companies of the Bank Millennium Group, in
accordance with the organizational boundaries adopted in the financial statements for the year 2024,
excluding two companies in liquidation:
1. Piast Expert sp. z o.o. in liquidation.
2. Lubuskie Fabryki Mebli S.A. in liquidation.
These companies did not conduct any operating activities in 2024. The Group's organizational
boundaries for the purpose of calculating emissions were defined using the operational control
method.
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The companies included in the calculations of GHG emissions for the Bank Millennium Group are:
• Bank Millennium S.A.
• Millennium Consulting S.A.
• Millennium TFI S.A. (subsidiary of Millennium Consulting S.A.)
• Millennium Leasing sp. z o.o.
• Millennium Bank Hipoteczny S.A.
• Millennium Goodie sp. z o.o.
• Millennium Service sp. z o.o.
• Millennium Telecommunication Services sp. z o.o. (including 2% affiliated entity Millennium
Leasing S.A.).
The calculation methodology includes greenhouse gases in accordance with the GHG Protocol: carbon
dioxide (CO
2
), methane (CH4), nitrous oxide (N
2
O), sulphur hexafluoride (SF
6
), nitrogen trifluoride
(NF
3
) as well as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs).
The reference unit for the disclosed emissions is carbon dioxide equivalent (CO
2
e). Non-CO
2
emissions
were calculated by multiplying their amount by a GWP100 (100-year perspective) with a value
consistent with the latest data published in the IPCC (Intergovernmental Panel on Climate Change)
reports.
The scope of disclosed greenhouse gas emissions of the Bank Millennium Group and Bank Millennium
included, in accordance with the GHG Protocol:
• direct emissions from Scope 1 from the combustion of fuels in own or controlled energy
sources,
• Scope 2 indirect emissions from the production of purchased electricity and heat energy,
• all other indirect greenhouse gas emissions (not covered by Scope 2) in the value chain of the
Bank Millennium Group and Bank Millennium (Scope 3).
Scope 1 emissions were calculated using physical data on fuel consumption. Some of the source data
used for the calculations was estimated based on expenditures.
The calculations consider emissions from the stationary combustion sources (heating boilers using
natural gas and fuel oil), from mobile combustion sources (vehicles used by companies powered by
gasoline and diesel oil) and uncontrolled emissions resulting from leaks of refrigerants from air
conditioning equipment.
Combustion of fuels in stationary combustion sources:
Natural gas – physical data (in m³) on gas consumption were obtained or estimated, and the emission
factor from the DEFRA2024 database were used.
Heating oil – physical data on fuel oil consumption were obtained or estimated, and emission factor
from the DEFRA 2024 database were used.
Fuel combustion in mobile combustion sources:
Diesel oil, gasoline – physical data (in litres) on fuel consumption for business purposes were obtained
and emission factors from the Defra 2024 database were used. The calculated greenhouse gas
emissions do not include the use of the Group's vehicles for private purposes.
Fugitive emissions:
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Refrigerants - physical data (in kg) on refrigerant losses from equipment under the operational control
of the Bank Millennium Group were obtained and emission factors from the Defra 2024 database were
used. In the process of inventorying GHG emission streams, the area of the used fleet of vehicles
equipped with air conditioning was identified, however, taking into account the low GWP potential
of R1234yf and incidental leaks in air conditioning systems in vehicles used by the Bank Millennium
Group, this stream was not included in the emission calculations for 2024.
Biogenic emissions from the addition of biofuel to diesel and gasoline were calculated based on actual
fuel consumption, according to Scope 1 data. They are included as "out-of-scope" emissions. The Defra
2024 emission factor was used. For Bank Millennium, they amounted to 112.37 tCO
2
e, and for the
Bank Millennium Group, 126.23 tCO
2
e.
Scope 2 emissions were calculated with the use of physical data on electricity and heat consumption.
Some of the source data used for the calculations was estimated based on expenditures.
The calculations consider indirect emissions from purchased electricity and heat. The Bank Millennium
Group did not obtain steam, and the purchase of cold was identified as irrelevant in the emission
calculations for 2024.
The calculation of Scope 2 emissions was carried out using two required methodological approaches,
namely the location-based method (using the average emission factor for Poland) and the market-
based method (using emission factors specific to energy providers from which the reporting entity
makes contractual purchases of electricity in combination with contractual instruments such as
Guarantee of Origins or energy Renewable Energy Certificates).
Electricity - data on electricity consumption (in kWh) in about 70% of locations was obtained from
the energy supplier. In the remaining 30% of locations, electricity consumption is settled on the basis
of re-invoices calculated as a share in the rented space or the cost of electricity. A small number of
these facilities have an electricity submeter. Calculations of the value of annual electricity
consumption are based on cost and quantitative data (expressed in physical units). Source of emission
factors: for location-based – KOBIZE 2024; for market-based – emission factor provided by energy
supplier confirmed by Guarantees of Origin together with a document confirming their cancellation.
The electricity consumption of plug-in hybrid vehicles is calculated together with the electricity
consumption of the office building (internal charging) or is invoiced by the card provider that enables
charging at external charging stations.
For the entire volume of energy consumed in 2024 (in all branches), Guarantees of Origin were
purchased and redeemed, certified by the Towarowa Giełda Energii (the Polish Power Exchange)
through Certificates provided by the energy supplier to Bank Millennium and Millennium Leasing. As a
result, indirect emissions in Scope 2 (according to the market-based method) for electricity purchased
in 2024 amounted to zero tonnes of CO
2
e
.
In addition, Bank Millennium has its own photovoltaic system on the roofs of Bank Millennium Group
buildings located in Gdańsk. The energy generated from the PV installation is consumed on-site, for
our own needs, which results in a lower demand for purchased electricity.
Heat - calculations of the annual heat consumption value are based on quantitative data (expressed
in physical units). Some of the source data used for the calculations was estimated based on
expenditures. Source of emission factors: for location-based – URE 2022; for the market-based
method, the emission factor was not taken into account due to high dispersion and many heat
suppliers.
Biogenic carbon dioxide (CO
2
) emissions from the combustion or biodegradation of biomass for Scope
2 amounted to 1,551.53 tCO
2
e for Bank Millennium according to the location-based method and
1,018.10 tCO
2
e according to the market-based method. For the Group, these figures were 1,633.40
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tCO
2
e according to the location-based method and 1,058.99 tCO
2
e according to the market-based
method.
Scope 3 emissions are indirect emissions resulting from the Bank Millennium Group's operations, but
originating from sources not owned or controlled by the Group. They were calculated using physical
and cost data.
The GHG emission calculations were made for the relevant Scope 3 categories, selected based on a
materiality assessment process considering impacts, financial expenditures, transition risks,
opportunities and stakeholder opinions related to the upstream and downstream value chain, and
after considering any specific value chain requirements in other ESRSs.
The assessment of materiality was based on the method of estimating the impact of the Bank
Millennium Group's activities, and the criteria for each category were assessed using the expert
method. For most of the estimated GHG emission calculations (i.e. for categories 1 and 2, 5, 6), the
basis was financial data. Data from Exiobase 3 (data for Poland, marked "PL") were used as indicators
to convert financial data to greenhouse gas emissions, taking into account the exchange rate (the EUR
2024 exchange rate was PLN 4.3064
1
) and the inflation rate 2019-2024 (0.81
2
). Scope 3 categories: 4
(Upstream transportation and distribution), 9 (Downstream transportation and distribution), 10
(Processing of sold products), 12 (End-of-life treatment of sold products) – did not apply to the
operations of the Bank Millennium Group in 2024 and no estimated emissions calculations were made
for them.
Based on the materiality assessment process, the following Scope 3 categories were considered
relevant in 2024:
• Category 1 - Purchased goods and services (material in terms of financial expenditure; but
not material in terms of impact and transition risks; no opportunities and materiality or
immateriality in relation to stakeholder opinions were identified);
• Category 3 – Fuel- and energy-related activities not included in Scope 1 and 2 (material in
terms of financial expenditure, impact, transition risks and stakeholder opinions);
• Category 13 - Downstream leased assets (material for financial expenditures, impact,
transition risks and stakeholder opinions);
• Category 15 – Investment (material in terms of financial expenditure, impact, transition risks
and stakeholder opinions).
Scope 3 categories: 2 (Capital goods), 5 (Waste generated in operations), 6 (Business travel), 7
(Employee commuting), 8 (Upstream leased assets), 11 (Use of sold products), 14 (Franchises) were
considered immaterial based on the materiality analysis.
Main assumptions and data used to calculate Scope 3 emissions and the emission factors used:
Category 1- Purchased goods and services
Category 1 includes emissions related to the production of goods and services delivered to Bank
Millennium in the current year.
GHG emissions for Category 1 were calculated according to the GHG Protocol Spend-based method
and emission factors available in the external database (Exiobase) were adopted.
Category 3 - Fuel- and energy-related activities not included in Scope 1 and 2
Category 3 includes emissions related to the extraction, production and transport of fuels and energy
purchased by Bank Millennium in 2024 that were not included in Scope 1 or 2. This category also
includes losses on the transmission of electricity and heat.
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The data on which the calculations in this category were based were physical data used for
calculations in Scope 1 and 2 derived from the consumption of natural gas, heating oil, diesel oil and
gasoline (Scope 1) and from the consumption of electricity and heat (Scope 2). Emission factors were
taken from the Defra database (2024, v.1_1; GWP100, AR5).
Category 13 - Downstream leased assets (from the lessor's perspective)
Category 13 includes emissions from the operation of assets owned by Millennium Leasing (acting as
a lessor receiving payments for this service) and leased to other entities during the reporting year,
which are not covered by Scope 1 or Scope 2.
For the calculation of emissions in Category 13, the GHG Protocol lessor-specific method was applied,
which includes data on Scope 1 and Scope 2 emissions of lessors and the allocation of these emissions
to the respective leased assets.
The carbon footprint of Bank Millennium regarding leased assets was calculated for the following
groups:
• Light transport
• Heavy transport (trucks over 3.5 tonnes and tractor units)
• Buses and coaches
• Other means of transport
• Machinery and equipment
• Real estate.
Greenhouse gas emissions for light transport were calculated as the product of the emission factor
and the estimated annual mileage for the entire year of 2024. The emission factor was obtained from
the DEFRA database, taking into account the national energy mix. For vehicles with an unknown type
of drive, a separate emission factor was calculated, considering data on the percentage share of
vehicles with a given drive/fuel in Poland and DEFRA emission factors. The annual mileage of leased
vehicles was estimated by the Bank based on data from CEPiK (Centralna Ewidencja Pojazdów i
Kierowców - Central Record of Vehicles and Drivers).
Greenhouse gas emissions for heavy transport were calculated as the product of the emission factor
and the estimated or actual fuel consumption obtained from clients for the entire year 2024. The
emission factor was sourced from the study Ślad węglowy w leasingu STANDARD 2.0 as part of the
ESG project carried out by the ZPL (Związek Polskiego Leasingu - Polish Leasing Association). Fuel
consumption was estimated using the average annual mileage calculated based on CEPiK data and the
average fuel consumption per 100 km derived from the European Environment Agency database.
Greenhouse gas emissions for buses and coaches were calculated as the product of the emission factor
and the estimated or actual fuel or electricity consumption obtained from clients for the entire year
of 2024. The emission factor for electric vehicles was sourced from KOBIZE while for other vehicles,
it was obtained from study Ślad węglowy w leasingu STANDARD 2.0 as part of the ESG project carried
out by the ZPL. Fuel consumption was estimated using the average annual mileage calculated based
on CEPiK data and the average consumption per 100 km derived from data of the Miejski Zakład
Autobusowy w Warszawie (Municipal Bus Company in Warsaw) for electric vehicles and data obtained
from clients for other vehicles.
Emissions of greenhouse gases for other means of transport were calculated as the product of the
emission factor and the estimated or actual fuel consumption obtained from clients for the entire
year of 2024. The emission factor was sourced from the Ślad węglowy w leasingu STANDARD 2.0
report, part of the ESG project conducted by the ZPL. Due to the diversity of other means of transport,
the highest emission factors—those for vehicles over 3.5 tonnes – were applied. For vehicles with an
unknown type of fuel, an average was taken from the emission factors for each type of fuel. Fuel
consumption was estimated using average annual mileage calculated based on CEPiK data or the
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average for the entire group of other means of transport, and the average fuel consumption per 100
km was derived from data provided by clients or the report The Economic Importance of Motorcycles
to Europe by ACEM.
The machinery and equipment portfolio was divided into categories, with following data and
calculation approaches applied:
• Forklifts: calculations were based on estimated annual operating hours and the emission
intensity of electricity.
• Construction Machinery: Calculations were based on estimated annual fuel consumption and
the emission intensity of diesel fuel.
• Photovoltaic Installations and Energy Storage: These were considered non-greenhouse gas
emitting, with zero emissions assumed for Scope 1 and Scope 2.
• Non-energy-consuming Equipment: Items such as halls, containers, and shelves were assumed
to have zero emissions in Scope 1 and Scope 2.
• Others: In cases where there was insufficient data to estimate the energy consumption of the
leased asset, emissions were estimated based on financial indicators, such as emission factors
based on the client's revenue from sales (calculated using data from Główny Urząd
Statystyczny - GUS - Central Statistical Office - or sourced from the Exiobase database). These
calculated client emissions were multiplied by the proportion of the total value of the leased
asset to the client's total balance sheet.
For the carbon footprint calculations of real estate in the leasing portfolio, publicly available PCAF
emission factors for commercial real estate from the year 2020 were used, expressed in tonnes of CO
2
equivalent per square meter of building.
Category 15 – Investments
Category 15 is intended for investors and financial service providers, including commercial banks,
whose investment activities (including equity and debt investments as well as project financing) are
not covered under Scope 1 and Scope 2. The guidelines developed by the GHG Protocol set out the
framework for calculating greenhouse gas emissions across all scopes. However, for Scope 3, Category
15 (Investments), emission calculations are carried out based on a detailed methodology developed
by the Partnership for Carbon Accounting Financials (PCAF) as outlined in the GHG Accounting and
Reporting Standard for the Financial Industry, Part A "Financed Emissions" (December 2022 version).
The GHG emissions according to the PCAF Standard are calculated for 7 asset classes, of which 6 were
considered for the Group's needs:
1. Business loans and unlisted equity.
2. Listed equity and corporate bonds.
3. Project finance.
4. Commercial real estate.
5. Mortgages.
6. Sovereign debt.
The Bank Millennium Group does not have a portfolio of motor vehicle loans.
The calculation of financed emissions was carried out separately for each asset class, taking into
account the emissions of each activity and the appropriate attribution factor that determines the
share of Bank Millennium Group's financial involvement in financing the specific activity or asset.
1. Business loans and unlisted equity
The asset class "Business loans and unlisted equity" includes balance sheet credit exposures that are
not intended for trading and are designated for general corporate purposes, meaning the specific use
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of funds is unknown. These are directed towards enterprises, non-profit organizations, and other
organizations. Within the Bank Millennium Group, this asset class includes the corporate loan
portfolio, defined as exposures to corporate clients maintaining accounting records, excluding project
finance and commercial real estate purchases.
The financed emissions for the asset class of corporate loans were calculated as the product of the
attribution factor and the total emissions of a given company (reported by the company or estimated
by the Group). When company emissions data was unavailable, a method was applied where the
attribution factor was multiplied by the company's revenue and by an emission factor (specific to the
sector, calculated based on data from GUS). In cases where client revenue data was missing, the
average corporate client revenue was estimated based on financial data and the number of non-
financial enterprises in various sectors published by GUS. For clients in the financial industry, due to
the lack of uniform statistical data, the average revenue of enterprises was estimated using the
Group's internal client database.
For some clients of the Group, due to the inability to estimate the necessary financial data,
attribution factors were based on the estimated share of the Group in the client's liabilities, without
considering that the company may partially finance its operations through equity. This approach might
lead to an overestimation of the calculated emissions for these clients.
According to the PCAF methodology, the attribution factor is determined as the ratio of the
outstanding loan amount to the total financing of the company, expressed as:
• The sum of equity and debt for non-listed companies, or
• EVIC (Enterprise Value Including Cash) for publicly listed companies
2. Equity investments and corporate bonds
According to PCAF standard we defined the asset class "Equity investments and corporate bonds" as
follows:
• "Listed equities and corporate bonds": These include all listed shares and corporate bonds
used for financing general corporate purposes, meaning the specific use of the funds is
unknown, as per the GHG Protocol.
• "Unlisted equities": These refer to unlisted equity investments with an unspecified purpose of
funds in companies, non-profit organizations, and other entities.
In the calculations of financed emissions, securities of companies serviced by the Treasury
Department were included. Each investment was treated individually, analyzing whether it was a debt
or equity investment and whether the security was traded on the market.
Financed emissions for this asset class were calculated as the product of the attribution factor and
the total emissions of the given company (reported by the company or estimated by the Group). When
company emissions data was unavailable, emission factors based on revenue (specific to the sector,
calculated using data from Główny Urząd Statystyczny) were applied.
According to the PCAF methodology, the attribution factor is determined as the ratio of the
investment value to the total financing of the company's operations, expressed as:
• The sum of equity and debt for unlisted companies, or
• EVIC (Enterprise Value Including Cash) for publicly listed companies.
3. Project finance
The "project finance" asset class includes all loans and equity investments in projects or activities
with a designated purpose, meaning the use of funds is known, as defined by the GHG Protocol.
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Financed activities include, for example, the construction and energy production from a gas power
plant or photovoltaic or wind installations.
In its corporate portfolio, the Bank Millennium Group has exposures that constitute financing for
renewable energy sources, for which financed emissions were calculated as the product of the
attribution factor and the total emissions of the project, either estimated by the Group or reported.
Since the renewable energy sources financed by the Bank are photovoltaic installations and wind
farms, the Bank Millennium Group adopted the approach that they do not emit greenhouse gases into
the atmosphere. The Group did not use the options provided by the PCAF standard to calculate
avoided or removed emissions due to the lack of necessary data for the calculation.
According to the PCAF methodology, the attribution factor is determined as the ratio of the
outstanding loan amount to the total financing of the project, expressed as the sum of equity and
debt of the project.
4. Commercial real estate
The PCAF standard defines commercial real estate loans as balance sheet exposures intended for the
purchase or refinancing of commercial real estate. This includes:
• Properties used for the borrower's own operations, and
• Properties leased or rented by the borrower for residential or commercial purposes of the
tenant.
The scope of calculations for this asset class includes emissions from buildings that are in use and,
optionally, emissions from their construction.
When an equity investment in commercial real estate is traded on the stock exchange, it is included
in the calculations of financed emissions for the asset class of listed equity. Additionally, commercial
real estate loans that are secured by commercial real estate but intended for other purposes, such as
general corporate purposes, are excluded from the "commercial real estate" asset class. Emissions
from these assets are instead included in the calculations for "business loans”.
For the asset class "commercial real estate" the financed emissions calculations covered the largest
structured financing provided by the Group for which detailed data on the financed properties were
available. In cases where data was unavailable, emissions from these properties were included in the
calculations for the "business loans" asset class.
Financed emissions from the commercial real estate portfolio were calculated as the product of the
attribution factor and the total emissions of the commercial property estimated by the Group or the
reported. For most properties, the Group had energy consumption data from the building's energy
performance certificate or estimates based on the EPC model. The emissions from the properties
were calculated using the building's area in m2 from the loan agreement, annual energy demand, and
emission factors from the PCAF database (broken down by building type and emissions in tCO
2
e/MWh).
In the absence of energy demand data, PCAF emission factors based on the property's area were used.
In the case of loans granted in a consortium, both the initial value and the building area were allocated
proportionally to the Bank's share in the consortium.
In accordance with the PCAF methodology, the attribution factor was determined as the ratio of the
outstanding loan amount to the initial value of the property. If the initial property value at the time
of financing was not known, the Group used the current property valuation available at the start of
the carbon footprint calculation. In the case of significant loan modifications, as defined by the PCAF
standard as increased financing amount, financing renewal, refinancing, or extension, the property
value was updated. The outstanding amount represented the borrower's debt, which decreased over
time until it reached zero at the end of the loan term.
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5. Mortgages
The asset class "mortgages" includes loans for the purchase and refinancing of residential properties,
meaning properties used solely for residential purposes and not for commercial activities. This asset
class does not include consumer loans secured by real estate or credit lines secured by real estate,
as these are typically general-purpose consumer loans for which the PCAF has not yet developed an
emissions calculation methodology.
The Bank Millennium Group included in its emissions calculations exposures that finance residential
properties and developed land, used by the end-user as of the balance sheet date. Mortgage loans for
the construction or modernization of a building are considered optional under the PCAF standard and
were not included in the Group's financed emissions due to a lack of available data. For land and
properties under construction (not in use as of the balance sheet date), zero emissions were assumed.
In addition, a loan that refinances a mortgage provided by the original lender replaces the original
loan. However, in the case of refinancing by a different institution, the exposure and associated
emissions are transferred to the refinancing institution.
Financed emissions for mortgages were calculated as the product of the attribution factor and the
total emissions of the residential property estimated by the Group. For calculating emissions from
residential properties, information from the energy performance certificate was used. In the absence
of such data, emissions were estimated based on the property's annual energy demand in kWh per
square meter using an accepted EPC model. (the property area data in m2 was sourced from the
Bank's internal database, and emission factors were drawn from the PCAF database, categorized by
type of residential property and emissions in tonnes of CO
2
e per MWh).
According to the PCAF standard, the attribution factor corresponds to the LTV (Loan-To-Value) ratio,
which is the ratio of the outstanding loan amount to the initial property value. If the initial property
value at the time of financing was unknown, the current property valuation at the start of the carbon
footprint calculation was used.
6. Sovereign debt
The "public debt" asset class includes government loans and bonds denominated in any currency.
Exposures to central banks are excluded from this methodology unless the central banks issue public
debt on behalf of governments, as well as exposures to local government units and municipal
enterprises are excluded. It is possible to include supranational issuers in this asset class, provided it
does not lead to double counting of a country's emissions.
The Bank Millennium Group calculates the carbon footprint from its sovereign debt securities,
excluding the trading book.
Financed emissions for "sovereign debt" were calculated according to the PCAF standard as the
product of the attribution factor and the emissions of the respective country. The attribution factor
for public debt was adopted from the PCAF standard and is defined as the ratio of the book value of
the bonds to the country's gross domestic product (GDP) adjusted for purchasing power parity (PPP).
Since the GDP adjusted for PPP published by the World Bank for each country is expressed in
international dollars (U.S. dollars), the book values of treasury securities expressed in PLN were
converted to U.S. dollars using the NBP Table A exchange rate.
State greenhouse gas emissions are defined by PCAF in 3 scopes, of which the Bank Millennium Group
has included only Scope 1 in calculations – domestic emissions from sources located within the
territory of a given country. Scope 2 - emissions related to the domestic consumption of electricity,
steam, heating or cooling imported from another territory and Scope 3 - emissions related to imports
of goods and services are not included in the calculation of "sovereign debt" emissions, due to the
cessation of publication of the necessary data for the last period by the OECD (data source indicated
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by the PCAF) and that the indicators made available for a fee to PCAF members relate only to Scope
1.
Information on biogenic emissions is not available for all of the Group's assets generating Scope 3
category 15 emissions.
Percentage of GHG emissions calculated with the use of primary data obtained from suppliers
or other partners in the value chain (Scope 3) for Bank Millennium
Sources of primary data
Emissions [tCO
2
e]
Percentage of emissions in
Scope 3 calculated with the
use of primary data
Cat.1
44,694.19
4.72%
Cat.3
1,154.60
0.12%
Cat.15 Corporate reports:
837,417.80
88.47%
In the portfolio of listed equity
and corporate bonds
832,558.34
87.95%
In the portfolio business loans
and unlisted equity
10.44
0.00%
In the commercial real estate
portfolio
4,849.02
0.51%
Cat. 15 Energy Performance
Certificates in the mortgage
portfolio
63,328.64
6.69%
Total
946,595.23
100.0%
Percentage of GHG emissions calculated with the use of primary data obtained from suppliers
or other partners in the value chain (Scope 3) for the Bank Millennium Group
Sources of primary data
Emissions [tCO
2
e]
Percentage of emissions in
Scope 3 calculated with the
use of primary data
Cat.1
46,762.52
4.58%
Cat.3
1,265.76
0.12%
Cat.13 Customer survey data
66,019.68
6.47%
Cat.15 Corporate reports:
837,417.80
82.07%
In the portfolio of listed equity
and corporate bonds
832,558.34
81.60%
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Sources of primary data
Emissions [tCO
2
e]
Percentage of emissions in
Scope 3 calculated with the
use of primary data
In the portfolio of business
loans and unlisted equity
10.44
0.00%
In the commercial real estate
portfolio
4,849.02
0.48%
Cat. 15 Energy Performance
Certificates in the mortgage
portfolio
68,848.14
6.75%
Scope 3 total
1,020,313.90
100.0%
16.3.4. GHG REMOVALS AND GHG MITIGATION PROJECTS FINANCED THROUGH
CARBON CREDITS
[E1-7] The objective of the disclosure of information about GHG removals and GHG mitigation
projects financed through carbon credits is to provide an understanding of the undertaking’s actions
to permanently remove or actively support the removal of GHG from the atmosphere, potentially for
achieving net-zero targets and to provide an understanding of the extent and quality of carbon credits
the undertaking has purchased or intends to purchase from the voluntary market, potentially for
supporting its GHG neutrality claims. The scope of the disclosures is inadequate to the business
activities conducted by the Bank Millennium Group, because it does not perform such projects in the
area of its own operations and neither does it finance such projects.
16.3.5. INTERNAL CARBON PRICING
[E1-8] The Bank Millennium Group does not apply any internal carbon pricing systems.
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17. BANK MILLENNIUM GROUP EMPLOYEES (ESRS S1)
17.1. STRATEGY FOR THE WORKFORCE AREA
17.1.1. INTERESTS AND VIEWS OF STAKEHOLDERS
[SBM-2] The Bank treats the views of employees as a key component of its management process and
of building an organizational culture based on dialogue and mutual respect, as has also been reflected
in our new strategy for 2025–2028 providing for, among other aspects, the pursuit of initiatives
responding to the outcomes of the Employee Satisfaction Survey.
The Bank provides its employees with channels of communication to submit their views, ideas and
comments through regular employee surveys, dedicated feedback boxes (electronic and physical),
open meetings with the Bank’s management, and an established process for the submission of
anonymous notifications that ensures the safety of the notifying individual.
Every view submitted by an employee is thoroughly reviewed and considered. The Bank takes
employee views into account and uses them to continuously improve its work environment and
processes. The consequences of actions taken on the basis of submitted information are
communicated to employees, depending on their nature, through the internal Intranet site, during
team meetings, etc.
The process of collecting and analysing employee views is conducted on a regular basis, annually, to
monitor changes in employee needs and expectations. The Bank evaluates the effectiveness of any
solutions that have been implemented based on subsequent surveys and employee engagement
indicators.
17.1.2. MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR
INTERACTION WITH STRATEGY AND BUSINESS MODEL
[SBM-3] The issue of material impacts, risks and opportunities and their interaction with strategy and
business model covers all own workforce, as is discussed later on in section 17.2 Employee
characteristics.
In the course of identifying impacts in the own workforce area, we have categorized a total of thirteen
significant issues. These include one negative impact and twelve positive ones. We have not identified
any risks or opportunities in this area.
The material issues are categorized under the following three sub-topics from the ESRS guidelines:
1. Working conditions:
• Health and safety
• Secure employment
• Work-life balance
• Working time
• Adequate compensation
• Social dialogue with employees
• Freedom of association, existence of works councils and employees’ rights to
information, consultation and participation
2. Equal treatment and opportunities for all:
• Gender equality and equal pay for work of equal value
• Training and skills development
• Measures against violence and harassment in the workplace
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• Diversity
3. Other work-related rights:
• Privacy
Measures to ensure health and safety of employees:
The Bank has implemented numerous initiatives and solutions to ensure the highest standards of
employee health and safety, including:
• Medical care – to ensure that employees have access to comprehensive medical care for
themselves and on preferential terms also for their families;
• Health and safety training – regular occupational health and safety training;
• Preventive support – promoting preventive health care and regular check-ups.
Measures to ensure secure employment:
The Bank provides its employees with job stability and security by:
• Hiring employees under indefinite-term employment contracts; minimizing hiring under
other forms of employment;
• Dedicated fringe benefits – for instance, implementing fringe benefit packages that
include health insurance, gym cards and retirement benefits.
Work-life balance:
The Bank complies with the Labour Code, including by providing its employees with the opportunity
to take a family leave
In response to the changing needs of employees and out of concern for their well-being, the Bank has
implemented programs to support work-life balance, providing for a hybrid work model and offering
workshops and webinars on mental health, stress management and methods to build mental
resilience.
Measures to ensure that employees are hired on a full-time basis and their overtime is properly
managed:
• Hiring employees on a full-time contract basis
• Overtime management – complying with regulations applicable to overtime, proper
recording and compensation arrangements.
Employee compensation consistent with benchmarks and subject to regular reviews:
• Transparent employee compensation system – the Bank ensures that its employees are
compensated in accordance with relevant benchmarks. The Bank carries out regular
market reviews to ensure that its employees receive competitive and fair compensation,
• Pay equality – ensuring the absence of pay gaps between genders or between similar
positions.
Social dialogue with employees:
• Consultation mechanisms – the Bank has adopted regular consultation processes,
including surveys and open meetings for employees with the Bank’s management.
• Openness to feedback – provision of mechanisms for anonymous submission of comments
and opinions by employees.
Freedom of association:
• The Bank respects employees’ rights of association and engages in active cooperation
with union representatives.
Promoting gender equality and gender neutrality in the employee compensation area:
• To counteract any discriminatory practices, the Bank endeavours to ensure that the
process of setting employee compensation ensures gender neutrality.
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Providing workforce with the means to support their skill development:
• Regularly investing in employees’ skill development by means of internal and external
training.
• The Bank supports employees in building career paths aligned with their needs.
Measures to provide employees with instruments against harassment:
• The application of any discriminatory practices bearing the characteristics of bullying or
harassment against employees is prohibited as provided for in pertinent policies and
internal regulations. The Bank has put in place a system for reporting any breaches of
employee rights.
Supporting diversity:
• The Bank actively supports diversity by promoting openness and respect towards all
employees.
Personal data protection:
• The Bank ensures compliance with data protection regulations
• The Bank provides regular training on data protection and cyber security.
All these issues are dealt with in detail in the ESRS S1 thematic sections of the report concerning the
area of own workforce.
The impacts identified in the course of the double materiality analysis are reflected in the Millennium
Bank Group’s Bank Strategy 2025-2028, in the Bank’s internal regulations and in the organization’s
business model.
The Bank’s new Strategy has laid down a set of clearly defined goals related to sustainability,
employee engagement and organizational innovation. All initiatives described in the area of own
resources support the achievement of such goals, specifically:
1. Ensure talent acquisition and development plan matching key strategic goals:
• Acquire talents for strategic business lines
• Develop new onboarding process
• Create and deploy development process for strategic area
2. Increase the attractiveness of the Bank as a place to work:
• Maintain Top Employer certificate
• Keep increasing satisfaction of employees
• Maintain Bank Millennium as inclusive and wellbalanced workplace
3. Keep competitiveness and compliance of remuneration policy:
• Mitigate the attrition of staff
• Keep competitive remuneration policy versus the Polish banking sector
• Further develop remuneration policy under ESG and transparency standards
4. Elevate values and corporate culture to support new strategy:
• Adjust corporate culture to internal and external changes
• Refresh and amplify the corporate culture by redefining and communicating the
vision, mission and values
• Continue to build lifelong learning culture
5. Constantly improve HR services:
• Further improve employee experience by introducing digital employee services
• Design and implement a service model based on HR business partners
• Keep optimising HR processes
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and the Bank Millennium S.A. Group in 2024
Under the sub-topic “Health and safety”, we have identified one negative impact: the potential for
employees in branches to be exposed to robbery associated with their handling of physical cash.
Ensuring the safety of employees is a fundamental responsibility of the employer as an entity required
to protect the health and lives of employees by ensuring safe working conditions. Accordingly, the
Bank is taking all possible steps to thwart any and all incidences of robbery in its branches, in
particular by reducing to a minimum the handling of cash by branch staff. Factors that reduce the
risk of robbery on a Bank branch are low amounts of cash and a high likelihood of incarceration. The
Bank recorded no incidents of robbery in its branches in 2024.
The Bank has adopted the Manual on physical safety and cash handling at Bank Millennium S.A.’s own
network outlets, which defines physical security and operating procedures for dealing with cash and
performing treasury activities at its own network outlets.
The fulfilment of the tasks provided for in the Bank’s new strategy will require the involvement of all
employees. The Bank understands the need to invest properly in its most important assets: people
and technology, and is adamant about building and developing its position as a top employer.
We have plans to extend educational activities for our workforce to include the topics of climate and
nature protection, volunteerism activities to support the pursuit of initiatives related to
environmentalism in its broadest sense, environmental protection, and encouraging grassroots
environmental and socially beneficial initiatives.
We understand the significance of dialogue with employees. Our primary objective is to ensure the
engagement of employees by actively listening to their opinions and being open to change. By
engaging in open communication, we enable the possibility of identifying additional areas for
improvement and taking action to improve the work environment that we offer.
We understand how concerned our employees are when it comes to the Bank’s impact on the natural
environment. In 2024, Bank Millennium began preparing a Transition Plan to reduce its negative
environmental impacts and increase the green and climate-neutral nature of its operations. As part
of the development of this plan, an analysis of the impact of activities to be carried out as a result
of its adoption on the Bank’s employees will be taken into account.
17.1.3. POLICIES RELATED TO OWN WORKFORCE
[S1-1] The Human Resources Department has been put in charge of monitoring alignment with the
objectives pursued by all internal regulations, described in chapter 17, related to own workforce.
This is served by the tools selected for the deployment of specific processes that are available to all
employees of the Bank, enabling their measurability and effectiveness, including: a channel for
reporting violations, a system for handling training, a system for working time and vacations, HR
portal for reporting problems or questions related to the HR area, and a system for reporting technical
problems related to the workplace. Thanks to these solutions, employees have easy access to the
necessary information and can actively participate in the organization's internal processes, and the
employer can monitor compliance with rules and regulations on an ongoing basis, analyzes their
effectiveness and, if necessary, implements appropriate changes to internal regulations.
Work Rules and Regulations in Bank Millennium
In the Bank Millennium Group, the underlying document defining the rights and obligations of
employees and the standards applicable to the safety and organization of work is the Work Rules and
Regulations, as approved by the Bank’s Management Board after prior approval by the Trade Unions
under the Collective Bargaining Agreement. The employer’s actions are performed by: President of
the Management Board, Management Board Member in charge of supervising the Human Resources
Department and the Head of the Human Resources Department.
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and the Bank Millennium S.A. Group in 2024
The provisions of the Rules and Regulations apply to all employees of Bank Millennium. The
transparency of the rules and regulations in place ensures that all employees enjoy a feeling of
certainty about their terms of employment, procedures and principles applied in the workplace.
Among other aspects, the document governs issues related to employment stability and job security.
Code of Ethics of the Bank Millennium Group
The Bank considers the conduct of business in a sustainable and ethical manner to be among the
fundamental principles of its operation, stemming directly from the Bank’s mission and values. The
Code of Ethics serves as the primary tool laying down the ethical and professional standards followed
by the Bank’s workforce. It is a collection of values and principles that guide the Bank in its relations
with employees, business partners and local communities. It promotes a work culture based on
honesty, respect and equality, fostering a sense of security and stability among employees.
The Code of Ethics has been approved by the Supervisory Board and applies to all employees of the
Bank Millennium Group. The Compliance Department is responsible for articulating the principles of
the Code of Ethics, communicating and promoting ethical values in the Bank and evaluating the
adherence to the principles of ethics.
Compensation policy for employees of the Bank Millennium Group,
Compensation policy for Members of the Bank Millennium Management Board and Supervisory
Board,
Compensation policy for risk takers in the Bank Millennium Group.
The Compensation policy for employees of the Bank Millennium Group articulates the assumptions
used to shape the fixed and variable components of compensation for all employees in the Group
while taking into account the tasks and degrees of power assigned to the teams and units concerned.
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. All
individual solutions concerning compensation systems are prepared according to the principles
prescribed by this policy.
The Compensation policy for Members of the Bank Millennium S.A. Management Board and
Supervisory Board governs the principles of employee compensation for the Bank’s top management
bodies.
The Compensation policy for risk takers in the Bank Millennium Group provides a formal framework
for shaping employee compensation for a separate group of senior managers in the Bank Millennium
Group, identified as exerting a material impact on the Group’s risk profile – also known as Risk Takers.
The Bank’s Management Board is responsible for the implementation of all the above Compensation
Policies. The Bank’s Management Board develops, implements, maintains and ensures the operation
of the Compensation Policies that are suitable for the management system and risk strategy and the
internal control system in the Bank Millennium Group.
The Bank’s Supervisory Board is responsible for approving the Compensation Policies. Once a year,
the Bank’s Supervisory Board prepares and presents to the Bank’s Shareholder Meeting a report on
the assessment of the functioning of Compensation Policies in the Bank Millennium Group.
The implementation of the Compensation Policies in the Bank Millennium Group is subject to opinions
by the Personnel Committee of the Bank’s Supervisory Board. In its report to the Bank’s Supervisory
Board, the Personnel Committee of the Bank’s Supervisory Board presents its conclusions regarding
the functioning of the Compensation Policies.
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and the Bank Millennium S.A. Group in 2024
The Bank’s Shareholder Meeting is responsible for assessing whether the approved Bank Millennium
Group Compensation Policies support growth and security. The Bank’s Shareholder Meeting makes the
above assessment on the basis of the annual report on the assessment of the functioning of the
Compensation Policies in the Bank Millennium Group, which is prepared and presented by the Bank’s
Supervisory Board.
The compensation of key managers is set by the Personnel Committee of the Bank’s Management
Board and the compensation of the Bank’s Management Board Members is determined by the
Personnel Committee of the Bank’s Supervisory Board.
Human rights policy
The human rights policy is approved by the Bank’s Management Board and applies to all employees of
the Bank Millennium Group.
Respect for human rights is embedded in the fundamental objectives and commitments of the Bank
Millennium Group, which is to conduct its business on the basis of social responsibility, in particular
by pursuing the United Nations Sustainable Development Goals. As the Bank Millennium Group, we
are committed to respecting human rights, ensuring compliance with the provisions of Polish and
international law (including the United Nations Universal Declaration of Human Rights) and the 10
Principles of the UN Global Compact, and defining internal practices and procedures in this area.
In the Policy, we have adopted the following principles related to respecting and advancing human
rights:
• Prohibition of forced labour, child labour and human trafficking – we reject all forms
of forced labour related to human trafficking, forced labour and child labour or any
modern form of slave labour, in compliance with the provisions of Polish and international
law in this respect.
• Prohibition of discrimination and violation of labour rights – we promote a culture of
tolerance and reject all forms of discrimination based on origin, gender, sexual
orientation, family situation, nationality, ethnicity, religion, membership in social groups
and political beliefs, or any kind of individual physical characteristics, health conditions
or disabilities. We provide a healthy and safe work environment, free from discrimination,
bullying, harassment and any and all forms of violence.
• Freedom of association – we respect the freedom of association and comply with the
rules that permit employees to associate, and we create conditions for employee
organizations, including trade unions, to operate in accordance with applicable laws.
• Employee compensation – we promote fair and equitable compensation for our
employees, based on their qualifications, experience, responsibilities and functions. We
comply with national and international laws, particularly the Labour Code, and all
pertinent internal regulations.
• We promote conditions that ensure a balance between professional career and personal
life as well as other personal needs of our employees.
• Employee relations – we promote human rights in our relations with employees by
adopting and applying relevant internal regulations, including the Bank Millennium
Group’s Code of Ethics, which defines principles that shape healthy and transparent
relations with this group of stakeholders.
Diversity management policy
Our diversity management policy is aimed at promoting a culture of mutual respect, identifying
diversity, ensuring equal opportunities, preventing exclusion and avoiding discrimination – all this in
respect of all employees of the Bank Millennium Group. The Bank’s Management Board is responsible
for implementing the policy.
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and the Bank Millennium S.A. Group in 2024
In accordance with the provisions of the diversity management policy, the Bank Millennium Group
operates while respecting human dignity, adheres to the law on equal treatment regardless of age,
gender, ethnic or national origin, financial situation, religion, family status, sexual orientation, health
condition, religious and ideological convictions, trade union membership and other reasons that might
trigger discrimination.
The Bank Millennium Group takes into account the principle of respect for diversity in all pertinent
internal regulations and puts it into practice in the following areas: appropriate working conditions,
building awareness and developing employees.
In accordance with the adopted policy, the Bank Millennium Group promotes among all employees
the values of unqualified respect for human dignity and diversity, with zero tolerance for any form of
discrimination. The only criteria affecting employee compensation and access to specific positions
involve the employee’s competence and performance. Employee compensation is defined in
accordance with function, career and degree of achievement of established goals, promoting a 1:1
pay ratio between men and women holding comparable functions and having similar levels of
responsibility and career progression.
Procedure for dealing with reports from employees, including those suggesting bullying, mobbing
or discrimination in Bank Millennium
[S1-1] In order to ensure the implementation of adopted commitments and principles in policies and
other internal regulations, the Bank has put in place a procedure, which is a supporting tool for
preventing and mitigating discrimination and taking action after its detection as well as increasing
diversity and overall inclusion.
The procedure governs and describes the process of employee notifications, which may include, in
particular: suspected bullying, discrimination, inappropriate behaviour, breaches of personal rights
or violation of the Bank’s rules of social coexistence.
The procedure applies to all employees of the Bank and is issued by way of communication from the
Director of the Human Resources Department.
HR policy
The HR policy is based on Bank Millennium’s mission and values and defines the framework for the
operation of the HR area in the Bank Millennium Group. It describes both the HR management model
and the regulations that serve as the legal basis for the HR management system in the Bank Millennium
Group.
The policy also outlines the HR Department’s key areas of operation, such as recruitment and
onboarding, compensation and benefits, training and development, leadership, employee opinion
surveys, digitalization of HR processes and data analysis, defines the objectives within these areas
that stem from the Bank Millennium Group’s strategy, and addresses the ambitions and aspirations
that guide the HR management area. The document aims to ensure consistency and transparency in
human resources management, support employee development, promote organizational values and
align HR processes with the latest trends and labour market requirements.
The HR policy is approved by the Bank’s Management Board and applies to all Group employees. The
HR Department is responsible for implementing the policy.
Instructions for participation in training programs at Bank Millennium
Training and development activities in the Bank are carried out with a view to improving the
competencies of employees, enhancing the quality and efficiency of work, and as a result –
contributing to current and future strategic goals.
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and the Bank Millennium S.A. Group in 2024
The Instructions constitute an internal operational document that contains the rules and describes all
necessary information on the process of providing training to Bank employees.
The document is approved by the Bank’s Management Board and the Human Resources Department,
which is in charge of arranging training for employees within the scope of its powers and is responsible
for its implementation and updating.
Instructions for managing occupational health and safety and fire protection in Bank Millennium
[S1-1] 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
for all employees of Bank Millennium.
Pursuing the task of implementing and updating the Instructions is the responsibility of the
Occupational Health and Safety Team with the participation of the Bank’s relevant units. The
Management Board is responsible for approving the Instructions as a document applicable to all
employees of Bank Millennium.
The Bank does not have a separate policy in place dealing with issues related to the prevention and
management of accidents at work, as these issues are governed by legislation, adhered to by the
Bank. In accordance with current practice, the Bank determines the circumstances and causes of
accidents at work and applies appropriate measures to prevent accidents on the basis of the
applicable provisions of the Labour Code and the Regulation of the Council of Ministers of 1 July 2009
on determining the circumstances and causes of accidents at work.
Bylaws of the Company Social Benefits Fund in Bank Millennium
[S1-11] The Bylaws lay down the principles for the creation and conditions for the use, by Bank
Millennium employees, of services and benefits financed by the Company Social Benefits Fund.
Individuals entitled to use the benefits provided by the Fund are full-time and part-time Bank
Millennium employees, their family members and former employees of the Bank who either retired
or received a disability pension immediately after the termination of their employment relationship
with the Bank. The Fund’s resources are administered by the Director of the Human Resources
Department, acting under the authority of the Bank’s Management Board.
Personal data security policy in Bank Millennium
The Bank has adopted the Personal data security policy in Bank Millennium S.A., which describes the
general rules regarding the protection of data processed by the Bank. The purpose of the Policy is to
define the rules for processing personal data in compliance with the requirements of the applicable
legal regulations on personal data protection. The Policy applies to all employees of Bank Millennium.
The Bank’s Management Board is responsible for approving, implementing and amending the Personal
Data Security Policy. The Data Protection Department is in charge of supervising the implementation
of the Policy.
Instructions for processing personal data in Bank Millennium
The document contains detailed information on the purposes and duration of the employer’s
processing of employees’ personal data, the categories of entities that have access to personal data
and the rights of employees related to the processing of their personal data. The scope of the
information provided corresponds to the requirements under EU data protection legislation, i.e.
Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: “Regulation”).
Supervision over the proper processing of personal data is exercised by the Data Protection Officer.
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and the Bank Millennium S.A. Group in 2024
17.1.4. PROCEDURES FOR COOPERATION WITH OWN WORKFORCE AND
EMPLOYEE REPRESENTATIVES REGARDING IMPACTS
[S1-2] In implementing the provisions of the Code of Ethics, Bank Millennium regularly surveys
employee opinions and conducts extensive communication and dialogue with employees:
Employee satisfaction surveys
The employee satisfaction survey is a process by which the Bank collects opinions directly from its
employees on various aspects of their work and work environment. The purpose of the survey is to
understand how employees evaluate their work experience, thus enabling the Bank to identify areas
for improvement and make appropriate changes within the organization. The survey is conducted
annually.
The survey covers various aspects of work, such as terms and conditions of employment, relationships
with superiors and co-workers, work organization, professional development opportunities,
compensation, job stress and other elements that affect overall employee satisfaction.
Employees receive information about general outcomes of the survey through a message posted and
communicated to employees via the World of Millennium intranet site, and detailed results are
discussed at managers’ meetings and departmental meetings with employees.
In 2024, 63% of the Bank’s employees participated in the survey.
The outcomes of the survey are reviewed and used to evaluate the organization’s activities, improve
strategy and plan future assignments. The outcomes of the 2023-2024 satisfaction survey were taken
into account in:
▪ Preparing a multi-level approach to employee training and development, which includes
individual training, development plans for areas and departments, programs for managers,
self-learning platforms as well as specialized development and certification programs.
▪ Employee compensation reform, which consisted of comprehensive job reform and
compensation updates, the introduction of new job titles, a competency evaluation system
and an approach to raises and promotions based on individual evaluation.
▪ Changes in work organization and improvement of communication based in particular on
building a new knowledge base and information on the intranet, implementing a new
onboarding process and introducing a voluntary lunch break.
▪ Designing activities to reduce occupational stress, for instance through the creation of an
intranet-based Me Zone, available to all employees, broad access to webinars on health and
stress reduction techniques, and a cancer prevention program.
The Bank’s unit responsible for implementing this process and reporting the results to the Management
Board is the Human Resources Department, in particular the Director of the Human Resources
Department who heads it. The Human Resources Department remains under direct oversight of the
President of the Management Board.
Participation in the survey conducted among Bank employees is voluntary and responses are
anonymous in order to provide respondents with the comfort and freedom to express their opinions.
The survey and review of its outcomes are conducted through an external company.
Meetings between employees and the Management Board
The Management Board emphasizes communication and dialogue with the Bank’s employees. The
Bank holds periodic meetings to discuss issues of importance to employees:
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and the Bank Millennium S.A. Group in 2024
▪ Periodic meetings with the Bank’s managers to discuss the Bank’s quarterly results, ongoing
projects and plans.
▪ Regular working meetings of managers with Management Board Members to discuss the Bank’s
current activities.
▪ Meetings of Management Board Members with specific employee groups – such meetings are
open to employees who may directly ask questions or submit their suggestions to Management
Board Members. As part of an organized initiative, interested employees may share their
opinions on a specific topic and then participate in business lunches held for a smaller group
of participants. Such meetings are attended by the President of the Management Board or
other Management Board Members. They provide an opportunity for employees to directly
share their opinions regarding work in Bank Millennium. In 2024, the meetings concerned the
survey on How to work more efficiently in Bank Millennium. Feedback was provided by 100
individuals, following which we categorized 238 ideas. Employees who provided their
responses were invited to participate in direct meetings with a small group of decision
makers. Lunch meetings were held in 3 Bank Millennium head offices – in Warsaw, Wrocław
and Gdańsk.
The Bank encourages open communication. The employee social network Viva Engage and the World
of Millennium intranet site serve this purpose. 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 Employee Zone intranet site on
which it regularly posts all information of interest to employees about employee-related matters.
Cooperation with trade unions
In accordance with the provisions of the human rights compliance policy implemented in Bank
Millennium, we respect the freedom of association and comply with the rules that permit employees
to associate, and we create conditions for employee organizations, including trade unions, to operate
in accordance with applicable laws.
Two trade union organizations operate in Bank Millennium and one trade union organization operates
in Millennium Leasing. There are no trade union organizations in other Group companies.
Employees of the Bank and Bank Millennium Group companies are not covered by a collective
bargaining agreement. The advancement of collective bargaining agreement negotiations is 0%. 100%
of employees are represented by trade unions.
The Bank, in accordance with the applicable laws, cooperates with the trade unions within the scope
defined by the legal regulations and the Trade Unions Act of 23 May 1991.
Under the agreements in place, the Bank and the trade unions agrees on internal regulations relevant
to employees, such as reward regulations, bonus regulations, remote work regulations and the social
fund spending plan. The Bank also consults with the trade unions on case-by-case employee issues.
The HR Department is responsible for cooperation with the trade unions.
The Bank provides employees with information on changes regarding relations with it as an employer,
taking into account the criterion of relevance, with the advance notice specified by labour legislation,
that is a minimum of 30 days.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
17.2. WORKFORCE CHARACTERISTICS
17.2.1. CHARACTERISTICS OF THE ENTITY’S WORKFORCE
[S1-6] The Bank treats the Republic of Poland as the area of its business activity, and therefore all
employee disclosures refer to Poland without the Bank isolating any other locations relevant to its
business activity. At the end of 2024, the headcount in the Bank Millennium Group was 6,836 people.
Most of the employed workers were women (65%), and the average age of employees was 40. In the
Millennium Bank Group, we did not experience any significant fluctuations in the number of Group
employees between the reporting periods. We do not hire employees during unguaranteed working
hours.
Workforce characteristics by gender in the Bank Millennium Group and Bank Millennium
3
Gender
Headcount
FTE
Headcount
FTE
Group
Bank
Males
2,419
2,373
2 269
2,260
Females
4,417
4,341
4,206
4,190
Other
0
0
0
0
Not reported
0
0
0
0
Total of employees
6,836
6,714
6,475
6,450
Characteristics of the Bank Millennium Group's employees, categorized by form of employment
and working hours
Number of people
Females
Males
Other
Not
reported
Total
Number of employees
4,417
2,419
0
0
6,836
Number of permanent employees
3,930
2,080
0
0
6,010
Number of temporary workers
487
339
0
0
826
Number of employees who are not
guaranteed working hours
0
0
0
0
0
Number of full-time employees
4,285
2,362
0
0
6,647
Number of part-time employees
132
57
0
0
189
3
Includes the Group’s employees working under an employment relationship (fixed-term and indefinite-term contracts,
substitutions) as at 31 December 2024. Data are provided for the Group in total and for the Bank individually, in persons, as
well as in full-time equivalents (FTEs) – for instance, if an employee is employed 50% of the time equivalent to a full-time
employment contract, we report 0.5 FTEs. The number of employees disclosed in this report is identical to the number of
employees disclosed in the Report of the Management Board on the activities of Bank Millennium and the Bank Millennium
Capital Group for 2024.
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and the Bank Millennium S.A. Group in 2024
Characteristics of the Bank Millennium employees, categorized by employment type and working
hours
Number of people
Females
Males
Other
Not
reported
Total
Number of employees
4,206
2,269
0
0
6,475
Number of permanent employees
3,726
1,943
0
0
5,669
Number of temporary workers
480
326
0
0
806
Number of employees who are not
guaranteed working hours
0
0
0
0
0
Number of full-time employees
4,141
2,253
0
0
6,394
Number of part-time employees
65
16
0
0
81
Employee turnover in the Bank Millennium Group and Bank Millennium
Number of people
Headcount
FTE
Headcount
FTE
Group
Bank
Number of total employees who left the unit
1,034
1,016.3
982
979.8
Employee initiative
558
555.7
533
531.8
Mutual agreement
106
93.2
92
91.6
Dismissal
336
335.5
326
325.8
Retirement
30
28.6
28
27.6
Death
4
3.3
3
3.0
Employee turnover rate
15.1%
15.1%
15.2%
15.2%
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and the Bank Millennium S.A. Group in 2024
17.2.2. CHARACTERISTICS OF NON-EMPLOYEES CONSTITUTING OWN
EMPLOYEE RESOURCES
[S1-7] As at 31 December 2024, the Bank cooperated with 1,567 persons that were non-employees.
This group mainly includes 508 contract employees providing highly specialized IT services in the
Bank’s development projects. The vast majority of the remainder are 850 franchisee employees bound
by an employment relationship with the Bank as a Natural Person Providing Agency Services (NPPAS).
Characteristics of persons not employed by the Bank Millennium Group breakdown by type of
employment contract
Number of people
Females
Males
Other
Not
reported
Total
Number of non-employees
953
614
0
0
1,567
Contracts of mandate, contracts for specific
work, civil law agreements for the Supervisory
Board, trust contracts, agreements based on
the resolution
74
135
0
0
209
Contracts of mandate NPPAS
741
109
0
0
850
B2B
118
247
0
0
365
Outsourcers
20
123
0
0
143
Characteristics of persons not employed by Bank Millennium breakdown by type of employment
contract
Number of people
Females
Males
Other
Not
reported
Total
Number of non-employees
828
354
0
0
1,182
Contracts of mandate, contracts for specific
work, civil law agreements for the Supervisory
Board, trust contracts, agreements based on the
resolution
67
122
0
0
189
Contracts of mandate OFWCA
741
109
0
0
850
B2B
0
0
0
0
0
Outsourcers
20
123
0
0
143
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17.3. EMPLOYMENT SECURITY, FRIENDLY PLACE TO WORK
17.3.1. POLICIES RELATED TO EMPLOYMENT SECURITY
[S1-1] In the Bank Millennium Group, the underlying document defining the rights and obligations of
all employees and the standards applicable to the safety and organization of work is the Work Rules
and Regulations.
The document is described in more detail in section 17.1 Strategy for the workforce area.
17.3.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] The Bank Millennium Group operates in Poland, where employment conditions and practices
are strictly regulated by law. All employees work under employment contracts and enjoy guaranteed
working hours. The Bank Millennium Group’s employment structure consists mainly of full-time (97%
of employees in 2024) and indefinite-term contracts (88%). 99% of employees are employed locally
(Polish citizens working in Poland). The forms of employment adopted in the Bank provide employees
with a sense of security and stability.
Bank Millennium recognizes employment security and stability as key elements of responsible and
sustainable human resources management. Our approach is based on two pillars: adherence to the
Labour Code as the supreme external document governing the rights and obligations of the employer
and employees, and internal regulations designed to ensure the highest standards of safety, ethics
and social responsibility.
Bank Millennium regularly surveys employee opinions and conducts extensive communication and
dialogue with employees. The purpose of the survey is to understand how employees evaluate their
work experience, thus enabling the Bank to identify areas for improvement and make appropriate
changes within the organization. These activities are described in more detail in section 17.1 Strategy
for the workforce area.
We promote conditions that ensure a balance between professional career and personal life as well
as other personal needs of our employees. Creating a friendly workplace that fosters work-life balance
is not only a key sustainability element, but also a major factor contributing to employee productivity,
commitment and loyalty.
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.
Bank Millennium permits its employees to customize their form and working hours by offering various
systems, such as fixed, shift-based, task-based or equivalent, as well as work under a hybrid model.
For more information, see section 17.5 Working time.
The Bank established an intranet-based Me Zone, available to all employees, broad access to webinars
on health and stress reduction techniques, and a cancer prevention program. In addition, we organize
numerous webinars on the topics of diversity and broadly construed well-being.
Employee volunteerism
Within these activities, employee volunteerism plays a special role, which not only supports local
communities, but also fosters a sense of meaning, community and commitment among teams.
Volunteer activities enable employees to pursue their passions and values while favourably affecting
workplace relations and building an organizational culture based on social responsibility.
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In 2024, employee volunteerism focused on environmental initiatives. Moreover, due to the flood
crisis that unfolded in southern Poland, volunteers had the opportunity to submit projects to support
those affected by the calamity.
Social safety [S1-11]
Bank Millennium operates under the provisions of the Labour Code, which guarantees, without
limitation, protection to all employees against loss of income due to serious life emergencies, such
as illness, unemployment, work accident, acquired disability, parental leave and retirement.
All Bank Millennium Group employees are offered the same social and financial benefits regardless of
the type of employment contract (for a definite/indefinite term), working time (part-time/full-time)
or the place of work:
• Support activities for employees approaching retirement/post-retirement
Approximately 14% of Bank Millennium Group employees are over the age of 50. Retired employees
may continue private medical care after termination of employment on preferential terms and may
apply for an allowance in challenging financial or health situations. At the request of retiring
employees, training related to employment continuity and facilitating the retirement process is
provided. In the event of retirement, the Bank pays the employee a retirement allowance based on
length of service, which is higher than that provided for in the Labour Code.
• Social benefits
The amount and scope of benefits depend on the employee’s life and financial situation. 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. The benefit may also be used by employees who retired
or received a disability pension immediately after the cessation of their employment
relationship.
The Bank provides employees with access to a private medical care program throughout Poland.
Under individually prepared ranges of medical subscriptions, all employees have access to basic and
specialist medical consultations, detailed diagnostic tests and prevention programs. Medical
subscriptions on preferential terms may also be used by family members of a current or retiring
employee.
For employees who want additional financial security for unforeseen life situations, we offer an
extensive life insurance program. Life insurance constitutes a cornerstone of financial security.
Owing to the Bank’s extremely favourable agreement with Poland’s largest insurer, employees may
join a group insurance program and benefit from terms they would not be able to obtain if they
insured themselves individually. Joining the insurance is voluntary. The protection covers the life and
health of the employee and their family members.
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17.3.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] Bank Millennium has set a goal in its Strategy for 2025-2028 to maintain a competitive,
transparent and compliant employee compensation policy and to enhance the Bank’s attractiveness
as a place to work by among other maintaining its position as a Top Employer.
Ongoing progress in implementing strategic sustainability initiatives (as described in the ESG Strategy
for 2022-2024) has been monitored on a quarterly basis by the Sustainability Committee. The
managers of the substantive units are responsible for the achievement of individual goals, and they
report on the level of the goal’s achievement in their area. On this basis, a report is prepared after
each Committee meeting.
The same monitoring model will be maintained in subsequent years, for the Strategy for 2025-2028.
Targets were set in consultation with the units involved in their pursuit.
17.3.4. WORK-LIFE BALANCE METRICS
[S1-15]
Employees of the Bank Millennium Group eligible to take a leave of absence for family-related
reasons
Number of people/FTE
Females
Males
Other
Not
reported
Total
Employees entitled to a family reasons’ leave
Maternity, paternity, parental leave
372
133
0
0
505
Child care leave (Article 188 of the Labor Code)
1,507
433
0
0
1,940
Care leave to provide personal care or support to a
person who is a family member or resides in the same
household (5 days)
4,417
2,419
0
0
6,836
Employees who took a family reasons’ leave
Maternity, paternity, parental leave
221
130
0
0
351
Child care leave (Article 188 of the Labor Code)
1,507
433
0
0
1,940
Care leave to provide personal care or support to a
person who is a family member or resides in the same
household (5 days)
45
16
0
0
61
Percentage of employees eligible to a family reasons’ leave
Maternity, paternity, parental leave
8%
5%
0%
0%
7%
Child care leave (Article 188 of the Labor Code)
34%
18%
0%
0%
28%
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Number of people/FTE
Females
Males
Other
Not
reported
Total
Care leave to provide personal care or support to a
person who is a family member or resides in the same
household (5 days)
100%
98%
0%
0%
100%
The percentage of eligible employees who took a family reasons’ leave
Maternity, paternity, parental leave
59%
98%
0%
0%
70%
Child care leave (Article 188 of the Labor Code)
100%
100%
0%
0%
100%
Care leave to provide personal care or support to a
person who is a family member or resides in the same
household (5 days)
1%
1%
0%
0%
1%
Employees of the Bank Millennium eligible to take a leave of absence for family-related reasons
Number of people/FTE
Females
Males
Other
Not
reported
Total
Employees entitled to a family reasons’ leave
Maternity, paternity, parental leave
362
124
0
0
486
Child care leave (Article 188 of the Labor Code)
1,459
409
0
0
1,868
Care leave to provide personal care or support to a
person who is a family member or resides in the
same household (5 days)
4,209
2,269
0
0
6,475
Employees who took a family reasons’ leave
Maternity, paternity, parental leave
216
122
0
0
338
Child care leave (Article 188 of the Labor Code)
1,459
409
0
0
1,868
Care leave to provide personal care or support to a
person who is a family member or resides in the
same household (5 days)
43
15
0
0
58
Percentage of employees eligible to a family reasons’ leave
Maternity, paternity, parental leave
9%
5%
0%
0%
8%
Child care leave (Article 188 of the Labor Code)
35%
18%
0%
0%
29%
Care leave to provide personal care or support to a
person who is a family member or resides in the
same household (5 days)
100%
100%
0%
0%
100%
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The percentage of eligible employees who took a family reasons’ leave
Maternity, paternity, parental leave
60%
98%
0%
0%
70%
Child care leave (Article 188 of the Labor Code)
100%
100%
0%
0%
100%
Care leave to provide personal care or support to a
person who is a family member or resides in the same
household (5 days)
1%
1%
0%
0%
1%
Employees eligible to take a leave of absence for family-related reasons:
• Individuals remaining in employment at the end of the reporting period who were on
maternity, parental or paternity leave for at least one day during the reporting period.
• Individuals remaining in employment at the end of the reporting period who declared the use
of leave for childcare (Article 188 of the Labour Code).
• Individuals remaining in employment at the end of the reporting period who were eligible to
take care leave for the personal care or support of a person who is a family member or resides
in the same household (5 days).
Employees who took a leave of absence for family-related reasons:
• Employees who completed their maternity, parental or paternity leave during the reporting
period.
• Employees who took childcare leave (Article 188 of the Labour Code) during the reporting
period (who applied for childcare leave)
• Employees who took at least 1 day of childcare leave during the reporting period for the
personal care or support of a person who is a family member or resides in the same household.
Percentage of employees eligible for family care leave is expressed as the ratio of employees eligible
for family care leave to the number of individuals in employment at the end of the reporting period.
The percentage of eligible employees who took a leave of absence for family-related reasons is
expressed as the ratio of the number of employees who took a leave of absence for family-related
reasons to the number of employees eligible to take such leave.
17.4. EMPLOYEE COMPENSATION
17.4.1. POLICIES RELATED TO EMPLOYEE COMPENSATION
[S1-1] Bank Millennium has implemented a uniform Compensation policy for employees of the Bank
Millennium Group which articulates the assumptions used to shape the fixed and variable components
of compensation for all employees in the Group while taking into account the tasks and degrees of
power assigned to the teams and units concerned.
Policies pertaining to the employee compensation area are described in more detail in section 17.1
Strategy for the workforce area.
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17.4.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] Employees have employment contracts and fixed compensation makes up a major part of their
overall compensation.
Our internal regulations ensure transparency, fairness and competitiveness in compensation. We set
clear criteria defining the rules for determining employee compensation, bonuses and fringe benefits,
enabling us to motivate our employees, build commitment and support their professional
development. Bank Millennium’s employee compensation system is aligned with sustainability
principles – we promote employee compensation that takes into consideration gender balance and
counteracts inequalities.
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.
In accordance with the Employee Compensation Policy, 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.
Moreover, in the Bank Millennium Group, we use variable employee compensation as an additional
motivational element 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 rules for
granting bonuses are defined for individual employee groups in the Rules and regulations of
performance assessment and conditions for granting bonuses.
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.
The Trade Unions active in Bank Millennium provide consultation of any changes that are introduced
to the rules governing basic salary and to bonus systems.
External consultants are not directly involved in the process to determine compensation levels,
however the Bank does analyse data from compensation reports provided by consultants from Korn
Ferry and Sedlak&Sedlak.
17.4.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] Bank Millennium has set a goal in its Strategy for 2025-2028 to maintain a competitive,
transparent and compliant employee compensation policy (for details, see section 17.1 Strategy for
the workforce area).
Ongoing progress in implementing strategic sustainability initiatives (as described in the ESG Strategy
for 2022-2024) has been monitored on a quarterly basis by the Sustainability Committee. The
managers of the substantive units are responsible for the achievement of individual goals, and they
report on the level of the goal’s achievement in their area. On this basis, a report is prepared after
each Committee meeting.
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The same monitoring model will be maintained in subsequent years, for the Strategy for 2025-2028.
Targets were set in consultation with the units involved in their pursuit.
17.4.4. ADEQUATE WAGES
[S1-10] All Bank Millennium employees receive adequate compensation.
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.
Ratio of salaries of entry-level employees to the minimum wage: 1.33.
17.4.5. COMPENSATION METRICS
[S1-16] The ratio of the annual total compensation for 2024 of the highest paid person in the
organization to the median annual total compensation of all employees (excluding the highest paid
person) is 38. The ratio of the percentage increase in annual total compensation for 2024 of the
highest paid person in the organization to the median percentage increase in annual total
compensation for all employees (excluding the highest paid person) is 59%.
The Bank analyses 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.
Gender pay gap in the Bank Millennium Group
Unadjusted
gender pay gap
Average
unadjusted pay
gap between men
and women
33,7%
The gender pay gap calculated as the difference
between the average total annual wage paid to men
and women expressed as a percentage of the
average total annual wage paid to men for the
Group. The salaries of part-time employees were
converted to full-time.
The pay gap indicator is not only used for sustainability reporting but is also reported to other
authorities (KNF, EBA). In order to maintain consistency in reporting, we have adopted a different
calculation method - converting the total remuneration per FTE using a monthly rather than an hourly
rate. The total remuneration includes both fixed and variable remuneration, i.e. basic remuneration
from engagement, bonuses, rewards, overtime, severance pay, holiday equivalents, non-cash benefits
added to income (i.e. all components included in PIT). The unadjusted gap takes into account all
employees employed at the end of the year and their total remuneration.
The difference in the average compensation of women and men 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 (74%), while men work chiefly in high technology areas (in the “technicians” category).
The Bank reviews in detail all factors that may contribute to the differences in employee
compensation between men and women.
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17.5. WORKING TIME
17.5.1. POLICIES RELATED TO WORKING TIME
[S1-1] The Bank Millennium Group has the Work Rules and Regulations in place, which establish the
organization and order of work and the related rights and duties of the employer and employees,
including issues related to working time.
The document is described in more detail in section 17.1 Strategy for the workforce area.
17.5.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] Fixed full-time working hours
97% of the Millennium Bank Group’s employees work full-time, predominantly according to a schedule
of fixed working hours. Individual work schedules and remote work are permissible on the basis of
individual contracts.
Bank Millennium Group employees are subject to one of the following working hour schedules: fixed
(the main one), shift-based, task-based, balanced, continuous. The selection of a system depends on
the type, organisation and place of work and the business requirements in a specific area.
Individual approach to the form and time of work
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.
Work in a hybrid mode
The hybrid work mode has been introduced in the Bank Millennium Group. The Bank recommends that
employees work 50% of time in the office and 50% on a remote basis, with the organizational unit
Managers being authorized to modify these proportions as the needs require in connection with the
tasks and projects in progress and the effectiveness achieved by employee teams. Such a solution
makes it possible to combine the needs of the employees with the interest of the employer.
Overtime management
In Bank Millennium, overtime is managed through the TETA system, which is available to all
employees. Registration of overtime during the reporting period is carried out in accordance with the
Polish labour law. Employees are familiarized with the rules for registering and receiving overtime
through the HR Portal on the intranet.
Bank Millennium makes every effort to ensure that employees have full knowledge of working time
rules, applicable laws and internal regulations. To this end, we arrange time management training
courses that are tailored to different groups of employees. The topics covered during such training
include:
▪ Labour Code regulations on working time, including working time standards and dimensions,
overtime and days off,
▪ Bank’s internal regulations – such as procedures for reporting overtime and vacation planning
rules,
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and the Bank Millennium S.A. Group in 2024
▪ effective work time management – techniques for planning and organizing tasks to increase
efficiency and minimize stress associated with excessive duties.
Training-related issues in Bank Millennium are described in more detail in section 17.8. Training and
development
17.5.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] Bank Millennium strives to create a friendly work environment that takes into account the
various needs of employees also in terms of their working hours, while remaining in compliance with
the Labour Code and Work Rules and Regulations. The following are the main goals we pursue to
manage our employees’ working time in a transparent and effective manner:
1. Ensure compliance with the law – the Bank ensures compliance with standards for working
hours, rest periods and overtime compensation rules.
2. Enabling flexible working time – we promote a flexible approach to the organization of
working time which enables employees to better adapt working hours to their needs (hybrid
work model, individual working time established under the provisions of the Work Rules and
Regulations)
3. Ensuring compliance with working time rules – regular monitoring and optimization of
working time to ensure that employees obtain enough rest and avoid excessive workload.
4. Developing a culture of responsible work – management is encouraged to promote
transparency and support the individual needs of employees in the organization of their
working time as part of building trust and long-term commitment of the team.
Monitoring the achievement of individual goals is supported by tools available to all employees of the
Bank, enabling their measurability and effectiveness: time and leave management system and HR
portal to report problems or questions related to the HR area.
17.6. EMPLOYEE HEALTH AND SAFETY
17.6.1. POLICIES RELATED TO EMPLOYEE HEALTH AND SAFETY
Occupational Health and Safety activities are regulated in the Instructions for managing occupational
health and safety and fire protection in Bank Millennium.
The document is described in more detail in section 17.1 Strategy for the workforce area.
17.6.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] Bank Millennium’s fundamental activity with regard to the health and safety of its employees
is the continuous provision of proper occupational health and safety conditions. The OHS 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, as well as periodic inspections of offices for compliance with fire protection and
OHS rules. In order to be able to effectively implement the requirements prescribed in the
regulations, a process has been developed at the Bank for the actions taken in this respect:
1. Periodic inspections of the state of occupational health and safety at all of the Bank’s
locations are carried out by an external company specializing in the OHS area.
2. Inspection reports are prepared and forwarded to the Bank’s Occupational Health and Safety
Office.
3. The Occupational Health and Safety Office verifies all information contained in such reports,
following which it implements the recommendations issued within the scope of its powers or
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forwards them to the relevant responsible units of the Bank that exert an impact on employee
occupational health and safety issues.
4. Each year, the Occupational Health and Safety Office prepares an annual analysis of the state
of occupational health and safety, which includes a summary of all inspections carried out
during the year and the identification of directions for improvement in the OHS area for the
whole organization.
The causes and circumstances of work-related accidents are investigated not only to fulfil insurance
obligations but also to educate and prevent any additional undesirable events (post-accident
recommendations). All new employees are familiarised with the occupational risk assessment for
individual jobs.
The key risks related to failing to observe OHS rules pertain to the possibility of employees sustaining
unfavourable health consequences (chiefly falling, getting hit, mental and physical burdens), the
ensuing absence from work and the requirement to disburse damages. The essence of the adopted
solutions is to ensure the Bank's capacity to continuously identify hazards in all areas of its business,
including those arising from cooperation with other entities, cooperation with subcontractors, and to
manage the risks associated with these hazards.
In order to minimize this risk, all newly hired employees participate in mandatory 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.
The Bank’s relevant organisational units develop and disseminate among employees the normative
acts, instructions (e.g. for the operation of equipment) and training materials necessary to perform
safe work on a dedicated internal intranet site.
The system for reporting technical defects in the form of the MSERV application, as currently being
implemented, serves the purpose of improving efficiency related to the rapid identification and direct
elimination of hazards.
During initial training in occupational health and safety, all newly hired employees are informed about
the available MSERV application on the intranet site. Each social labour inspector acting as an
employee representative is additionally notified by email from the OHS Department.
The Bank restricts cash handling in retail outlets, which significantly mitigates risks related to and
adverse effects of crime (physical and mental injuries). The low amounts of cash in the outlets and
the high risk of incarceration suppress the number of robberies. The Bank recorded no incidents of
robbery in its branches in 2024.
The Bank has adopted the Manual on physical safety and cash handling at Bank Millennium S.A.’s own
network outlets, which describes the rules related to maintaining security at the Bank’s outlets and
the cash handling process.
The Bank conducts security inspections at its outlets, focuses on maintaining the constant efficiency
of security systems (awareness programs) and provides network employees with threat warnings on
an ongoing basis.
In the rare event of a robbery at an outlet, the Bank provides support to employees in the form of
psychological and substantive assistance.
Employees are entitled to receive benefits for accidents at work and occupational diseases in
accordance with the Act of 30 October 2002 on Social Insurance for Accidents at Work and
Occupational Diseases. The health care provided to employees comprises occupational medicine
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services, including preventive healthcare examinations for employees during their working hours and
at the employer’s expense.
Consultations with employee representatives are carried out as part of regular (at least quarterly)
meetings of the Occupational Health and Safety Commission held in Bank Millennium. The
Commission’s meetings are minuted in detail and forwarded to the Director of the Human Resources
Department, who serves as the Commission’s chairperson responsible for overseeing the taking of
actions specified in the minutes. During these meetings, employee representatives submit proposals
for areas of improvement in occupational health and safety conditions. Actions resulting from the
work of the Commission that do not require significant financial expenditures or major changes in the
processes operating in the Bank are implemented on an ongoing basis by the Bank’s relevant
organizational units, while those actions that require greater financial resources and changes in the
organization are forwarded by the Director of the Human Resources Department or the Head of the
Occupational Health and Safety Office to the Management Board for approval before their
implementation.
The Bank cooperates on an ongoing basis with trade union representatives within the framework of
the OHS Committee and with Social Labour Inspectors whom it consults about OHS issues and working
conditions.
In accordance with the requirements of the Social Labour Inspection Act of 24 June 1983, in order to
improve cooperation, the employer has developed and shared with the social labour inspectors, who
work at the Bank’s various locations throughout the country, a book of comments and
recommendations in the form of an electronic application for making records. When a record is made
by a social labour inspector, the Occupational Health and Safety Office, the Human Resources
Department and the Administration Department receive notification from the application and take
immediate action – analyse and determine ways to implement the comments and recommendations
made.
17.6.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] Bank Millennium’s goals for the continuous provision of occupational health and safety
conditions for all its employees derive directly from the Labour Code and the needs reported by
employees in this regard. In order to effectively manage them, Bank Millennium has implemented an
internal document, Instructions for managing occupational health and safety and fire protection in
Bank Millennium, in which they are included as a permanent component of the Bank’s operations. In
accordance with its provisions, the Bank, as an organizational unit hiring employees, takes into
account in its activities the needs of all employees in ensuring safe and healthy working conditions
and fire protection, including by:
1) supervising compliance with the rules and regulations pertaining to occupational health and safety
and fire protection,
2) taking into account in the development programs of the Bank’s organizational units the
improvement of occupational health and safety conditions and fire protection,
3) ensuring that the planned tasks are determined while taking into account the requirements of
occupational health and safety and fire protection,
4) controlling and evaluating the status of implementation of tasks in the field of occupational health
and safety and fire protection in the Bank’s units, and determining the directions for improvement of
this status.
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Monitoring of the achievement of individual goals is supported by the Bank's established process for
monitoring the health and safety status of all Bank's location units, as well as dedicated tools available
to all Bank’s employees for measurability and effectiveness, such as: HR portal for reporting problems
or questions related to the HR area, and a system for reporting technical problems in the workplace.
17.6.4. OCCUPATIONAL HEALTH AND SAFETY METRICS
[S1-14] In the Bank Millennium Group, the occupational health and safety management system based
on legal requirements or recognized standards or guidelines covers 100% of employees.
Accidents at work in the Bank Millennium Group
4
Number of people
Females
Males
Other
Not
reported
Total
Number of incidents involving work-related injuries
18
11
0
0
29
Number of days of absence related to work-related
injury incidents
354
191
0
0
545
Accident rate (occurrence of accidents)
5
0,0004%
0,0005%
0
0
0,0004%
Accident severity rate
6
39
32
0
0
71
Number of cases of work-related poor health
0
0
0
0
0
Number of fatal accidents
0
0
0
0
0
Accidents at work in Bank Millennium
7
Number of people
Females
Males
Other
Not
reported
Total
Number of incidents involving work-related injuries
17
11
0
0
28
Number of days of absence related to work-related
injury incidents
315
191
0
0
506
Accident rate (occurrence of accidents)8
0,0004%
0,0005%
0
0
0,0004%
Accident severity rate
9
39
32
0
0
71
Number of cases of work-related poor health
0
0
0
0
0
Number of fatal accidents
0
0
0
0
0
17.7. PROMOTING DIVERSITY AND EQUAL EMPLOYEE COMPENSATION
4
The number of work-related injury incidents consists of accidents at work, accidents treated as equivalent to accidents at work and accidents
on the way to or from work.
5
A different method has been adopted for calculating the accident rate, which, in the Bank's opinion, is more transparent and clear for the
recipient. According to the adopted methodology, the accident rate is the number of injured persons per 1000 workers.
6
Accident severity rate: this is the number of days of incapacity for work in relation to the number of accidents at work, i.e. the quotient of
the number of days of incapacity for work caused by accidents at work by the number of accidents at work.
7
The number of work-related injury incidents consists of accidents at work, accidents treated as equivalent to accidents at work and accidents
on the way to or from work.
8
A different method has been adopted for calculating the accident rate, which, in the Bank's opinion, is more transparent and clear for the
recipient. According to the adopted methodology, the accident rate is the number of injured persons per 1000 workers.
9
Accident severity rate: this is the number of days of incapacity for work in relation to the number of accidents at work, i.e. the quotient of
the number of days of incapacity for work caused by accidents at work by the number of accidents at work.
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17.7.1. POLICIES RELATED TO EMPLOYEE COMPENSATION AND DIVERSITY
[S1-1] Bank Millennium has implemented a uniform Compensation policy for employees of the Bank
Millennium Group which provides a formal framework for shaping the Group’s employee compensation
practices with respect for dignity and against discrimination.
Issues related to the gender-neutrality of employee compensation principles and the goals set in this
respect are included in the Diversity Policy in the Bank Millennium Group.
Moreover, issues related to respecting diversity in the Bank’s Group are also governed by the Work
Rules and Regulations, the Code of Ethics and the Human Rights Compliance Policy.
These documents are described in more detail in section 17.1 Strategy for the workforce area.
17.7.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] The Bank Millennium Group implements the principles of respecting and honouring diversity,
including ensuring equal compensation for all employees through taking measures such as:
1. Formal framework for shaping the practice of compensating all employees of the Group –
regardless of their position or level of responsibility, always taking into account the values of
unqualified respect for human dignity and diversity, with zero tolerance for any form of
discrimination. The only criteria affecting employee compensation and access to specific
positions involve the employee’s competence and performance. Employee compensation is
defined in accordance with function, career and degree of achievement of established goals,
promoting a 1:1 pay ratio between men and women holding comparable functions and having
similar levels of responsibility and career progression.
2. Adhering to the Human Rights Compliance Policy and Work Rules and Regulations, according to
which employees in Bank Millennium are not allowed to engage in any discriminatory practices,
direct or indirect, against any other employee. We promote a culture of tolerance and reject
all forms of discrimination based on origin, gender, sexual orientation, family situation,
nationality, ethnicity, religion, membership in social groups and political beliefs, or any kind of
individual physical characteristics, health conditions or disabilities.
The right to equality applies in particular to:
• Selection criteria and conditions of employment.
• Opportunities for professional development, access to training and opportunities to
change the unit in which the employee works, including for the purposes of gaining
practical experience.
• Salary and other financial benefits, promotion to all levels of organizational hierarchy;
• Membership in collective representation structures or in any organization whose
members practice a specific profession (for example, associations, chambers of legal
counsel).
3. During employee recruitment, the Bank does not apply criteria putting one in jeopardy of
discriminatory behaviour. 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. Employees must refrain from making decisions on the basis of
discriminatory criteria that will affect another person’s access to a job, promotion, salary or
any other work-related decision, or those that create an intimidating, hostile or humiliating
work environment.
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and the Bank Millennium S.A. Group in 2024
4. Mandatory training for all employees on the Bank’s Code of Ethics, which prohibits any form of
discrimination. During training, managers are taught how to manage diverse teams. Training is
an important part of developing the right attitudes – also to overcome stereotypes and promote
openness to employees’ various convictions and mould their own responsibility and that of their
reports.
5. We have launched the Diversity is OK! Initiative to educate employees, promote mutual
understanding, raise awareness of the importance of synergy in teams, and build skills to
influence the development of teams through effective communication and collaboration among
employees. The purpose of the initiative is to demonstrate that differences can unite and bring
tangible benefits. We want to make sure that every person in the organization feels important
and valued. To reach as many employees as possible, we host regular webinars that can be
viewed live or listened to on the Cornerstone training platform. So far, we have covered topics
such as gender equality, body positivity, the pay gap, communicating in multigenerational
teams, as well “she and he in business – the synergy effect, and feminatives”.
6. Bank Millennium 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.
17.7.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] The Bank’s strategy for 2025-2028 also includes goals related to promoting diversity, equality
and inclusion in our business activities. In pursuit of the objective formulated as Further developing
compensation policies aligned with ESG and transparency standards, the Bank will strive to ensure
the highest standards required in this respect for all Group employees.
Ongoing progress in implementing strategic sustainability initiatives (as described in the ESG Strategy
for 2022-2024) has been monitored on a quarterly basis by the Sustainability Committee. The
managers of the substantive units are responsible for the achievement of individual goals, and they
report on the level of the goal’s achievement in their area. On this basis, a report is prepared after
each Committee meeting.
The same monitoring model will be maintained in subsequent years, for the Strategy for 2025-2028.
Targets were set in consultation with the units involved in their pursuit.
17.7.4. DIVERSITY METRICS
[S1-9] Senior management – positions of Key Director, Senior Director and Director. Management –
other managerial positions. Data are provided for the Group in total and for the Bank individually, in
persons.
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and the Bank Millennium S.A. Group in 2024
Employment structure by age in Bank Millennium Group
Number of
people
<30
years
old
%
30-50
years
old
%
>50
years
old
%
Total
%
Board of directors
0
0%
0
0%
7
100%
7
100%
Senior management
0
0%
53
46%
63
54%
116
100%
Management
30
3%
687
76%
189
21%
906
100%
Sales employees
1,004
29%
2,080
61%
322
9%
3,406
100%
Technical employees
288
12%
1,552
67%
472
20%
2,312
100%
Other employees
2
2%
53
60%
34
38%
89
100%
Total
1,324
19%
4,425
65%
1,087
16%
6,836
100%
Employment structure by age in Bank Millennium
Number of
people
<30
years
old
%
30-50
years
old
%
>50
years
old
%
Total
%
Board of directors
0
0%
0
0%
7
100%
7
100%
Senior management
0
0%
48
48%
51
52%
99
100%
Management
30
4%
645
76%
169
20%
844
100%
Sales employees
1,003
30%
2,041
61%
312
9%
3,356
100%
Technical employees
266
13%
1,399
67%
424
20%
2,089
100%
Other employees
2
3%
48
60%
30
38%
80
100%
Total
1,301
20%
4,181
65%
993
15%
6,475
100%
Employment structure by gender in Bank Millennium Group
Number of people
Females
%
Males
%
Total
%
Board of directors
0
0%
7
100%
7
100%
Senior management
39
34%
77
66%
116
100%
Management
516
57%
390
43%
906
100%
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Number of people
Females
%
Males
%
Total
%
Sales employees
2,510
74%
896
26%
3,406
100%
Technical employees
1,307
57%
1,005
43%
2,312
100%
Other employees
45
51%
44
49%
89
100%
Total
4,417
65%
2,419
35%
6,836
100%
Employment structure by gender in Bank Millennium
Number of people
Females
%
Males
%
Total
%
Board of directors
0
0%
7
100%
7
100%
Senior management
35
35%
64
65%
99
100%
Management
475
56%
369
44%
844
100%
Sales employees
2,481
74%
875
26%
3,356
100%
Technical employees
1,175
56%
914
44%
2,089
100%
Other employees
40
50%
40
50%
80
100%
Total
4,206
65%
2,269
35%
6,475
100%
17.8. TRAINING AND DEVELOPMENT
17.8.1. POLICIES RELATED TO TRAINING AND DEVELOPMENT
[S1-1] The Bank Millennium Group has put in place the Work Rules and Regulations that guarantee all
Bank employees the opportunity for professional development through participation in courses and
training. The issue of training is also governed by the HR Policy, which includes our main objectives
in the area of training and development for the Bank’s employees as well as the actions we are
implementing to achieve them. The rules for employee participation in training are governed by the
Instructions for participation in training programs at Bank Millennium S.A.
These documents are described in more detail in section 17.1 Strategy for the workforce area.
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and the Bank Millennium S.A. Group in 2024
17.8.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] Training in Bank Millennium is a major part of daily activity and is treated as an investment in
human capital and as activities that boost the professional development of employees. With this in
mind, our activities in this respect include such components as:
▪ Continuous improvement of our training programs and training offerings to be in line with
the latest trends and best market practices.
▪ Building employee engagement by investing in their professional development.
▪ Offering a broad range of training programs that range from technical training to soft skills
training.
▪ Using an e-learning platform to enable employees to learn at a time and place of their
choosing.
▪ Enabling the Bank’s employees to participate annually in external and internal training,
conferences and congresses.
▪ Implementing the majority of training in remote or hybrid arrangements convenient for
employees. Some of the training has been delivered in the form of e-learning. If the subject
matter of the training requires it, it may also be held in a traditional, stationary format.
Scope of training offered to Bank employees
Introductory training for new employees of Bank Millennium Group was conducted remotely using MS
Teams software and on-site. Webinars with trainers are interspersed with in-branch practice, e-
learning training and in-house work.
Millennium Campus
This is 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 via the intranet
under the World of Millennium.
Development Fridays
The program aims at enabling the exchange of knowledge and experience among the Bank's
employees. Speakers include specialists who share their knowledge and experience through lectures.
The offer to participate in this program is addressed to all of the Bank’s employees. Lectures are held
online, while recordings and aids are made available on the training platform and via the intranet
under the World of Millennium.
External training platforms
Youniversity
Youniversity is a website providing access to the knowledge and experience of the best trainers from
Poland and abroad. It is a unique content ensuring development both in business and in private life.
It makes it possible for Managers to develop their competences through the use of a streaming service
and knowledge from over 57 thematic areas. New series and video courses are launched even a few
times a month. This allows managers to build a regular development routine.
Coach Hub platform
CoachHub is a coaching platform available to our key managers and regional directors from the retail
and corporate network.
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and the Bank Millennium S.A. Group in 2024
Through one-on-one meetings, the coachee identifies and selects areas for development and then
achieves their goals with the help of a certified coach.
The program is carried out online. This allows its participants to develop anywhere and at their
preferred time.
EU DORA Regulation – training for board members and employees of financial institutions
In connection with the EU DORA Regulation, which came into force on 17 January 2025, mandatory
training was prepared for board members and employees of companies defined as financial
institutions. In cooperation with an external provider, the following was prepared:
• online webinars for management board members,
• e-learning – broken down into an advanced module (for IT employees) and a basic module (for
non-IT employees).
Management programs
Manager Certification – a training program for the managers of retail outlets in the Bank’s own
network. 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.
Development training for heads of retail outlets – a training program supporting managers in the
continuation of development of their skills. In 2024, we implemented training courses on the income
model, managing a multi-generational team, managing one’s use of time, and knowledge of
motivators and how to recognize them. Regional Directors of the Retail Banking Department also
participated in development training.
M#leaders
In 2024, the Bank completed another edition of the M#leaders leadership skills improvement program.
This year’s edition of the program was addressed to persons holding managerial positions in the head
office and in the Bank's companies.
Training in the form of webinars under the Me Zone initiative
We are committed to ensuring that individuals employed in Bank Millennium, in their active
professional lives, take care of their own mental resilience and well-being. This is why we have
created the Me Zone to reduce stress and improve the well-being of our employees, increase their
productivity and creativity, help them better cope with the challenges of everyday life, discover their
potential and help them develop in the chosen direction. Every person employed in our organization
may participate in webinars on dealing with stress, emotions, managing one’s own energy, ways to
relax, taking care of the mental state of women and men and reconciling social roles. Moreover, we
are building employees’ health awareness and organizing activities in the form of a Week for Health
and Cancer Prevention, which includes thematic webinars, stationary and online exercises, and the
opportunity to obtain vouchers for preventive medical check-ups.
ESG training
In 2024, a training course was conducted in the form of a webinar for all employees, covering issues
related to the ESG area. During the training, participants learned about basic ESG issues, the impact
of sustainability on the financial sector, and the most significant EU sustainability regulations. The
training also covered issues related to sustainable financing, the greenwashing phenomenon and
greenhouse gas emissions.
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and the Bank Millennium S.A. Group in 2024
Green Academy
The Green Academy is a proprietary development program for corporate banking advisors, which aims
to enhance the relationship managers’ competence in green investment financing and broadly defined
ESG issues. The goal of the program was also to support the development of the green financing
portfolio, including investment financing, in line with the bank’s ESG strategy. The Green Academy
program is one of the elements enabling the Bank to achieve its sustainability goals. Knowledge and
competencies in business-relevant areas of sustainability from a business perspective make it possible
to actively support companies in the implementation of green investments. This enables them to
implement and develop their long-term transitional strategies with significant participation from the
Bank.
Comprehensive training is also regularly provided to specific groups of employees across all business
lines, for instance:
• Training for branch and franchise network employees
• Training for Direct Banking Department employees
• Training for Corporate Banking Department employees
• Training for employees selling insurance products
• Development training for Regional Directors
• Training for the Affluent Client Banking Department
17.8.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] In its operations, Bank Millennium strives to enhance the competences of employees, which
translates into improving quality and work productivity and achieving current and future business
objectives. Bank Millennium’s key objectives in the training area are specified in the HR Policy, they
are:
• Improving qualifications: We provide employees with access to training and development
programs that will enable them to acquire new skills and knowledge.
• Increasing engagement: We build employee engagement by investing in their professional
development.
• Preparing for future challenges: We support the development of the Bank Millennium Group
by preparing employees for taking more responsible roles and acquiring competencies for the
future.
In the Strategy for 2025-2028, the Bank established the goal of Aligning the talent acquisition and
development plan with the organization’s key strategic objectives, within which it set out to provide
an attractive development offer for employees in strategic areas and to update the onboarding
process. The Bank has also adopted the goal of continuing to build a culture of continuous learning.
Ongoing progress in implementing strategic sustainability initiatives (as described in the ESG Strategy
for 2022-2024) has been monitored on a quarterly basis by the Sustainability Committee. The
managers of the substantive units are responsible for the achievement of individual goals, and they
report on the level of the goal’s achievement in their area. On this basis, a report is prepared after
each Committee meeting. The same monitoring model will be maintained in subsequent years, for
the Strategy for 2025-2028.
Targets were set in consultation with the units involved in their pursuit.
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and the Bank Millennium S.A. Group in 2024
17.8.4. TRAINING AND SKILLS DEVELOPMENT METRICS
Employees of the Bank Millennium participating in the evaluation - gender breakdown
Percentage of active employees
participating in the evaluation by
gender
Females
%
Males
%
Total
%
Rated
3 985
98,13%
2 319
97,60%
6 304
97,93%
Not rated
76
1,87%
57
2,40%
133
2,07%
Total
4 061
100%
2 376
100%
6 437
100%
In Bank Millennium, all employees are subject to periodic performance evaluations. Depending on the
group and the tasks performed, employees are evaluated on a monthly, quarterly or semi-annual
basis. In order to be included in a given evaluation process, an employee must meet the requirements
specified in the internal regulations regarding minimum seniority and working time in the period under
evaluation. Approximately 98% of employees participate in cyclical evaluation processes (excluding
employees who do not meet the indicated requirements).
The Bank determines the percentage of employees participating in the evaluation based on a sample
consisting of a verification of the inclusion in the evaluation carried out in the last quarter of the year
for each employee employed under an employment contract in the Millennium Bank Group in the last
quarter of the year. Employees who are on long-term leave and who worked less than 15 days in the
last quarter of the year are excluded from the survey. Employees who are employed by more than
one company in the Bank Millennium Group are included in the survey at the company where they
work the most.
Average number of training hours by employees gender
Average number of training hours by gender
Females
58,9
Males
46,8
Total
106
Data refers to persons employed in Bank Millennium S.A. on a full-time basis as of 31 of December 2024.
17.9. COUNTERING VIOLATIONS IN THE WORKPLACE
17.9.1. POLICIES RELATED TO COUNTERING VIOLATIONS
[S1-1] In the Bank Millennium Group, the use of any discriminatory practices with features of bullying
or harassment in relation to employees is prohibited. The main documents that define the rights and
obligations of employees and standards regarding these issues are the Code of Ethics and the Work
Rules and Regulations.
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and the Bank Millennium S.A. Group in 2024
The process of reporting employee-related violations in the Bank is governed by the Procedure for
dealing with reports from employees, including those suggesting bullying or discrimination in Bank
Millennium S.A. and the Bank Millennium S.A. Whistleblower Manual.
These documents are described in more detail in section 17.1 Strategy for the workforce area.
17.9.2. ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] In order to ensure compliance with ethical principles and prevent violations, we conduct the
following activities:
1. Code of Ethics – lays down our ethical principles. Newly hired employees are required to
familiarize themselves with the contents of the Code of Ethics and sign a statement of knowledge
of the principles contained in the Code and their application.
2. Ethics Officer – the function of the Ethics Officer is exercised by the head of the Compliance
Department. The Ethics Officer’s responsibilities include safeguarding compliance with the Code
of Ethics by Bank employees, promoting and disseminating information about ethical standards,
ordering inspections of compliance with ethical principles and verifying cases of their breach.
3. Ethics training system – a dedicated e-learning course Code of Ethics has been prepared for all
Bank employees. Every new employee is required to undergo it. Moreover, every employee is
required to participate in refresher training, conducted annually.
4. Communication with employees – informing employees of all changes in the ethics area – the Code
of Ethics is posted on an intranet site accessible by all Bank employees.
5. Breach reporting system – upon discovery or reasonable suspicion of a breach by another employee
of the law, applicable procedures or the Code of Ethics, each employee is required to promptly
report such discovery to: naruszenia@bankmillennium.pl
6. Rules of ethics compliance monitoring system – the Compliance Department at least annually
assesses the risks associated with ethics violations in the Bank. A report from the assessment is
drafted and 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 Bank Millennium Supervisory Board about the results of the assessment.
17.9.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] Bank Millennium is an employer that, in its relations with its employees, is guided primarily by
ethical principles and acts in accordance with generally applicable laws and internal regulations. In
the Bank Millennium Group Strategy for 2025-2028, we have focused, among other aspects, on caring
for the well-being of our employees, including through the promotion of diversity and equality.
Included in this objective are the measures implemented by the Bank to prevent any discriminatory
practices against our employees, as described in section 17.9.2 Actions taken to implement policies
and section 17.9.4 Processes for remediation of negative impacts and channels for reporting
violations.
Ongoing progress in implementing strategic sustainability initiatives (as described in the ESG Strategy
for 2022-2024) has been monitored on a quarterly basis by the Sustainability Committee. The
managers of the substantive units are responsible for the achievement of individual goals, and they
report on the level of the goal’s achievement in their area. On this basis, a report is prepared after
each Committee meeting.
The same monitoring model will be maintained in subsequent years, for the Strategy for 2025-2028.
Targets were set in consultation with the units involved in their pursuit.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
17.9.4. PROCESSES FOR REMEDIATION OF NEGATIVE IMPACTS AND CHANNELS
FOR REPORTING VIOLATIONS
[S1-3] A Communication from the Director of the Human Resources Department was addressed to all
Bank Millennium employees on the introduction of the Procedure for dealing with reports from
employees, including those suggesting bullying or discrimination. The procedure specifies in detail
how an employee may submit a report and how the investigation proceeds.
Any employee in possession of information or a reasonable suspicion of a breach of the law, applicable
policies, procedures or provisions of the Bank Millennium Group’s Code of Ethics is required to report
such information promptly through any of the dedicated reporting channels.
The report may be sent by email to: NARUSZENIA@BANKMILLENNIUM.PL or directly to the Director of
the Human Resources Department. The report may be sent from the company’s mailbox or
anonymously from an external domain or may be placed personally by the employee in a special HR
correspondence box (located in the Bank), or sent by mail.
The HR Department maintains a register in which all reports of violations are recorded. They are
reported to the Process and Operational Risk Committee. The processing of a report is carried out on
the basis of a procedure that describes the detailed course of analysis of such reports.
The investigative activities carried out are mainly individual interviews, conversations and anonymous
questionnaires conducted with the employee group in question. If bullying or discrimination is
confirmed, the Bank implements adequate measures, to be reviewed and verified as part of internal
management processes.
A summary of the steps taken and explanations carried out is documented and presented in the form
of a report to the Management Board Member overseeing the affected unit, the President of the
Management Board and the Director of the Compliance Department.
There is also a separate place on the Bank’s intranet site with detailed information for employees on
countering bullying behaviours:
• what actions not to take,
• how to respond to behaviour that may constitute workplace bullying,
• how to prevent bullying from occurring.
Bank Millennium also provides employees with opportunities to bring up inquiries, concerns and
complaints regarding:
• ethical issues – to the Ethics Officer,
• conflicts of interest – to a specially designated function box,
• anti-corruption – to a specially designated function box,
• employees’ own transactions in financial instruments – to a specially designated function
box.
We ensure anonymous channels for submitting reports, the confidentiality of all whistleblowing
reports and refrain from taking any action against anyone who, in good faith, reports information
regarding potential breaches of the law and/or adopted policies, procedures or the Code of Ethics,
or who participates in the procedure for reviewing whistleblowing reports.
These measures ensure that inquiries, concerns and reports received through all designated channels
are addressed and employees receive their responses.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
The Bank has internal communication systems in place to provide employees with real-time, up-to-
date information and allow them to access the information they need to perform their professional
duties and exercise their employee rights. We also enable employees to present their own information
and opinions through internal and external channels.
On an ongoing basis, we also cooperate with trade unions, with which (in the event that an employee
provides them with information about their report) we discuss the outcomes of the investigation.
[S1-17] In 2024, the Bank did not identify any work-related complaints or incidents of discrimination,
including harassment. Accordingly, it was not required to pay any fines, penalties or compensation
for damages resulting from such complaints or violations. Nor did the Bank record any incidents of
human rights violations (such as forced labour or child labour). No sanctions, fines or damages related
to human rights violations were imposed on the Bank.
17.10. PRIVACY
17.10.1. POLICIES RELATED TO PRIVACY
[S1-1] With regard to privacy, the Bank operates on the basis of the Personal data security policy in
Bank Millennium S.A., which describes the general rules regarding the protection of data processed
by the Bank. The purpose of the Policy is to define the rules for processing personal data in compliance
with the requirements of the applicable legal regulations on personal data protection.
An internal document entitled Instructions for processing personal data in Bank Millennium S.A. has
been implemented for employees hired by the Bank under an employment contract. The document is
intended to provide information and explain the principles adopted in Bank Millennium for processing
employees’ personal data.
The document contains detailed information on the purposes and duration of the employer’s
processing of employees’ personal data and the rights of employees related to the processing of their
personal data. The scope of the information provided corresponds to the requirements under EU data
protection legislation, i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council
(hereinafter: “Regulation”).
These documents are described in more detail in section 17.1 Strategy for the workforce area.
17.10.2. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES ACTIONS TAKEN TO IMPLEMENT POLICY OBJECTIVES
[S1-4] Ensuring the privacy of employee data is an important factor in a safe working environment.
To this end, we implement the following measures (among others): conducting annual reviews and
necessary updates of the Policy, testing and evaluating the effectiveness of the technical and
organizational measures implemented and providing periodic training on data privacy. The training
Personal data protection is intended for all Bank’s employees. It is a compulsory cyclical training
repeated once a year. The Personal Data Inspector supervises the implementation of this training.
The degree of implementation of this training by Bank’s employees is monitored.
Moreover, we have adopted a process for dealing with data protection violations, where the basic
principle is to respond promptly and to treat each incident with special care.
We provide all employees with a channel for reporting violations: abuse@bankmillennium.pl.
Furthermore, any employee may contact the Data Protection Officer on all matters related to the
processing of their data via a designated email address.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Information on the principles of personal data processing and privacy policy have been uploaded to
our official Bank Millennium website at www.bankmillennium.pl/ochrona-danych
17.10.3. OBJECTIVES RELATED TO THE IMPLEMENTATION OF POLICIES AND
ACTIVITIES
[S1-5] The Bank’s goal in implementing the objectives adopted in the Policy is to ensure data security.
All information provided by our employees is protected using state-of-the-art technologies, in
accordance with applicable legal standards, security requirements and confidentiality rules.
Monitoring the achievement of individual goals is supported by tools available to all employees of the
Bank, enabling their measurability and effectiveness, including: dedicated channel for reporting
violations, a system for handling training, and an HR portal for reporting problems or questions related
to the HR area.
The activities and goals for protecting employee privacy are the same as those covering Customers,
which is described in more detail in Section 19.5 Privacy.
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Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
18. WORKERS OF THE BANK MILLENNIUM GROUP’S VALUE CHAIN
(ESRS S2)
18.1. STRATEGY
[SBM-3] The Bank cooperates with many business partners, which specifically include franchisees,
brokers and suppliers of goods and services. The cooperation between the Bank Millennium Group
Companies and their business partners is regulated primarily by agency agreements (mainly for
franchisees). Agency agreements are concluded with business entities independent of the Bank, which
act on behalf of and for the account of the Bank based on powers of attorney granted by the Bank.
The Group also cooperates with brokers to whom it entrusts activities connected with intermediacy
in the sales of mortgage and leasing products (since 2021) based on agency agreements which are
usually outsourcing agreements. As for suppliers of goods and services, the key business partners
render services associated with the lease of and support for branches and office space, services and
purchase of IT equipment as well as security and marketing services.
In connection with a significant scale of cooperation with business partners, two material positive
impacts have been identified. Both material positive impacts concern working conditions for
employees in the value chain. Bank Millennium Group has not identified any adverse impacts or risks
and opportunities related to persons working in the Bank Millennium Group’s value chain, particularly
to employees of: franchisees operating on behalf of the Bank Millennium Group, suppliers of goods
and services and brokers cooperating with the Bank. We assess the impacts as positive and they follow
from the requirements regarding human rights and workers' rights, which are conditions for
cooperating with the Bank Millennium Group and also values guiding us in our activity and the adopted
business model. Both the Strategy adopted for 2022-2024 and the newest Strategy for 2025-2028 do
not refer to identified impacts in the process of double materiality analysis. In the year of the double
materiality analysis, the Bank did not identify material risks and opportunities relating to persons
working in the value chain.
[SBM-3] [S2-4] The Bank takes a number of measures aiming to achieve material positive impacts on
persons working in the value chain. The measures taken include i.a. access to a number of training
courses or standards of outlets as work establishments are the same as for employees in our own
branches and franchises. Details of performed measures and the way to track and assess their
effectiveness are presented in Chapter 17. Bank Millennium Group employees (ESRS S1). In case of
our remaining business partners (i.e. brokers and suppliers), we mainly require them to sign and
comply with the rules found in the Sustainability Guidelines for Suppliers.
[SBM-3] Among persons working in the value chain on whom we exert positive impact, we may
distinguish employees working for entities in the entity’s value chain at a lower level (franchisees and
brokers).
The Bank has 242 partner outlets throughout the territory of Poland, where a total of 870 people
work, including - 169 people acting as managers of the outlets, and 143 people representing
franchisees (business entities cooperating with the Bank). 49% employees are women. 87% outlets are
located in towns with population below 50 thousand inhabitants, due to which employees may be
recruited from the local labour market.
The Group purchases goods and services primarily from domestic suppliers (according to the data
concerning issued invoices), operating in the same legal and ethical system as the Bank, i.e. they are
obliged to, among others, compliance with employment principles provided for in the Labour Code.
[SBM-2] A description of the impact of interests, views and rights of persons working in the value
chain on the Bank’s strategy and business model is described in sub-chapter 15.3.2. Key
stakeholders.
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18.2. MANAGEMENT OF IMPACTS, RISKS AND OPPORTUNITIES
[S2-1] All business partners are obliged to adhere to the Code of Ethics of the Bank Millennium Group,
which includes a number of principles regarding human rights and workers' rights in compliance with
the UN Universal Declaration of Human Rights, addressing, among others, issues of human trafficking,
forced or compulsory labour and child labour. The issues of respecting human rights are also described
in the Diversity Policy as well as in anti-discrimination and anti-harassment procedures. These
documents are described in more detail in section 17.1. Strategy for the workforce area (ESRS S1-1).
The condition follows from the endeavour to consolidate the policies across the value chain of the
Bank Millennium Group with respect to all individuals cooperating with us. The group of stakeholders
for whom it is especially important to observe ethical principles are employees of our franchise
(partner) outlets, which are an important distribution channel for products offered by the Bank.
Because of the lack of appropriate tools, the Bank does not monitor the compliance with the principles
following from the above documents by business partners.
Our franchisees are bound by provisions of the Code of Ethics of the Bank Millennium Group, which
the agency agreement explicitly refers to, granting it the status of the so called “internal regulation”,
which the franchisee is obliged to comply with. To supplement the Code of Ethics, in the franchise
model used by the Bank, there is an absolute rule that each person employed by a franchisee and
authorized to act on behalf of Bank Millennium must have an employment contract, which entails the
necessity to apply provisions of the Labour Code to such employees. Franchisees, on the other hand,
as entrepreneurs are tied directly to the Bank by the agency agreement.
The Bank decided to introduce such a solution for several reasons, which include:
• ensuring observance of the Banking Law with regard to sub-outsourcing,
• ensuring utmost protection of employees of franchise branches as provided for in the Labour
Code,
• ensuring a uniform approach to responsibility and risk management of anyone acting on behalf
of the Bank.
The Code of Ethics is described in detail in Chapter 20. Business Conduct (ESRS G1).
[S2-1] The rules of cooperation with suppliers of Bank Millennium are described in the Instructions
for the selection of suppliers for procurement and outsourcing, which was adopted by a Management
Note of the Deputy Chairman of the Bank Millennium S.A. Management Board. These instructions
define, among other things, how the procurement process is organized, the roles 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.
Monitoring the correct compliance with the Instructions for the selection of suppliers for
procurement and outsourcing is part of the tasks of the Internal Audit Department.
The Bank’s suppliers selected in tenders (regardless of the geographical location of the entity’s
registered office) are obliged to adhere to not only the requirements of the Code of Ethics of the
Bank Millennium Group but also to accept the ESG principles (Sustainability Guidelines for Suppliers)
including also compliance with law; compliance with human rights and workers' rights; prevention,
health and security for employees; environmental protection; improvement of management process.
Acceptance of the above issues is required already at the stage of entering tenders by signing a
relevant statement by the supplier, which is supervised by the Central Procurement Department.
Sustainability Guidelines for Suppliers have been accepted by the Bank’s Management Board Member,
and it is the Central Procurement Department which is responsible for their implementation in Bank.
The responsibility for reviews of the document, carried out every two years, and for updating it rests
with the Sustainability Department, in cooperation with the Central Procurement Department. The
Bank does not monitor the observance of the principles described in the guidelines by external
partners because of the lack of tools in this regard.
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Furthermore, our suppliers are encouraged to provide additional information using an ESG survey and
undertake to cooperate with Bank in providing information making it possible to assess the conformity
of the processes with the above principles by verification measures, including survey interviews or
visits to the place where business activity is conducted. To prove the assumed obligations to
implement the above principles, suppliers:
• shall develop a code of conduct binding employees,
• may prepare a sustainability policy,
• shall provide information about sustainability (e.g. initiatives implemented in the
environmental or social areas) internally or outside of the company.
The undertaking of our suppliers to adhere to Sustainability Guidelines for Suppliers and the Code of
Ethics implemented in the entire Millennium Group is an important element of the Bank’s
procurement regulations aimed to make the Bank’s impact in the whole value chain more coherent
and to prevent potential adverse impacts on any employees engaged in the Bank’s activity.
[S2-2] As at 31 December 2024, the Bank did not implement a general cooperation procedure for
people working in the value chain.
[S2-3] The Bank, while promoting ethical values and establishing processes allowing for minimizing
adverse impacts, provides employees (also those employed by franchisees, or people working in the
value chain) as well as suppliers and brokers with the opportunity to report violations of ethical
standards by email or by traditional mail (also anonymously). Whenever an irregularity is discovered
in the business conduct of the Bank’s employees (other than Management Board Members), it may be
reported by e-mail to a dedicated address or by a letter sent directly to the President of the Bank’s
Management Board (this channel ensures the whistleblower’s anonymity). As regards the
identification of irregularities in the business conduct of the Bank’s Management Board Members or
Supervisory Board Members, the respective report should be made by letter directly to the Chairman
of the Audit Committee of the Bank’s Supervisory Board. Details can be found in Chapter 20. Business
Conduct, in sub-chapter 20.3. Whistleblower reporting and protection. The Bank provides franchise
employees with Reporting Violations at Bank Millennium training, which is repeated annually. The
Bank does not assess and monitor whether workers in the value chain trust the process described
above as a system for reporting, resolving and addressing their concerns and needs.
[S2-4] The requirements imposed by us to adhere to the Code of Ethics of the Millennium Group both
by our franchisees and suppliers are aimed to ensure for all individuals working in the Bank’s value
chain that their employers’ conduct complies with law and the best practices of ethical conduct. The
attitudes promoted by us include:
• zero tolerance for violations of human rights of any kind, prohibiting any form of harassment,
discrimination, coercion, abuse, violence or exploitation in the area of impact;
• respecting workers' rights, prohibiting the use of forced or child labour, and providing fair and
just remuneration, guaranteeing equal opportunities and a balance between work, family and
personal life in a work environment free of discrimination, harassment, threats and physical
or psychological aggression; providing regular training for its employees;
• identifying, monitoring and preventing hazards to avoid occupational accidents and diseases,
encouraging behaviour that promotes employees' physical and mental well-being and safety,
including the provision of appropriate protective measures and training.
The above activities will be continued in the future as well.
The documents adopted in the Bank Millennium Group, describing sustainability principles (including
the Human Rights Policy, Diversity Policy, Sustainability Guidelines for Suppliers) are made available
all the time in the ESG tab on the Bank’s website. Due to the above, the Bank’s business partners may
familiarize themselves with possible amendments introduced to currently binding policies. For the
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Bank’s employees, including employees of franchise partners, information campaigns are conducted
to make them remember the prevailing principles in the area and inform them about changes to the
regulations. The latest information campaign about current sustainability principles took place in
December 2024 with an article published in the corporate intranet Świat Millennium [World of
Millennium].
[S2-4] Our suppliers undertake to cooperate in providing information making it possible to assess the
conformity of the compliance with the above principles by verification measures – responses to surveys
(to the Central Procurement Department) or visits to the place where the business activity is
conducted.
Sustainability surveys for suppliers include questions about the company's ESG efforts:
• does the company have a Sustainability Policy and communicate it to its employees,
• does the company provide sustainability information internally to its employees or outside of
the company,
• does the company have a Code of conduct binding its employees,
• does the company have environmental or social responsibility certificates.
The received surveys are delivered to the Sustainability Department.
[S2-4] The Department which is responsible for supporting our franchise partners, including ensuring
the compliance with relevant standards is the Retail Banking Department - Franchise and Instalment
Sales, which consists of the Franchise Outlet Support Division and the Hire-Purchase Division. In
addition, there is a team of Regional Directors, located in 3 Regions, managed by 3 Macroregional
Directors. The total number of employees in the Department is 35, of which 31 are directly responsible
for managing and supporting the franchise network.
Relations with suppliers are the area of responsibility of the Central Procurement Department.
Responsibility for cooperation with our leasing brokers rests with the structures of Millennium Leasing
Sp. z o.o. On the other hand, relations with brokers of mortgage loans are supervised by the Retail
Banking Marketing Department.
Management of material impacts on people working in the value chain is carried out within ongoing
operating activity of the above departments.
[S2-4] In 2024, no serious issues or incidents were reported which would concern the violation of
human rights in the Bank’s value chain. [S2-1] The Bank received no reports of cases of non-
compliance with the UN Guiding Principles on Business and Human Rights, the International Labour
Organization’s Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for
Multinational Enterprises.
18.3. BENCHMARKS AND OBJECTIVES
[S2-5] The aim of the Bank Millennium Group is to maintain the positive impact on persons working
in the value chain, therefore all the business partners accept the above ESG principles and policies.
There is no possibility of signing an agreement with the Bank or join an organized tender procedure
without a written acceptance of relevant documents regulating ESG issues, including those concerning
working conditions. In connection with this, our ambition is to cover 100% of the Group’s business
partners with our ethics and ESG principles. The objective is monitored on an ongoing basis by the
organizational units involved in handling agreements with our partners. The Bank has not set other
measurable and time-bound objectives in this area and has no plans to set such objectives in the near
future.
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19. BANK MILLENNIUM CUSTOMERS (ESRS S4)
19.1. CUSTOMER STRATEGY
19.1.1. INTERESTS AND VIEWS OF STAKEHOLDERS
[SBM-2] In Bank Millennium’s value chain, customers are a key stakeholder. We target both the retail
segment, that is individual customers and micro-entrepreneurs, and, as part of corporate banking,
small, medium-sized and large companies.
In order to best respond to the needs of our customers, we thoroughly examine the feedback we
obtain from them. Our customers’ needs, expectations and feedback constitute a fundamental value
for shaping our strategy and business model, including our service model. We take this input into
account when innovating and improving the Bank’s products, services and operations.
Customer feedback is also processed in the CX Loop and Voice of Customer software (as described in
more detail in section 19.2 General customer engagement processes), based on which we make
improvements, counteract negative impacts and amplify positive impacts. We obtain these from the
following sources:
• Outlets, mobile and internet banking,
• Intranet, community forum,
• Hotline,
• Complaints,
• Satisfaction surveys.
The observance of human rights is incorporated into the main goals and commitments of the Bank
Millennium Group. For more on this, see section 19.3 Respect for human rights in customer relations.
19.1.2. MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR
INTERACTION WITH STRATEGY AND BUSINESS MODEL
[SBM-3] In the course of identifying impacts, risks and opportunities in the customer area (S4:
consumers and end users), we have identified a total of ten material issues. These include five positive
impacts, three negative impacts and two risks; we have not identified any material opportunities.
The material issues are categorized under the following four sub-topics from the ESRS guidelines
(seven issues) and one sub-topic specific to a financial institution (three issues):
• [ESRS] Impact of information on consumers or end users:
1. Access to (high-quality) information.
2. Privacy.
• [ESRS] Social inclusion:
3. Responsible marketing practices.
4. Non-discrimination.
• [Sector-specific]
5. Safety of deposited funds.
Ensuring the safety of funds deposited in the bank by customers coupled with access to high-quality
information and privacy, security of personal information and bank secrecy are at the core of our
business and of what defines banking. The impacts, risks and opportunities identified in the course of
double materiality analysis are reflected in the Bank Millennium Group’s Strategy for 2025-2028 –
Value and Growth and in the Bank’s internal regulations. The Bank is ready to effectively face the
challenges of impacts and risks in the banking sector, including those identified in the double
materiality analysis. All negative impacts are of a potential nature, meaning that they may not
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materialize at all in the Bank’s daily operations. However, the Bank takes into account the risk of
their occurrence.
A potential loss of safety of deposited funds and a potential breach of personal data and bank secrecy
might affect all groups of the Bank’s customers, that is both retail and corporate banking customers.
As regards cyber-attacks, the most vulnerable customer groups are seniors and teenagers, which is
why the Bank is ramping up education efforts targeted at these groups with a view to preventing data
breaches and compromising the safety of deposited funds. The impact involving potential failure to
provide customers with sufficient amount of information applies only to retail customers, as they are
the ones who may lack specialized knowledge of financial products and/or services. Due to its sector-
specific nature, the Bank is subject to regulatory requirements that entail the provision of detailed
information about the Bank’s offerings in compliance with the established legal norms.
Two of the identified material negative impacts on customers – concerning the potential loss of
security of deposited funds and potential breaches of personal data and bank secrecy are associated
with systemic external threats, such as cyber-attacks. In fact, they pose a threat to the whole banking
sector. Bank Millennium is developing its own processes to counter these threats. As regards the
impact stemming from the potential provision of insufficient information to customers, we are dealing
with both a systemic factor (namely changes in regulations or their interpretation) and factors
involving proper management on the Bank’s side of the dissemination of information to consumers.
In the Bank, we take numerous steps boosting the positive impact on our stakeholders. As regards
customers, the Bank’s material positive impacts pertain to activities in the areas of safety of
deposited funds, privacy, access to (high-quality) information, responsible marketing practices and
non-discrimination (inclusive banking).
In the area of safety of deposited funds, cybersecurity plays a crucial role. In addition to continuous
monitoring and improvements to IT solutions, we conduct frequent audits and tests of our information
systems – both external and internal. We have adopted an information security management model
that defines a comprehensive system for protecting all information processed by the Bank, including
information about customers. We constantly examine new threats and the methods used by criminals.
We have established a special team to ensure the security of all channels used to access our products
and services. It is also crucial to raise the maturity of employees in the area of cybersecurity, which
is why we take care of the provision of education and the verification of knowledge internally in our
organization. Moreover, we educate various customer groups, including seniors, teenagers and
parents of younger children. We join sector-wide activities. We also publish warnings about new
methods applied by criminals on our website and in our electronic channels:
www.bankmillennium.pl/bankowosc-elektroniczna/bezpieczenstwo?languageChange=true.
In terms of privacy, that is the security of our customers’ personal data, we have put in place
appropriate processes, policies and responsibilities (Data Protection Officer). We are ceaselessly
improving our technical and organizational measures to ensure the protection of personal data
processing. The rules for our processing of personal data are presented each time in an information
clause – customers have the opportunity to familiarize themselves with the information clause before
they enter into a contract for banking products or services and they may also read its wording posted
on the Bank’s website at any time.
We also prevent data breaches by conducting educational activities targeted at employees.
Customers’ personal data are additionally covered by banking secrecy.
To ensure that our customers receive high-quality information from us, we focus strongly on
compliance of documentation and customer service with all applicable regulatory requirements. We
thoroughly review and approve our products in accordance with internally adopted guidelines. We
keep monitoring regulatory progress to identify changes and implement them in the Bank’s internal
rules. We apply the service and sales standards we have introduced to reduce the risk of unethical
sales and providing insufficient information to customers. We monitor and regularly evaluate
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compliance with the standards as well as the scope and quality of information we provide to our
customers.
We have also adopted internal regulations laying down the principles for creating our information and
advertising materials. They must comply with legal regulations and good practices defined by the
Polish Financial Supervision Authority, the Polish Bank Association, the Advertising Council, the
Advertising Ethics Commission and other pertinent institutions. They precisely define the steps we
must take during the process of preparing and publishing advertising materials. These steps help us
ensure that the Bank’s products and services are communicated in a clear and comprehensible
manner.
As regards inclusive banking, that is non-discrimination, we conduct activities oriented towards the
search for innovative and inclusive (anti-exclusion) products and distribution channels and in our
approach to customer service. We have identified two risks: that of potential data leakage, loss of
trust and financial losses due to cyber-attacks, and the risk arising from increasing consumer
protection resulting from the regulator’s actions in the local and European markets, which may trigger
certain compliance, financial and reputational risks, requiring sectoral proactive dialogue with the
regulator and early identification of the potential impact of new requirements. In our Strategy for
2025-2028, we directly address how to manage these risks in order to effectively mitigate them.
In the area of cybersecurity, we will continue to steadily ramp up our technological and organizational
resilience to protect our organization against current and future cyber risks. In terms of mitigating
the risks associated with increasing consumer protection, we will continue to actively participate in
sector-driven initiatives and dialogue with the regulator as well as emphasize early identification of
potential impacts of proposed changes.
19.2. GENERAL CUSTOMER ENGAGEMENT PROCESSES
[S4-2] The Bank’s goal is to build the best possible customer experience in the daily use of our
services, to understand their needs and potential barriers they face in their relationship with the
Bank. We make sure that the degree of customer satisfaction with our services is constantly
increasing, which is why we listen to customer opinions and thoroughly review any comments and
needs they report.
Our customers are welcome to provide their feedback through a variety of channels: at the outlet, by
phone, through electronic banking, by letter and in mobile app stores. We thoroughly analyse the
information about the perceived imperfections, but also the needs that customers report to us, and
use it to improve our products and processes.
We involve customers at the design stage of the Bank’s digital solutions. For more than ten years now,
the Bank has had a UX Lab, where researchers conduct in-depth analyses, user interviews and test
new solutions. Customers are always at the centre of new solutions – all projects and implemented
improvements in online banking and applications are inspired by their needs, habits, language and
the world surrounding them.
Moreover, cooperation with customers is carried out through the complaints process we have put in
place. It is supported by the VOC (Voice of Customer) complaint cause elimination program. It strives
to detect and eliminate any potential irregularities by carefully examining customer requests. The
details of customer requests are consulted with process owners and substantive units. This is aimed
at rectifying irregularities, changing processes and, as a consequence, preventing any future potential
complaints. As part of the complaint process, we provide the customer with a response through the
customer’s preferred channel of contact. In each and every instance when the customer’s
expectations are not met, we indicate the available paths of appealing against the decision made.
With regard to identified impacts, the Bank strives to ensure that all customer feedback is addressed
properly. Customer feedback is forwarded to the units put in charge of managing the impact in
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question, and it is then their job to examine the request. In many cases, further processing depends
on the type of customer feedback. The Bank, as an institution of public trust operating in a regulated
financial market is subject to sector-specific laws. This includes cybersecurity activities and ensuring
the privacy of customer data. This means that the Bank, acting in the best interest of the customer,
takes customer feedback into account in compliance with all applicable regulations.
The Quality Department and, in terms of designing digital solutions, the Electronic Banking
Department are responsible for customer cooperation processes. Both these units report to the Bank’s
pertinent Management Board Member.
Assessment of the effectiveness of cooperation with customers is reflected in the Bank’s customer
satisfaction surveys and in the ongoing monitoring of Voice of Customer (VOC) program notifications.
19.3. RESPECT FOR HUMAN RIGHTS IN CUSTOMER RELATIONS
[S4-1] The observance of human rights is incorporated into the main goals and commitments of the
Bank Millennium Group. The Group’s conducts its business on the basis of social responsibility, in
particular by pursuing the United Nations Sustainable Development Goals. As the Bank Millennium
Group, we are committed to respecting human rights, ensuring compliance with the provisions of
Polish and international law (including the United Nations Universal Declaration of Human Rights) and
the 10 Principles of the UN Global Compact, and defining internal practices and procedures in this
area. The document that lays down our approach to the protection of and respect for human rights is
our Human Rights Compliance Policy. This document has been put in place as part of our Sustainability
Policy, and is available to customers on the Bank’s website. The Bank’s Management Board is
responsible for approving and implementing the document.
We treat customers with respect, prohibiting any and all forms of discrimination based on any aspect
of diversity, including origin, gender, sexual orientation, family situation, nationality, ethnicity,
religion, social status and political beliefs, as well as any individual physical characteristics, health
conditions or disabilities. We provide financial products and services tailored to the individual needs
of our customers. We adopt policies and procedures that provide an adequate approach to customers,
while observing their right to privacy and ensuring the confidentiality and security of their data. We
promote sustainable financing by encouraging customers to engage in a sustainable transition of their
businesses.
The Human Rights Compliance Policy also governs mechanisms for evaluating and monitoring
compliance with human rights. With respect to customers, these include promoting the provisions of
the Code of Ethics among the Bank’s employees, monitoring risks of non-compliance with human
rights, providing a special confidential (anonymous, if so chosen) channel for reporting irregularities
and breaches, including in the area of human rights, and implementing a process for examining any
detected incidents. The Policy covers actions with respect to all Group customers.
In Bank Millennium, we treat each case of violation individually. In the event of a potential violation
of human rights, the processes put in place by the Bank will ensure that appropriate corrective steps
are taken.
The Human Rights Compliance Policy is aligned with the UN Guiding Principles on Business and Human
Rights in terms of the company’s policy-level commitment to take responsibility for respecting human
rights by putting procedures and solutions in place for taking remedial action in the event of a
negative impact on human rights caused or contributed to by the Bank. According to the Guiding
Principless, the Policy gets approved at the company’s highest level, is based on the knowledge and
experience accumulated within the Bank, includes the Bank’s human rights expectations for
employees, business partners and others directly related to its operations, is publicly available on the
Bank’s website, and is reflected in the Bank’s day-to-day operations. The Bank will be implementing
the Corporate Sustainability Due Diligence Directive (CSDDD). These activities will be associated with
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a re-review of the compliance of the Bank’s internal documents pertaining to respect for human rights
with universally applicable guidelines (for example, the UN Guiding Principles on Business and Human
Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at
Work and the OECD Guidelines for Multinational Enterprises).
Within the Bank Millennium Group’s own operations, no cases were reported of non-compliance with
the UN Guiding Principles on Business and Human Rights, the International Labour Organization’s
Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational
Enterprises that affected any customers.
In 2024, no human rights violations were reported in the area of customer relations.
19.4. SAFETY OF DEPOSITED FUNDS
19.4.1. POLICIES RELATED TO THE SAFETY OF DEPOSITED FUNDS
[S4-1] Ensuring safety of the funds deposited by customers is a priority in the activity of the Bank
Millennium Group. As part of our double materiality analysis, we have identified a topic specific to
Bank Millennium: impacts on consumers or end users related to the safety of deposited funds. Under
this topic, we have identified the risk of data leakage, loss of trust and financial losses due to cyber-
attacks, the potential negative impact related to compromising the safety of deposited funds due to
cyber-attacks, and the actual positive impact resulting from our cybersecurity measures. Our
management of this area is based on activities compliant with our internal security regulations,
including the Bank’s Security Policy, the Bank’s Digital Resilience Strategy and the Security Incident
Handling Procedure.
The Bank’s Security Policy supports the organization’s assurance of compliance with regulations,
industry standards and regulatory expectations in the area of security, which is crucial for maintaining
reputation and trust among our stakeholders, including customers. The Policy provides the basis for
planning, implementing and maintaining: the information system security in the Bank, the physical
security in the Bank, and the business continuity program.
The Policy defines the framework and direction for the protection of the Bank’s physical and
information assets through the establishment of effective security management mechanisms,
including in the areas of ICT risk management, by countering adverse events and taking corrective
actions as they occur. The Policy establishes rules for the pursuit of tasks related to security in its
broadest sense and serves as the glue of all of the Bank’s procedures, regulations and standards in
this area. The Policy is developed on an ongoing basis by the Security Department. The Bank’s
Management Board is responsible for approving, implementing and modifying the Policy.
The Bank’s Digital Resilience Strategy is a document describing Bank Millennium’s ICT risk
management strategy, which seeks to minimize ICT risks with a view to ensuring data integrity,
confidentiality, availability and authenticity as well as the Bank’s business continuity, regulatory
compliance, cost optimization, process improvement, fostering innovation and maintaining a
favourable image and customer confidence.
The Strategy includes the management of various ICT risks, including operational risk, reputational
risk, legal risk, business risk and strategic risk. The Strategy is developed on an ongoing basis by the
Security Department. The Bank’s Management Board is responsible for approving, implementing and
monitoring the Strategy.
Key objectives of ICT risk management include:
• Ensuring data integrity, confidentiality, availability and authenticity.
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• Business continuity: supporting the process of ensuring the continuity of the Bank’s ICT
operations, even in circumstances involving disruptions to or failure of ICT systems.
• Regulatory compliance: ensuring the Bank’s compliance with applicable regulations on digital
resilience, data protection, user privacy and other technology-related issues.
• Cost optimization: minimizing technology management expenses by efficiently allocating
resources and avoiding unnecessary investments.
• Process improvement: identifying and minimizing ICT risks to improve the Bank’s processes
and operations.
• Innovation and growth: supporting the Bank’s innovation and growth by enabling the secure
deployment of new technologies and solutions.
• Image and trust: maintaining a positive image and trust of customers, business partners and
stakeholders by ensuring a secure and reliable technological environment.
The Security Incident Handling Procedure describes detailed rules for handling information security
incidents. The Procedure covers the identification, reporting, analysis, remediation and closure of
incidents. The document includes definitions of key terms such as information security incident, cyber
threat, ICT incident and major ICT incident.
The Procedure is designed to ensure compliance with applicable legal requirements and security
standards, including ENISA guidelines, NCS Act, GDPR and DORA. The document also includes
information on incident handling responsibilities and the organizational structure of incident
management teams.
The Procedure is developed, approved and deployed by the Director of the Security Department
(CISO).
These regulations were revised last year and supplemented with the requirements of the upcoming
Digital Operational Resilience Act (DORA). The Bank’s internal regulators serve the prevention and
identification of various risks related to the conduct of banking business, among other tasks.
In the Bank, all internal regulations are reviewed at least annually by the document owner, that is
the unit director/process owner responsible for developing the regulation. The document owner
updates the document on an as-needed basis.
The Security Department is in charge of monitoring compliance with the assumptions of the internal
regulations put in place for the security of deposited funds, as mentioned earlier in this section, and
for reviewing and updating these documents. To this end, it applies the tools (for instance, ongoing
reports and monitoring of critical indicators) established in respect of specific processes, thus
enabling the continuous monitoring of activities and evaluation of their effectiveness. The information
security management system consists of a set of the documented processes and regulations in force
in the Bank and in the part aligned with the profile of the activity they conduct. The Bank’s ITC
security management system complies with both the National Cyber Security System Act and the
previously mentioned DORA.
Commitments to respect human rights at Bank Millennium, including in respect of the safety of
deposited funds, are presented collectively for all relevant impacts in section 19.3 Compliance with
human rights in customer relations.
19.4.2. GENERAL CUSTOMER ENGAGEMENT PROCESSES IN TERMS OF THE
SAFETY OF DEPOSITED FUNDS
[S4-2] In the process of ensuring the safety of funds deposited by customers, the Bank cooperates
with customers both at the operational level in the event of a security incident and by building
customer awareness of digital threats.
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In the event of a cyber-attack, we use several mechanisms to work with customers to ensure effective
protection and reduce any damage to a minimum in accordance with the Security Incident Handling
Procedure described in the section above. First of all, we notify customers of the threat and provide
instructions on how to secure their accounts. We monitor and prevent the execution of suspicious
transactions to thwart any further losses. We also cooperate with law enforcement agencies and
Internet service providers with a view to shutting down fraudulent sites.
In practice, cooperation with the customer is as follows: when an incident is detected, the customer
is promptly notified of the threat and provided with detailed instructions on what to do next. The
Bank monitors the situation and takes corrective action, such as preventing the execution of suspicious
transactions and cooperating with relevant authorities. The customer is kept informed of the progress
and actions taken by the Bank to resolve the problem.
Cooperation with the customer also includes a standard complaint path, which is more dynamic in the
case of active cyber-attacks. Details on the complaint process are provided in section
19.9 Remediation of negative impacts.
In terms of building customer awareness of digital threats, the Bank conducts educational activities,
as described in more detail in section 19.4.3 Measures to ensure the safety of deposited funds.
Details on general customer engagement processes are described in section 19.2 General customer
engagement processes.
19.4.3. MEASURES TO ENSURE THE SAFETY OF DEPOSITED FUNDS
[S4-4] In Bank Millennium, we carry out a number of activities aimed at managing the risks and
impacts identified in our double materiality analysis focused on the safety of deposited funds. We
keep confidential any information on the processes by which we determine the type of measures to
be taken or how we assess their effectiveness. At the same time, we ensure that the activities we do
carry out are appropriate and effective. They are conducted on the basis of best market practices
and expertise of the Bank’s experts.
We regularly subject our information systems to security audits/tests – both external and internal
ones. In addition to the audits required by the provisions of the National Cyber Security System Act,
performed at least once every two years, the Bank carries out a number of pertinent audits/tests on
an as-needed basis. The audit processes concern systems in operation, with a particular focus on
systems that process customer data, systems made available online as well as modifications, new
solutions and systems that are being rolled out. In connection with the DORA requirements being
introduced, the Bank is preparing to participate in mandatory Threat-Led Penetration Tests (TLPTs),
which will be carried out in accordance with the recommendations of the Polish Financial Supervision
Authority. TLPTs are a key component under DORA to assess the resilience of financial institutions to
advanced cyber threats.
The accepted information security management model determines the comprehensive system for
protecting all information processed in the Bank, including information on customers, employees,
business partners and transactions. In order to achieve this goal, we use a broad range of
organizational, procedural and technical 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.
We use our best efforts to ensure the protection of customers’ 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.
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We attach particular importance to the security of our customers using electronic channels to access
banking products and services and we continue to improve technical and operational security
measures. We have been using tested and safe methods to confirm identity of IT system users and we
continue to develop them to ensure safe and convenient access to the Bank’s systems. Our customers
may use innovative identification methods such as biometry.
New threats and methods employed by criminals are undergoing constant analysis to be able to
counter them even more effectively. In addition, we have been actively collaborating with other
financial sector entities in Poland and internationally, sharing our knowledge about the latest threats,
trends and the evolving methods of abuse.
The data and resources of our Bank’s customers remain under constant oversight of a dedicated
specialist team ensuring security of all the channels used to access our products and services. Within
the Bank’s organizational structure, a unit has been established and put in charge of ensuring security
in the broadest sense, with teams that deal with all aspects of security: from physical security, to all
aspects of cyber security and ICT security, to fraud risk management. Also, within this security unit,
a dedicated team is responsible for performing ongoing vulnerability checks on the Bank’s systems.
Such checks are performed on a continuous basis. The Bank acts proactively against potential security
incidents through monitoring and ongoing operation of the Security Operation Center (24/7).
We educate various customer groups, including seniors, teenagers and parents of younger children.
The Bank joins sector-wide activities coordinated by the Polish Bank Association, but also conducts
its own communication activities. Educational messages are directed to customers through various
channels, including the mobile application, online banking and social media. We also publish warnings
about new methods applied by criminals on our website and in our electronic channels:
www.bankmillennium.pl/bankowosc-elektroniczna/bezpieczenstwo#zasady-bezpieczenstwa.
In each case, the Bank tailors the content of its communications to the needs of the specific customer
group and seeks new, more accessible forms of expression – in 2024, we used push-video for the first
time in educational campaigns conducted in the Bank’s channels. We also study customer
expectations and their reception of these communications. We conduct qualitative research in the
Bank’s UX Lab and quantitative research using third parties. Based on the research and historical
data, we build customer profiles for personalized educational communications.
The obligatory educational program applicable to all employees forms a major part of our 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. Employees are trained regularly on the
rules for preventing abuse and ensuring protection of the customers’ funds and data. Additionally, a
number of technical safeguards operating in a multi-layer model (defence in depth) have been
implemented in this area. Moreover, we conduct regular controlled phishing campaigns, thereby
further increasing the level of security maturity of our employees. The Bank monitors the delivery of
training efforts in security-related areas, including digital security, by employees, and reports the
outcomes to the units responsible for monitoring risk indicators.
In order to achieve a positive impact in terms of the safety of deposited funds, we are taking numerous
measures in the cybersecurity area. This is done primarily to support the Bank’s innovation and
development by enabling the secure implementation of new technologies and solutions as well as the
early identification and minimization of ICT risks to improve the Bank’s operational processes and
activities. Furthermore, we are focused on educating various customer groups, including seniors,
teenagers and parents of younger children, about cybersecurity.
In order to mitigate the negative impact of potential cyber-attacks on the financial system and public
trust, it is absolutely crucial to ensure a secure and reliable technological environment. To this end,
our process for ensuring the continuity of the Bank’s ICT operations, taking into account any
disruptions and failures of ICT systems, plays a significant role. As part of the process, we take steps
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to minimize potential inconvenience to customers and take into account the provision of relevant
information to stakeholders, commensurate with the level of threat and potential consequences
resulting from possible attacks.
To manage the risk of loss of safety of deposited funds due to a cyber-attack, we take care to ensure
the integrity, confidentiality, availability and authenticity of data. We proactively operate a Security
Operation Center (available 24/7) and conduct ongoing monitoring to promptly respond to any
potential security incidents. On a continuous basis, we perform ongoing vulnerability checks on the
Bank’s systems. We also use the best technological and organizational solutions to ensure the security
of our ICT environment.
Our goal is to ensure a high degree of security of customer funds by identifying and minimizing risks
associated with cyber-attacks and other ICT threats. All these activities are continuous in nature and
are developed and improved on an ongoing basis.
In order to monitor the safety of customer funds, including in the context of cyber-security, we
implement a number of activities and use various tools. The primary elements of these endeavours
include key performance indicators (KPIs) and key risk indicators (KRIs) for ICT security. For instance,
we monitor the number of ICT security incidents related to receiving or attempting to send unsolicited
content. Monitoring is carried out on an ongoing basis, and reports are generated quarterly. For
security incidents, reporting is performed both internally and to external authorities. We use
advanced tools to analyse and monitor transactions and ICT systems. We use incident classification in
accordance with ENISA’s Reference Incident Classification Taxonomy.
Monitoring results are reported to the units responsible for risk monitoring and to the Bank’s
Management Board. In the event of serious incidents, reports are also submitted to the national or
sectoral Computer Security Incident Response Team (CSIRT).
The Bank refrains from disclosing information on specific targets, metrics and ways to track and
evaluate activities in the area of safety of customer funds. These constitute company secrets.
In our opinion, the Bank’s own practices in the area of security of customer funds do not cause or
contribute to any significant negative impacts on customers.
The Bank has put in place appropriate organizational structures to effectively manage the identified
impacts and risks, and provides resources for the operation of such structures. In this respect, a key
role is played by the Security Department, which has been put in charge of ensuring the security of
the organization by managing both physical and information-related risks. The Department’s key tasks
focus on identifying potential risks and on developing and implementing strategies to minimize them.
The Security Department cooperates with the Bank’s other organizational units and external
regulators to ensure business continuity and improve security.
19.4.4. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES
[S4-5] Security objectives are among the important elements of our strategy. In Bank Millennium’s
People Inspire Us Strategy for 2022-2024, security, including cybersecurity, and a proactive approach
to countering threats was one of 17 strategic initiatives.
These activities continue and are also included in the Bank’s Strategy for 2025-2028, entitled Strategy
2028 – Value and growth. The technology development plan, which is designed to support business
strategy initiatives and provide security to our customers and the organization, is broken down into
seven areas. One of these areas is digital resilience and security, under which the following two main
goals have been specified:
• Continuous enhancement of technological and organizational resilience to protect the Bank
and its customers from current and future cybersecurity risks.
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• Further development of information and communications technology (ICT) risk management
to prepare for new threats.
Strategic goals are monitored and reported on a quarterly basis. The Bank refrains from disclosing
information on the details of its targets, their baselines and desired levels related to the security of
customer funds. These constitute company secrets.
We cooperate with other players in the Polish financial market with a view to exchanging experience
and information, including information on cyber threats. In the process of setting targets for resilience
and digital security, the Bank has used the knowledge and experience of its experts without any input
from customers in this regard.
19.5. PRIVACY
19.5.1. POLICIES RELATED TO PRIVACY
[S4-1] In Bank Millennium, we process personal data in order to operate bank accounts, securely
execute instructions, perform obligations imposed by law on the Bank, and to inform the market about
new services and products. Acting as a data controller, we make every effort to meet the
requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to the processing of personal data and on the
free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation)
("GDPR”) and thus protect personal data. Personal data of Bank Millennium’s customers, in accordance
with banking law, are also covered by banking secrecy, which entails the obligation to provide even
more far-reaching data protection.
To ensure compliance with the requirements of GDPR, we have adopted the Bank Millennium Personal
Data Security Policy. The purpose of the Policy is to define the rules for processing personal data in
compliance with the requirements of the applicable legal regulations on personal data protection.
The Policy establishes general rules for the processing of personal data, which should be observed
and applied by all persons processing personal data in Bank Millennium, both in IT systems and
traditionally (in paper form). The principles described in the Policy enable effective management of
the identified impacts: the potential negative impact associated with a breach of personal data
protection and the actual positive impact resulting from actions to ensure the privacy, confidentiality
and security of customer data. Actions taken under the Policy are monitored by a unit established
especially for this purpose: the Personal Data Protection Department. The Department monitors
legislation on an ongoing basis and, in the event of changes in legislation, makes recommendations
for changes to the Bank’s existing internal regulations.
The Bank Millennium Personal Data Security Policy establishes general rules for the processing of
personal data, which should be observed and applied by all persons processing personal data in Bank
Millennium. The scope of the Policy includes the following issues:
• Principles of personal data processing,
• Responsibilities of the Data Protection Officer,
• Rights and responsibilities of IT systems users,
• Data processing transparency,
• Data subjects' rights,
• Data processing risk analysis and impact assessment,
• Subcontracting of personal data processing and data sharing,
• Technical and organizational measures to ensure the security of personal data,
• Handling of data breaches.
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Within the framework of the adopted rules for the processing of personal data, the Bank ensures that
only certain persons with relevant authorization and rights have access to personal data. Access
control is implemented both by restricting access to rooms where paper-based information is stored
and by ensuring that appropriate procedures are in place for access to all sets of personal data in
electronic form.
Personal data entrusted to the Bank may be processed only based on a valid legal basis for such
processing in respect of each instance of personal data processing.
Each employee of the Bank is required to comply with the Policy. The Bank’s Management Board is
responsible for approving, implementing and modifying the Policy.
The Personal Data Protection Department is responsible for monitoring compliance with the Personal
Data Security Policy. Monitoring is carried out on a continuous basis as part of reviewing processes,
documents, contracts and others. Moreover, as part of the handling of incidents, the Department
recommends taking appropriate mitigating actions.
On the website https://www.bankmillennium.pl/en/data-protection?languageChange=true, we
provide detailed information for customers on personal data processing in Bank Millennium and our
privacy policy. This site includes documents containing detailed information on the processing of
personal data in Bank Millennium, as well as information on customers’ rights in this area.
Commitments to respect human rights at Bank Millennium, including in respect of personal data
protection, are presented collectively for all relevant impacts in section 19.3 Respect for human
rights in customer relations.
19.5.2. CUSTOMER ENGAGEMENT PROCESSES IN TERMS OF PRIVACY
[S4-2] The principles of personal data protection and banking secrecy of the Bank’s customers are
governed by the laws that form the basis for conducting the business of a financial institution (in
particular: GDPR, Personal Data Protection Act, Banking Law). Accordingly, the Bank is absolutely
required to act in accordance with the provisions of the legislation. Moreover, the process for working
with customers in the area of privacy follows directly from the applicable regulations.
To this end, the Bank, acting as a personal data controller, has appointed a Data Protection Officer
to monitor compliance with data protection laws and policies adopted by the Bank. Data subjects may
contact the Data Protection Officer on all matters related to the processing of their personal data
and the exercise of their rights under GDPR.
The Data Protection Officer’s contact details are published on the Bank’s website and are included in
the wording of information obligations provided to customers.
The Bank’s customers enjoy a number of rights regarding their personal data, including the right to
access, change, restrict the processing of such data, and the right to withdraw consents granted for
particular purposes of data processing. To this end, they may contact the Data Protection Officer
directly, as well as the Bank’s employees in branches, through the TeleMillennium hotline, may submit
a request in the Millenet Internet banking system, and may send a letter to the Bank Millennium
address.
The Bank is required to provide the information requested by the customer in accordance with the
time limits set by law.
In the event of any irregularities identified in data processing, the Bank must take all reasonable
corrective measures. Any personal data collected in violation of the law or any personal data that are
incorrect or unnecessary in light of the purposes of their processing must be rectified or deleted.
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Details on general customer engagement processes are described in section 19.2 General customer
engagement processes.
19.5.3. MEASURES RELATED TO PRIVACY
[S4-4] In Bank Millennium, we process customers’ personal data using technical and organizational
resources necessary to ensure the security of such data. Personal data are among the Bank’s key
resources, which is why their security is a top priority for us. The activities carried out by the Bank
enable effective management of any identified privacy impacts.
Key activities conducted by the Bank in this area are as follows:
• Continuous improvement of the technical and organizational resources used to ensure the
protection of personal data processing, in particular the protection of data against
unauthorized access, loss or unauthorized alteration. The goal is to ensure the broadest
possible protection of personal data processing.
• Employees are trained to ensure the highest standards of privacy in respect of the Bank’s
customers, and personal data are covered by banking secrecy, which also imposes on us the
obligation to protect customer data to the greatest possible degree. We require all employees
to undergo periodic training on personal data protection. Each new employee is required to
participate in a training course on personal data processing immediately after hiring, while
all employees undergo refresher training annually. We monitor the degree of training
completion and strive to ensure that 100% of employees fulfil their training obligations within
the set time limit.
• Also, each time we introduce a new project or process in the Bank, we review it for its impact
on the processing of personal data, examining the risk level of the process or project for
privacy violations. The purpose of such examination is to minimize the risk of violating the
rights or freedoms of individuals.
• We have adopted a process for dealing with data protection violations, where the basic
principle is to respond promptly and to treat each incident with special care. The Bank
provides resources and properly functioning processes for responding to breaches, affecting
the mitigation of the risk of negative consequences of a breach. Details of this process are
provided in section 19.9. Remediation of negative impacts. The goal is to reduce the risk of
negative consequences of a breach of an individual’s personal data protection rights.
All of the above activities are being carried out continuously and will continue in future years as well.
The effectiveness of the activities in this area is monitored and reported on a quarterly basis. If an
increase in the number of personal data violation incidents is recorded, the Bank takes appropriate
corrective actions.
In planning its privacy activities, the Bank continuously monitors and analyses legal regulations,
performs an analysis of potential threats, and prepares the scope of its activities in accordance with
the current legal environment and ongoing threats. The Bank addresses privacy issues in all its
products and services. The Bank cooperates with industry organizations in communicating privacy and
cybersecurity risks.
In the event of a security incident resulting in a violation of customer data protection, the Bank takes
measures to reduce the incidence of such situations in the future. The measures applied are
commensurate with the cause of the violation. In particular, they include educational activities,
changes in processes and changes in IT systems.
The Bank monitors the level of incidents related to the processing of personal data, analyses the
causes of incidents and implements mitigating measures to reduce their number in the future.
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The Bank ensures that processes related to marketing, sales and use of data function in accordance
with legal regulations. Accordingly, the Bank’s practices do not contribute to any material negative
impacts on consumers.
In managing the broadly construed privacy process, the Bank has appropriate organizational structures
in place, including departments whose goals and tasks are related to the area of ensuring the privacy
of our customers’ data: the Data Protection Department whose job is to provide advice, support and
supervision of the fulfilment of obligations in the area of personal data processing, and the Security
Department. The Bank provides resources for the operation of these units. Moreover, the Bank
Millennium Group has had a Data Protection Officer (DPO) in place for many years to oversee proper
data processing and data protection regulations.
19.5.4. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES
[S4-5] The goal of privacy activities is to ensure data security for customers and to reduce to minimum
the incidence of potential data violations. All information provided by our customers is protected
using state-of-the-art technologies, in accordance with applicable legal standards, security
requirements and confidentiality rules. The Bank is actively developing its privacy and customer
security systems by rolling out new organizational and technical safeguards.
19.6. ACCESS TO (HIGH-QUALITY) INFORMATION
19.6.1. POLICIES RELATED TO ACCESS TO (HIGH-QUALITY) INFORMATION
[S4-1] Bank Millennium has a number of internal regulations in place to ensure that documents
prepared for customers, and information contained in them, are reliable, transparent and in
compliance with the law. The Bank uses multi-level verification tools, the use of which suppresses
the risks and negative impacts on consumers. Every new or modified product or service in the Bank,
regardless of which customer group it is aimed at, is subject to the guidelines of the Policy for
Approval of New Products and Services and lower-level documents.
The Policy defines the general rules and procedures applicable to the marketing of new products and
modifications to existing products. The scope of the document includes:
• preparatory process for the introduction of a new product, implementation of a new service,
introduction of significant changes to existing products and services, etc.,
• opinion and approval process, which is carried out in cooperation with the Risk Department,
the Compliance Department, the Legal Department and other units that are relevant to the
product or service,
• process for setting product prices.
Lower-level documents clarify the rules of conduct for the Policy – they define the principles and
procedures applicable in Bank Millennium when marketing new products and modifying existing
products and services offered by the Bank. They include:
• details of the preparation and consultation process for the marketing of a new product or
modification of an existing product, including an analysis of compliance with the Bank’s
Strategy, an analysis of compliance with regulatory requirements, and the identification of
opinion-giving bodies for specific products,
• details of the review and decision-making process for the marketing of a new product or
modification of an existing product,
• reporting principles,
• process of taking action after obtaining approval to implement a change,
• details of the process of making changes to the price list of services,
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• preparation and approval of marketing communication plans and budget,
• information on the responsibilities of the unit requesting the marketing of a new product or
modification of an existing product, and references to any other internal regulations of the
Bank – specific to the product group.
The Policy for Approval of New Products and Services and lower-level documents are internal
documents applicable to all of the Bank’s products and services targeted at both retail and corporate
customers. A review of the documents is conducted annually. The Bank’s Management Board is
responsible for approving, implementing and modifying the Policy. Ongoing monitoring of regulations
and updates of the above documents in this regard is supervised by the Compliance Department. Each
quarter, a report of the Compliance Department is prepared and presented at a meeting of the Bank’s
Management Board and the Supervisory Board Audit Committee. The report includes information on
the most material regulatory changes identified in the respective quarter, relations with regulators
(including the Office of Competition and Consumer Protection, the Polish Financial Supervision
Authority and the Financial Ombudsman), as well as information on instances of compliance risk
identified by the Compliance Department – both with generally applicable regulations and with the
guidelines of the indicated regulators.
Moreover, the Bank’s employees, while serving customers at retail outlets, are required to follow the
guidelines set forth in the Customer Service Standards for the Retail Segment. The document
organizes and structures customer service and product sales processes. It also supports the
development of high-quality customer service, establishing positive relations with customers and the
provision of transparent and reliable information to customers about the Bank’s offerings.
The guidelines set forth in the Book of Customer Service Standards obligate employees to do the
following in particular: analyse customer needs, present the Bank’s offering clearly, discuss the rules
on how the product works, present cost information, diagnose customer doubts, provide explanations
and ultimately – confirm that the rules on how the product works are comprehensible to the customer
prior to signing an agreement.
We attach great significance to the quality of customer service, including the quality of information
provided to customers. Our employees are further supported in this by Customer Call Scripts for
everyday banking products, credit products or 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 customer education so that they can benefit
from the services offered by the Bank with full awareness.
We design the Models and Standards based on a thorough analysis of our customers’ preferences. We
take into account different needs, barriers and types of customers in order to best adapt to their
expectations.
The Quality Department is responsible for developing, monitoring and implementing the Customer
Service Standards and the Customer Call Scripts. The Management Board Member responsible for the
respective business line is responsible for approval. The customer engagement model and tools, when
implemented or changed, are subject to review by the Compliance Department. Monitoring of the
implementation of activities in accordance with the provisions of the Customer Service Standards and
Call Scripts is carried out through regular mystery shopper studies.
The rules of conduct described in the documents presented above enable effective management of
the identified impacts: the actual positive impact resulting from taking numerous measures to ensure
that customers have access to reliable information about product offerings in all sales channels and
the potential negative impact on retail customers related to insufficient information provided to
customers, as well as management of risks resulting from increasing consumer protection.
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Commitments to respect human rights at Bank Millennium, including in the area of access to quality
information, are presented collectively for all relevant impacts in section 19.3 Respect for human
rights in customer relations.
19.6.2. CUSTOMER ENGAGEMENT PROCESSES IN TERMS OF ACCESS TO
INFORMATION
[S4-2] When marketing a new product or making changes to an existing product, the Bank ensures
that it is tailored to the needs of its users. The Bank monitors the fit of a new product or changes to
an existing product with the users, in particular by monitoring the sales process and analysing
complaints and claims made by customers.
Details on general customer engagement processes are described in section 19.2 General customer
engagement processes.
19.6.3. MEASURES RELATED TO ACCESS TO INFORMATION
[S4-4] Measures related to the provision of transparent and clear information to customers place
a strong emphasis on compliance of documentation and customer service with all applicable
regulatory requirements. Accordingly, we conduct numerous activities in this regard.
Key activities in this regard include:
• Detailed review and approval of (new and modified) products and services in accordance with
the guidelines of the New Products and Services Approval Policy and the Products and Services
Rollout Instructions. This applies to each new or modified product and service of the Bank.
As part of this process, the Compliance Department verifies the compliance risk of the
proposed product or service and the reputational risk, in particular, compliance with the
requirements to provide potential customers with adequate information before signing the
contract, obligations in terms of the contract and service regulations, information obligations
during the provision of the financial service, and areas of potential conflicts of interest. Only
products and services that have received positive feedback from the units required in the
opinion process in accordance with the Policy and Instructions (including, mandatorily, the
Compliance Department) may be processed further.
• Ongoing monitoring of regulatory progress to identify changes and implement them in the
Bank’s internal rules. Ongoing regulatory monitoring and updates are supervised by the Legal
Department and the Compliance Department. Each month, the Legal Department prepares
a newsletter containing draft or final versions of commonly applicable regulations from the
Bank’s area of interest published in the respective month. Each month, the Compliance
Department prepares a newsletter containing drafts or final versions of guidelines of the
regulators – EBA, ESMA and EIOPA – published in the respective month. Each quarter, a report
of the Compliance Department is prepared and presented at a meeting of the Bank’s
Management Board and the Supervisory Board Audit Committee. The report includes
information on the most material regulatory changes identified in the respective quarter,
relations with regulators (including the Office of Competition and Consumer Protection, the
Polish Financial Supervision Authority and the Financial Ombudsman), as well as information
on instances of compliance risk identified by the Compliance Department – both with generally
applicable regulations and with the guidelines of the indicated regulators.
• The application of service and sales standards (which include Customer Service Standards and
Call Scripts), and consequently the provision of clear and understandable product information
to customers in all sales and customer service channels.
All the employees who provide customers with information are properly trained in the scope
required by the law, sectoral regulations, best practices and quality standards implemented
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by the Bank. Bank employees are informed on an ongoing basis about any significant changes
in sales and customer 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 customers 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.
Implementing service and 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).
Customer service in accordance with the Customer Service Standards and Call Scripts is
constantly monitored by the Quality Management Team – a unit specially established for this
purpose within the Quality Department. The outcomes are communicated both to the Bank’s
Management Board and to the direct superiors of the employees subject to evaluation, and
are used to take remedial efforts across the Bank. Compliance with sales standards 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.
These initiatives are pursued to mitigate risks in the area of increased consumer protection resulting
from the regulator’s actions in the local and European markets and the negative impacts in the form
of inadequate information to customers, and support the positive impacts resulting from taking
numerous measures to ensure that customers have access to reliable information about product
offerings in all sales channels.
In planning our activities in the area of access to (high-quality) information, the Bank keeps track of
and analyses legal regulations, analyses the legal environment, follows the outcomes of surveys and
the results of external audits of customer service quality (including rankings conducted by
independent institutions or the media), and conducts its own surveys of service quality and customer
satisfaction. The Bank addresses the information obtained in the products and services it implements
and in its customer service models.
All of the above activities are being carried out continuously and will continue in future years as well.
The effectiveness of such activities is monitored and reported by the units responsible for verifying
their performance.
Monitoring and evaluation of the effectiveness of the activities carried out is carried out by means of
the Voice of Customer (VOC) program, under which we analyse customer reports, including in the
area of access to information. The program is aimed at detecting and eliminating potential
irregularities. Details of the notification are consulted with process or product owners and substantive
units to eliminate any potential irregularities and make changes to processes.
The Bank ensures that processes related to marketing, sales and use of data function in accordance
with legal regulations, including regulations covering financial products and services. Accordingly, the
Bank’s practices do not contribute to any material negative impacts on consumers.
The Bank has put in place appropriate organizational structures to effectively manage the identified
impacts and risks, and provides resources for the operation of such structures. In the area of
mitigating risks related to enhanced consumer protection, the key units involved in this process are
the business owner of the product or service, the Compliance Department and the Legal Department.
In the area of mitigating the negative impact in the form of insufficient information to customers as
well as supporting the positive impact resulting from the numerous activities related to ensuring that
customers have access to reliable information, in addition to the said units, the Quality Department
is also involved.
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19.6.4. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES
[S4-5] Reliable, clear and comprehensible information to customers serves as the basis for our
activities. Our ambition is to ensure full compliance with the law, a goal that is not measurable. The
management strategy we have adopted is based on early identification and minimization of potential
risks and ensuring regulatory compliance.
We invariably focused on this goal in 2024 and will continue this approach in the years to come. In
the Bank’s Strategy for 2025-2028, we have included the following points as core elements of our
business model, which will complement the Bank’s strategic development:
• minimizing legal risks and ensuring compliance with regulatory requirements (WIBOR transit
to another benchmark, foreign currency loans, AML, KYC).
• mitigating risks in the area of consumer protection.
In accordance with the provisions of the Bank’s Strategy, we are constantly monitoring changes in
legal regulations as well as providing ongoing supervision and taking action on contractual
documentation used by the Bank. Accordingly, we will focus on active and effective participation in
sector-wide initiatives (information campaigns) and dialogue with regulators as well as early
identification of the potential impact of regulatory changes and, following these actions, defining
appropriate implementation projects.
In line with the Strategy, our goal is also to strengthen our customer experience (CX) management,
monitoring and qualitative approach in order to improve the customer experience and be in the Top 3
in the Net Promoter Score (NPS) retail customer satisfaction survey results. A crucial component in
this area is the high quality of information provided to customers.
These goals are related to impact and risk management related to providing customers with
information. In the process of setting the goals, the Bank did not cooperate directly with customers.
These activities are formulated in the Bank’s Strategy for 2025-2028. The Bank monitors the outcomes
of its activities on an ongoing basis, and reports them to the Bank’s Management Board on a quarterly
basis.
19.7. RESPONSIBLE MARKETING PRACTICES
19.7.1. POLICIES RELATED TO RESPONSIBLE MARKETING PRACTICES
[S4-1] Bank Millennium has also adopted internal regulations laying down the principles for creating
our information and advertising materials. They precisely define the steps that the Bank must follow
when preparing and publishing advertising materials for customers. This helps achieve a positive
impact related to providing clear and understandable information about the Bank’s products and
services.
1. Instructions –rules for devising informational and advertising materials for banking products and
services in Bank Millennium S.A. for insurance, loan and savings products.
The Instructions lay down the rules for devising materials on products and services offered by the
Bank (excluding financial products and instruments), which are targeted at the Bank’s customers
or potential customers. The document is designed to ensure that the materials prepared comply
with the applicable laws and internal regulations. The Instructions are approved by the President
of the Bank’s Management Board.
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The document defines the process of preparing information and advertising materials targeted at
the customer through the types of communication with the customer adopted by the Bank,
including through electronic banking channels and means of remote communication. It covers the
duties of the unit preparing the materials, the process of providing opinions and granting approval.
It defines the principles of reliability and completeness of the information contained
in the materials, information on fees, commissions and non-monetary benefits, or comparison
of products. It covers all products and services of the Bank, except for financial products and
instruments.
2. Instructions – rules for devising materials, including commercial publications on products and
financial instruments in Bank Millennium S.A. for financial products and instruments.
The Instructions lay down the rules for creating materials on products and financial instruments
targeted at the Bank’s customers or potential customers. The document is designed to ensure that
the materials prepared comply with the applicable laws and internal regulations. The Instructions
are approved by the President of the Bank’s Management Board.
The document specifies in detail how the materials should be prepared, taking into account the
general principles of the standard of information and the manner of its communication, balancing
information on benefits and risks, comparisons of offerings, indication of past performance,
simulation of results and information on future performance. It also defines the method
of presentation of information about fees. It covers financial instruments within the meaning
of Article 2 of the Act of 29 July 2005 on Trading Financial Instruments, and financial products,
including structured and combined products.
In addition, the information and advertising materials prepared by Bank Millennium is compliant with
the laws and regulations applicable to this area, including in particular:
• Recommendations laid down by the Code of Ethics in Advertising developed by the Advertising
Council and the Advertising Ethics Commission,
• Principles for Advertising of Banking Services of 2008 laid down by the Polish Financial
Supervision Authority,
• Best Practices on consumer loans advertising standards of the Polish Bank Association of 2015,
• Consumer Credit Act of 12 May 2011,
• Act of 23 March 2017 on Mortgage Loans and Supervision of Mortgage Brokers and Agents,
• Act of 29 July 2005 on Trading Financial Instruments.
Commitments to respect human rights at Bank Millennium, including in the area of responsible
marketing practices, are presented collectively for all relevant impacts in section 19.3 Respect for
human rights in customer relations.
19.7.2. MEASURES RELATED TO RESPONSIBLE MARKETING PRACTICES
[S4-4] In the process of developing marketing communication we adhere to the following
recommendations and principles: the Bank’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 customer. If the
message pertains to a promotional offer, its conditions are specified. Customers are also advised on
where they can obtain detailed information about a particular product, service or 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 product, legal and compliance teams,
in order to provide customers 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.
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Monitoring of activities in the area of reliable marketing communications is carried out as part of the
compliance function exercised by the Compliance Department. This process is carried out on the basis
of Bank Millennium S.A.’s Compliance Policy. Its provisions include a description of the instruments
used to manage compliance risk, including with respect to responsible marketing practices. These
instruments include monitoring of products, collection of data on incidents, assessment of compliance
risks and controls, key indicators and risks, analysis of customer complaints and complaints to
supervisory authorities, results of internal audits involving the discovery of irregularities. The results
of Bank product monitoring endeavours are reported quarterly to the Bank’s Management Board and
the Supervisory Board Audit Committee. All of the above activities are being carried out continuously
and will continue in future years as well.
Bank Millennium has a Marketing Communications Department whose task, in cooperation with other
organizational units of the bank, is to work out and devise information and advertising materials, in
accordance with the provisions of the Instructions. The department is staffed by people with
experience and specialized expertise in marketing communications. Units from the product,
compliance and legal areas are involved in the process of reviewing advertising materials. The Bank
provides resources for the operation of these units.
19.7.3. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES
[S4-5] The Bank, as an institution of public trust, provides reliable information of the Bank’s offerings
to customers as the basis of its activities, including in marketing communications. Our ambition –
unchanged over the years – in this regard is to ensure full compliance with the law, a goal that is not
measurable.
Our goal for responsible marketing practices was successfully implemented in 2024 and is also
consistent with the Bank’s Strategy for 2025-2028.
We are planning activities aimed at strengthening our leadership position in the area of customer
experience (CX), a component of which is reliable advertising. As part of the Strategy, we ultimately
want to be the main Bank for 70 percent of our customers, which must be supported by responsible
and reliable marketing practices. We strive to ensure that our marketing communications fully comply
with the guidelines set forth in our internal regulations and applicable laws.
The Bank has not cooperated directly with customers in the process of establishing the goal of
providing reliable information to customers about banking products, including in its marketing
practices.
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19.8. NON-DISCRIMINATION (INCLUSIVE BANKING)
19.8.1. POLICIES RELATED TO NON-DISCRIMINATION
[S4-1] In Bank Millennium, we operate in accordance with the provisions of the Social Impact Policy
and the Diversity Management Policy, which are documents that support activities related to non-
discrimination, including in the area of relations with all of the Bank’s customers.
In accordance with our Social Impact Policy, our direct commitment to the United Nations Sustainable
Development Goals is reflected in strategic activities oriented toward finding innovative and inclusive
(anti-exclusion) products and distribution channels and in our approach to customer service. The
Policy indicates our areas of commitment to customers, including those oriented to the search for
innovative and inclusive (anti-exclusion) products and distribution channels and in our approach to
customer service and respect for human rights.
Our Diversity Management Policy is aimed at promoting a culture of mutual respect, identifying
diversity, ensuring equal opportunities, preventing exclusion and avoiding discrimination. It defines
our commitments in the area of respect for diversity and equal treatment.
Both documents are part of the Bank’s Sustainability Policy, a document that the Bank’s Management
Board is responsible for implementing.
The Sustainability Department is responsible for reviewing and updating the Policies. Monitoring of
the principles described in these documents with regard to customers is carried out using Voice
of Customer (VOC) customer analysis tools, which enable ongoing monitoring of activities and
evaluation of their effectiveness.
Commitments to respect human rights at Bank Millennium, including in the area of non-discrimination,
are presented collectively for all relevant impacts in section 19.3 Respect for human rights in
customer relations.
19.8.2. MEASURES RELATED TO NON-DISCRIMINATION
[S4-4] In Bank Millennium, we work to make sure that each group of customers, who have different
needs and expectations, is properly taken care of. Employees and designed solutions help customers
comfortably bank and use various services at a time and pace that suits them. We are working to
maintain the synergy between the digital message and the traditional form of customer contact with
the bank.
The Bank is taking steps to digitize customers in various areas. Electronic banking channels cooperate
closely with traditional channels. We know that many customers establish a relationship with the Bank
in one of its brick-and-mortar outlets, so the branch is the place where they learn about mobile and
internet banking. The role of employees is therefore crucial, which is why they are properly supported
in this process during periodic meetings and webinars (such as the Digital Ambassadors program).
For Bank Millennium, it is crucial not only to digitize new users, but also to activate those less
involved. We use a personalized approach to digitization. After activating access to digital channels,
we familiarize customers with the opportunities offered by such channels, educate customers on the
principles of cybersecurity and support them in sales processes, such as through contextual chat. This
digitalization path is not identical for every customer, but we tailor it based on analysis of activity
and preferences, while communications are sent to the customer in real time.
We continue our efforts to enhance customer satisfaction also in terms of the transparency
of communication and simplifying the language used. We are changing the texts provided to customers
from account opening to information on handling their products. We gradually transfer experiences
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from the retail segment to the corporate banking area. We continue to train advisors and gradually
introduce the principles of simple language into more types of texts – internal and external. We have
obtained a Simple Language Certificate for responding to complaints. The websites and all customer
communications are also written in simple language that is easily understandable for the user and
may be read by automated text readers. The content is created in accordance with the plain language
principles and the plain language index (PLI) is monitored on an ongoing basis.
The Bank is striving for all our customers, including those with disabilities, to have convenient access
to services. We are constantly working to remove digital and physical barriers to accessing financial
and non-financial services. Most our facilities have wheelchair access. In facilities where there are
architectural barriers, we try to remodel them as much as possible so that the barriers are eliminated.
Clearly, the solution used depends on the type of such barrier. Moreover, all of our establishments
have seated customer service desks with ramp access for people using wheelchairs.
We have introduced many facilities for the blind, visually impaired and wheelchair users, such as:
• elevators and ramps in the Bank’s branches,
• documents in braille, audio recordings,
• documents written in very large font,
• “blind notch” solution in Millennium 360 debit cards, which consists of a semi-circular cut-
out on one of the sides. The solution is conceived as a convenience for the visually impaired
and blind. The cut-out makes using the card, for example when withdrawing from an ATM,
much easier.
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. 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. Also, our mobile
application 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.
The Bank's customers may use mobile devices and computers to access our services, but also a number
of additional solutions, such as in the mobile application, customers may purchase public
transportation and parking tickets. The electronic banking system also allows customers to use digital
identity and engage in remote contact with Polish government offices.
Customers 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 also serve as a valuable guide to daily banking. Customers
may use the assistance of Milla 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.
We have also developed a special procedure for serving blind or visually impaired customers at our
branches. Among other aspects, it includes indications for product presentation and customer
contact. When serving a blind or visually impaired customer, we take care to provide a full description
of the product or transaction being discussed, avoid long pauses in speech, and always inform the
customer of the actions we are performing, such as an employee saying: “I’m entering data into the
system now,” “I’m printing the contract,” “I’m stepping away from the desk for a moment, please
wait.” We keep the customer informed of the actions we are taking so that they can get an idea of
what is going on around them.
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 customer’s express
wish – a witness the customer considers to be a trusted individual. In such cases, an outlet employee
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can also read the agreement aloud and/or in the case of customers who cannot write, they can sign
using an ink fingerprint.
Customers 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, for instance a document prepared using a large font size, an audio file or a file prepared in
braille.
We prepare such documents at the customer’s request. If the customer requests it, we agree with
the customer what kind of document they want to receive, in what form it should be prepared and
how to deliver it to them.
Customers taking their first steps in the area of digital banking have the following site at their
disposal: www.bankmillennium.pl/en/firststeponline.
Ukrainian citizens can find information in Ukrainian on the bank's website. They may also use a special
hotline, where they will be served in their own language. In addition, they can fill out an online
application for family benefits in this language. They also receive communications in their language,
regarding important matters such as application deadlines and cyber security warnings.
The Bank has prepared 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 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.
Disabled people with movement impairments can use ATMs and deposit machines fitted with a
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.
We carry out the above described measures continuously and we keep developing them based on
audits conducted by independent expert institutions. Various departments are involved in these
activities, including: Electronic Banking Department, Retail Banking Marketing Department and Sales
Support Department. Audits of the “We Are Seen” Foundation took place in 2024, covering the areas
of digital processes for Account 360, customer onboarding, electronic banking navigation, debit cards
and credit cards.
19.8.3. OBJECTIVES RELATED TO THE PURSUIT OF POLICIES AND ACTIVITIES
[S4-5] Our goal is to provide products and services that promote the prevention of social exclusion,
including by providing support to the part of society with fewer opportunities to use digital banking
solutions as well as spreading access to financial products.
Barrier-free banking – that is, supporting people with special needs in using banking services and
helping customers navigate the digital world – was part of the Bank Millennium Group’s ESG Strategy
for 2022-2024, and is also continued in the new Strategy for 2028 – Value and Growth. In this regard,
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according to the provisions of the new Strategy, we aim, among other goals, to have 95 percent of
customers digitally active in 2028, an increase by nearly 5 percentage points from 2024.
Also, our level of ambition is to strive to ensure that all customers, including people with disabilities,
have convenient access to financial services. We promote a culture of mutual respect, respect for
diversity, providing equal opportunities, preventing exclusion and avoiding discrimination. This goal
is not measurable, but we make every effort to ensure that any possible violation of our policies in
this regard is identified and that potential harm is remedied.
We monitor the progress of initiatives aimed at increasing the availability of banking services and
products and promoting the prevention of social exclusion. We monitor the effectiveness and
evaluation of the measures taken by analysing the voices of our customers from the Bank’s customer
satisfaction surveys, also as part of the ongoing monitoring of Voice of Customer (VOC) program
submissions described in more detail in Section 19.2 General customer engagement processes.
Progress in implementing the Strategy, including activities in the area of non-discrimination,
is reported on a quarterly basis.
Representatives of the Bank participate in the work of the Polish Bank Association on accessibility of
places and services for people with disabilities. In the process of setting the goal of inclusiveness and
non-discrimination, we have used knowledge from the experience of our customers, including
cooperation within the Polish Bank Association as well as representatives of the “We Are Seen”
Foundation.
19.9. REMEDIATION OF NEGATIVE IMPACTS
[S4-3] In Bank Millennium, issues related to remedying the effects of negative impacts are governed
by internal documents, that is product regulations and the Complaints Handling Instructions, which
define the principles and procedure for handling complaints, which are the responsibility of the
Customer Relations Department. The Bank has implemented internal regulations aimed at ensuring
compliance with the Act on Complaint Examination by Financial Market Entities and on the Financial
Ombudsman and the Financial Education Fund, and the Payment Services Act.
Employees process claims in accordance with the Rules for Processing Claims, the Complaints
Processing Instructions, as well as the powers contained in the Regulations on Pricing and Commercial
Powers.
In the event of a personal data breach, the general rules of conduct are set forth in the Personal Data
Security Policy, as described in more detail in section 19.5. Privacy. Moreover, the Security Incident
Handling Procedure describes detailed rules for handling information security incidents, including as
a result of cyber threats. The procedure covers the identification, reporting, analysis, remediation
and closure of incidents, including those related to privacy and loss of security of funds deposited in
the Bank.
The customer has the opportunity to report a complaint through multiple channels of contact with
the Bank, in accordance with the customer’s preferences and capabilities: at the branch, by phone,
through electronic banking, by e-mail and by letter. We register all complaints (retail and corporate)
in the central complaint registry MilleResolver2, which is used to record and handle claims. The
MilleResolver2 system automatically assigns requests to designated teams and their employees or
robots supporting the process at certain stages. The employee verifies the request and confirms or
changes the categorization, type of request, source and date of the request to the correct type or
value. The employee also sends an inquiry to the appropriate substantive unit if consultation is
needed. In the case of a personal data breach, the customer may also report the incident directly to
the Data Protection Officer. The Bank is required to provide the information requested by the
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customer in accordance with the time limits set by law, and strives to respond to all notifications as
soon as possible.
In the case of notifications in the privacy area, the basic principle is to respond promptly and to treat
each incident with special care. All incidents, even potential incidents, are reported to a team
working 24/7 and then referred to data protection specialists for further analysis if the matter
involves the processing of personal data. Based on these analyses, the Bank continuously improves its
security measures. If the occurrence of a violation has been ascertained related to the protection of
personal data of which the Bank is the data controller, the Data Protection Department assesses the
impact of the violation on the rights and freedoms of the individuals affected by it. If the assessment
indicates at least a high impact of the violation on the rights and freedoms of individuals, we notify
the data protection authority and, in certain situations, the data subject, as required by Articles 34
and 35 of GDPR, in the manner and within the timeframe specified in these provisions. If an incident
involves identity theft, the Bank cooperates fully with the relevant law enforcement authorities.
We evaluate the effectiveness of our actions based on the results of satisfaction surveys conducted
among customers, which supports us in continuously improving our processes. All these channels of
contact with the Bank have been established by the Bank.
We provide customers with various forms of contact with the Bank. During our contacts with
customers, employees inform them about the available contact channels. This is especially
emphasized when establishing a new relationship – when opening an account. Bank employees
encourage contact and inform customers about the possibility of contacting Bank Millennium 24 hours
a day, 7 days a week.
The complaint process is carefully monitored by tracking key performance indicators. These indicators
help us evaluate the effectiveness and efficiency of our operations in various areas, such as service
time, the number of complaints, costs, and how we resolve cases of unauthorized transactions. They
are important for monitoring progress, achieving business goals and ensuring high-quality customer
service and efficient complaint management. With these indicators, we are also able to effectively
identify areas for improvement and take appropriate corrective action.
We periodically conduct a Close The Loop survey of the Bank’s complaint process, including by
assessing the ease of the process. The outcomes of the survey indicate that customers are aware of
the ways to file complaints with the Bank, and have confidence in the process. Also, all Bank
Millennium employees are bound by the provisions of the Code of Ethics. Adherence to the Code
protects the customer from potential retaliation.
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20. BUSINESS CONDUCT (ESRS G1)
20.1. CORPORATE CULTURE AND BUSINESS ETHICS
[G1 IRO-1] In the identification process aiming at impacts, risks and opportunities in the corporate
governance area, we have identified the following three major spheres of impact: corporate culture,
corruption and bribery, and whistleblower protection. We have not, however, identified any material
risks or opportunities in this area. All relevant and applicable criteria for this process, such as location,
business, sector and transaction structure, are described in more detail in section 15.3. Double
materiality assessment.
The Bank Millennium Group operates its business in a sustainable manner, while considering
adherence to ethical principles to be of paramount significance for its corporate culture and business
conduct. This follows from our mission as a financial sector operator and the Group’s professed values,
which we consider crucial.
[G1-1] The fundamental document that governs these issues within the Bank Millennium Group is The
Bank Millennium Group Code of Ethics. The Code of Ethics is a set of principles that must be adhered
to by all employees of the Bank Millennium Group. 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,
prevention of conflicts of interest, anti-corruption, including rules on accepting and giving benefits,
and participation in and organization of tenders. The Code of Ethics also applies to franchisees and
employees at franchise locations.
Every employee is required to become familiar with the Code by completing a mandatory e-learning
course, confirm their knowledge and apply the principles included in the Code in their daily work.
The scope of the training covers conflict-of-interest management, anti-corruption, confidential
information, personal transactions and other topics. The knowledge and materials provided during
the training 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 the disclosure of which might 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. Such training must be attended by every newly hired employee of
the Bank Millennium Group. Moreover, every Group employee is required to participate in refresher
training, conducted annually.
The tasks of the Ethics Officer include overseeing compliance with the Code of Ethics. The function
of the Ethics Officer is exercised by the head of the Compliance Department. The responsibilities of
the Ethics Officer, in addition to overseeing compliance with the Code of Ethics, include promoting
ethical standards, ordering inspections of compliance with ethical principles and examining cases of
their breach.
The Code of Ethics is subject to annual review and updates on an as-needed basis. The Code of Ethics
may also be updated depending on current needs, supervisory recommendations or detected
irregularities, in particular as regards adjusting to changes in the regulatory environment, changes in
the risk profile and size of the Bank, as well as factors of the economic environment in which we
operate.
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The Code of Ethics has been uploaded to our corporate website and is available on the Intranet (in
MilleTeka).
20.2. ANTI-CORRUPTION
[G1-1] The Bank has put in place various formalized policies for preventing, detecting, investigating
and responding to allegations or incidents of corruption or bribery – these issues are governed by the
following internal documents: Anti-corruption in Bank Millennium S.A. Policies and guidelines and
Anti-corruption policy, applicable to all employees of the Bank Millennium Group. Both these
documents are consistent with the United Nations Convention against Corruption.
Anti-corruption in Bank Millennium S.A. Policies and guidelines lays down the principles of conduct
applicable to various contexts, including relations with contractors and government employees as
well as with other organizations, including political parties and non-profit organizations, for the
purpose of preventing incidents of corruption and bribery. The document also sets out the rules
applicable to the acceptance and offering of gifts as well as participation in business-related and
other events by Bank employees.
Anti-corruption in Bank Millennium S.A. Policies and guidelines has been uploaded to the Bank’s
Intranet site in the manner customary for such documents. Its contents are disseminated to and shared
with 100% of business partners and each participating supplier. The anti-corruption principles are
made available to business partners and other stakeholders on the Bank’s website. Moreover, the
Compliance Department publishes regular reminders on the application of the anti-corruption
principles, including on the acceptance and offering of gifts.
[G1-3] The responsibility for counteracting corruption rests with all Bank employees, which means
that they are required, in the event of suspicion that an act of this kind has been committed, to
immediately inform the Compliance Department by sending a message to a dedicated email box:
*CORRUPTION (for internal communications) or to: MBF0084@bankmillennium.pl (for external
communications). In the event that the reporting person sees any reason to fear repercussions of their
bringing the matter to the attention of relevant services, the Bank also consents to such reports being
submitted on a fully anonymous basis, from any email box other than that bearing the Bank’s domain
name, or in hardcopy form addressed to the Compliance Department, or to a selected employee of
that unit.
If a corruption incident occurs, the Head of the Compliance Department is required to promptly bring
the matter to the attention of the President of the Management Board and the Chairperson of the
Supervisory Board, and then take action in cooperation with the relevant Management Board members
to look into the matter, assess its potential unfavourable consequences, take corrective steps and
decide on the consequences of the discovery of the corrupt activity. The Compliance Department, as
the unit exercising the compliance function referred to in Article 3(1)(2) of the Regulation issued by
the Minister of Finance, Funds and Regional Policy on 8 June 2021 on the risk management system
and internal control system and compensation policy in banks, operates as a unit independent from
other units within the Bank. It has been vested with the authority and powers suitable for fulfilling
the duties described above.
On a regular basis, the Head of the Compliance Department notifies the Management Board and the
Supervisory Board Audit Committee of all identified instances of corruption (if they take place), both
in its quarterly reports and in the annual report on the evaluation of the Bank’s compliance system.
In order to prevent corruption in purchasing processes, the Bank has also introduced the principles of
cooperation with Bank Millennium’s suppliers, as laid down 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
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transparency of the procurement process, the substantive and commercial evaluations of bids are
done by independent Bank units. 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.
As part of the assessment of individual components of operational risk, also the aspect of vulnerability
to corruption risk of different types of the Bank’s activities is reviewed 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, authorisations and limits. Periodic audits carried out by the Internal Audit
Department cover all activities of the Bank and all business processes within the Bank Millennium
Group.
The Bank also holds periodic (annual) training courses on preventing corruption. They have been
prepared as a separate group of training courses for Bank Millennium employees and franchise
employees and as a component of compliance training for members of the Bank’s Management Board
and Supervisory Board. The purpose of such training is to familiarize participants with anti-corruption
policies, potential causes and forms of corruption, areas at risk of corruption and ways of acting and
behaving in special situations, for instance when accepting gifts or attending external events.
Information on the percentage of employees who have failed to undergo the training is provided
periodically (quarterly) to the Bank’s Management Board and the Supervisory Board Audit Committee.
Participation in anti-corruption training in 2024
Persons at risk of
corruption to
whom training was
assigned
Persons who
completed the
training
Persons who failed
to undergo the
training
Training in
progress (not
yet completed)
Employees
7,274
6,770
376
128
Percentage
100%
93.07%
5.17%
1.76%
Of which
employees in
managerial
positions
1,139
1,076
50
13
Percentage
100%
94.47%
4.39%
1.14%
[G1-4] In 2024, no cases of corruption were detected in the Bank Millennium Group. Nor were there
any cases of confirmed incidents in which employees were dismissed or disciplined for corruption,
confirmed incidents in which contracts with business partners were terminated or not renewed due
to corruption-related breaches, or public corruption-related litigation brought against the Bank or its
employees. Moreover, no court judgments were issued convicting any employees and/or imposing any
fines for breaches of anti-corruption or anti-bribery laws.
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20.3. WHISTLEBLOWER REPORTING AND PROTECTION
[G1-1] Bank Millennium has two whistleblowing processes in place. The first one pertains to reporting
breaches under the Whistleblower Protection Act of 14 June 2024 and the second one concerns
reports submitted under other regulations (e.g., the Act of 29 July 2005 on Public Offering, Terms
and Conditions for Introducing Financial Instruments to an Organized Trading System and on Public
Companies, the Regulation issued by the Minister of Finance, Funds and Regional Policy on 8 June
2021 on the risk management system and internal control system and compensation policy in banks,
the Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on
market abuse and repealing Directive 2003/6/EC of the European Parliament and of the Council and
Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC, the Act of 1 March 2018 on
Combating Money Laundering and Financing Terrorism, or the Regulation of the Minister of Finance
of 29 May 2018 on the detailed technical and organizational conditions for investment firms, the
banks referred to in Article 70(2) of the Act on Trading in Financial Instruments, and custodian
banks).
As part of the former process, any breaches of the law within the meaning of the Whistleblower
Protection Act may be reported, that is various types of unlawful acts or omissions or those aimed at
circumventing the law in the areas of corruption, public procurement, financial services, products
and markets, anti-money laundering and terrorist financing, product safety and compliance,
environmental protection, consumer protection, protection of privacy and personal data, security of
networks and ICT systems, financial interests of the State Treasury of the Republic of Poland, local
government units and the European Union, or the internal market of the European Union, including
rules governing public competition, state aid and corporate taxation. As part of this process,
whistleblowing reports may be submitted by Bank employees, persons performing work under a civil
law contract, commercial proxies, shareholders, members of the Bank’s Management Board, members
of the Bank’s Supervisory Board, persons performing work under the supervision and direction of a
contractor, subcontractor or supplier, apprentices and volunteers (during the course of their
relationship with the Bank and thereafter). Reports submitted under the Whistleblower Protection
Act are not anonymous.
As part of the latter process, any breaches involving non-compliance with the law and the Bank’s
procedures or ethical standards may be reported. Whistleblowing reports under this process may only
be made by Bank employees or members of the Bank’s Management Board. However, reports obtained
from outside the organization will also be reviewed. Any employee in possession of information or a
reasonable suspicion of a breach of the law, applicable policies, procedures or provisions of the Bank
Millennium Group’s Code of Ethics is required to report such information promptly through any of the
dedicated reporting channels. Such reports may be submitted by email to
naruszenia@bankmillennium.pl (a channel ensuring the whistleblower’s anonymity) or to the
*NARUSZENIA [*BREACHES] mailbox accessible only from the Bank’s internal employee resource (a
channel that does not ensure the whistleblower’s anonymity). A whistleblowing report may also be
submitted by letter – in a sealed envelope delivered by external mail marked as “breach report” and
“for the attention of the addressee only,” placed in another sealed envelope, addressed to the
President of the Management Board or the Chairperson of the Supervisory Board Audit Committee (if
the breach concerns a Management Board member), to the Bank’s registered office address.
The rules governing these processes are laid down in internal regulations: the Bank Millennium S.A.
Whistleblower Manual and the Bank Millennium S.A. Supervisory Board Whistleblower Policy. Both
these documents have been uploaded to the Bank’s Intranet site. Key information on the
whistleblowing system is also published on the Bank’s Intranet site in the Compliance Department
section, and with regard to the process of accepting reports submitted under the Whistleblower
Protection Act of 14 June 2024 – on the Bank’s website.
With regard to the whistleblowing process, the Bank implemented separate training for employees in
2024, to be refreshed annually. The process governing the submission of whistleblowing reports and
the conduct of investigations has also been included in training for members of the Bank’s
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Management Board and Supervisory Board. The area of training for Bank employees is governed by
the Instructions for participation in training programs at Bank Millennium S.A., which is described in
more detail in section 17.1.3. HR policies.
In the regulation Anti-corruption in Bank Millennium S.A. Policies and guidelines, the areas that, in
the Bank’s opinion, are the riskiest in terms of the possibility of the commission of corrupt acts have
been identified. These areas include: relations with contractors, government employees and other
external organizations, the acceptance and offering of gifts, business and PR events. In principle, all
employees may perform duties in the areas indicated, which means that the Bank takes into account
the risk of exposure to corruption and bribery for each employee.
We ensure the confidentiality of all whistleblowing reports and refrain from taking any action against
anyone who, in good faith, reports information regarding potential breaches of the law and/or
adopted policies, procedures or the Code of Ethics, or who participates in the procedure for reviewing
whistleblowing reports, unless a false report or information was provided in bad faith. According to
sec. 6(1) of the Bank Millennium S.A. Whistleblower Manual, the Bank is required to provide the
whistleblower with protection against any repression, discrimination or other types of unfair
treatment or resulting in the deterioration of their legal or factual situation, or involving threats
against them, in particular actions that unfavourably affect their working conditions or terms of
employment. Such protection is afforded by guaranteeing the confidentiality of information
pertaining to the whistleblowing report, thereby reducing the risk of retaliation against the employee.
In a situation where the whistleblower has a reasonable suspicion of possible retaliation against
him/her in connection with the submission of a whistleblowing report or experiences such retaliation,
he/she should promptly inform the Head of the Human Resources Department or file a separate report
in accordance with the Bank Millennium S.A. Whistleblower Manual, indicating that it contains
information about retaliation related to a whistleblowing report submitted in accordance with the
Manual. Subsequently, a dedicated Management Board member or the Head of the Human Resources
Department are required to take all actions provided by law and the Work Rules and Regulations to
ensure that the whistleblower is fully protected from any retaliation. The whistleblower must
cooperate with the dedicated Management Board member or the Head of the Human Resources
Department in the implementation of measures to protect him/her from retaliation.
In turn, section 7 of the Manual governs the Bank’s provision of protection from any retaliation to
whistleblowers who report information about a breach of the law or make an external report or
a public disclosure. Only whistleblowers who, at the time of reporting, have a reasonable basis for
the veracity of their reported information are covered by such protection. No retaliation or attempted
or threatened retaliation may be applied against the whistleblower. In a situation where the
whistleblower has a reasonable suspicion of possible retaliation against him/her in connection with
the submission of a whistleblowing report or experiences such retaliation (including attempts and/or
threats to apply such actions), he/she should promptly inform the Head of the Human Resources
Department (if the whistleblower is an employee) or file a separate report in accordance with the
Bank Millennium S.A. Whistleblower Manual, indicating that it contains information about retaliation
related to the submission of information on a breach of the law, external report or public disclosure
made in accordance with the Manual. Subsequently, the Human Resources Department or the
Compliance Department, as the case may be, takes all actions prescribed by law and the Work Rules
and Regulations to ensure that the whistleblower is protected from retaliation.
Reports submitted under the whistleblowing process are summarized annually by the Compliance
Department as part of its report duties to the Bank’s Management Board, the Supervisory Board Audit
Committee and the Supervisory Board. In 2024, there were no reports that met the definition of the
Bank Millennium S.A. Whistleblower Manual or the Bank Millennium S.A. Supervisory Board
Whistleblower Policy.
The policies described in section 20. Business conduct are posted on the Bank’s website. In turn,
procedures and instructions (including policies) are disseminated among employees via the corporate
Intranet. Through various communication channels, including the “help desk” formula, employees
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may also obtain advice on the pursuit of the Company’s policies and practices of responsible business
conduct (including those related to reporting breaches or counteracting corruption) by referring to
the pertinent units, depending on the area in which the advice is sought. For instance, as regards the
pursuit of the policy to ensure compliance with supervisory laws and regulations and with internal
procedures, the Compliance Department is the competent unit; for the HR policy, the HR Department
is the place to go to; for issues related to credit risk, it is the Risk Department. For issues related to
responsible business conduct practices, the Compliance Department is the appropriate unit for
consultation.
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21. DISCLOSURE OF INFORMATION IN ACCORDANCE WITH THE EU
TAXONOMY (ART. 8 REGULATION (EU) 2020/852)
Legal basis for the Group's reporting obligations under the EU Taxonomy
The Bank Millennium Group is required to publish EU Taxonomy information under Article 8 of
Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020
(“EU Taxonomy”).
The Group prepares EU Taxonomy disclosures in accordance with Regulation 2021/2178
10
as amended
by Regulation 2022/1214
11
and by Regulation 2023/2486.
12
Based on the requirements set out in Annex V of Regulation 2021/2178, Bank Millennium prepares EU
Taxonomy disclosures on a consolidated basis according to the scope of prudential consolidation
applied by the Bank for capital adequacy purposes.
The Bank’s subsidiaries subject to prudential consolidation include:
• Millennium Bank Hipoteczny S.A.
• Millennium Leasing sp. z o.o.
• Millennium Consulting S.A.
• Millennium TFI S.A.
• Millennium Service sp. z o.o.
• Millennium Goodie sp. z o.o.
• Millennium Telecommunication Services sp. z o.o.
Pursuant to Article 10(5) of Regulation 2021/2178, since 1 January 2024, the Group has disclosed
key performance indicators for credit institutions (in particular the Green Asset Ratio - GAR),
including all relevant accompanying information, based on Annexes V, VI, XI and XII of the Regulation
(with sec. 1.2.3 and 1.2.4 of Annex V applicable as of 1 January 2026). This information relates to the
financing of activities specified in Regulation 2021/2139
13
concerning economic activity which
qualifies as contributing substantially to climate change mitigation or climate change adaptation (as
amended by Regulation 2022/1214).
In turn, under Article 10(7) of Regulation 2021/2178, in the period from 1 January 2024 to 31
December 2025, the Group only discloses the percentage indicators of EU Taxonomy eligible and non-
eligible activities (along with relevant qualitative information) – for the activities specified in
Regulation 2023/2485
14
(amending Regulation 2021/2139) and for the activities specified in Regulation
2023/2486 which concerns an economic activity which qualifies as contributing substantially to the
sustainable use and protection of water and marine resources, to the transition to a circular economy,
10
Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of
the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive
2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure
obligation.
11
Commission Delegated Regulation (EU) 2022/1214 of 9 March 2022 amending Delegated Regulation (EU) 2021/2139 as regards economic
activities in certain energy sectors and Delegated Regulation (EU) 2021/2178 as regards specific public disclosures for those economic activities.
12
Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023 supplementing Regulation (EU) 2020/852 of the European Parliament and of
the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as
contributing substantially to the sustainable use and protection of water and marine resources, to the transition to a circular economy, to
pollution prevention and control, or to the protection and restoration of biodiversity and ecosystems and for determining whether that economic
activity causes no significant harm to any of the other environmental objectives and amending Commission Delegated Regulation (EU) 2021/2178
as regards specific public disclosures for those economic activities.
13
Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of
the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as
contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes
no significant harm to any of the other environmental objectives.
14
Commission Delegated Regulation (EU) 2023/2485 of 27 June 2023 amending Delegated Regulation (EU) 2021/2139 establishing additional
technical screening criteria for determining the conditions under which certain economic activities qualify as contributing substantially to climate
change mitigation or climate change adaptation and for determining whether those activities cause no significant harm to any of the other
environmental objectives
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to pollution prevention and control, or to the protection and restoration of biodiversity and
ecosystems.
EU Taxonomy-eligible financing granted by the Group are exposures that finance activities (or
objectives/projects related to these activities) listed in Delegated Regulation 2021/2139 (as
amended) or Delegated Regulation 2023/2486 – irrespective of whether these activities meet the
Taxonomy technical screening criteria for sustainability. For the purpose of preparing the table in
accordance with template 2 of Annex V, we have assumed that the sectors covered by the Taxonomy
are listed in the file available on the EU Taxonomy Navigator website at the date of preparation of
this statement.
EU Taxonomy-aligned financing granted by the Group (green/sustainable financing as defined in
the EU Taxonomy) are exposures that finance activities (or objectives/projects related to these
activities) that meet the substantial contribution criteria and “do no significant harm” (DNSH) criteria
set out in Delegated Regulation 2021/2139 (as amended) or 2023/2486, and are in compliance with
the minimum social safeguards laid down in Article 18 of Regulation 2020/852. EU Taxonomy-aligned
financing is a subset of EU Taxonomy-eligible financing.
Contextual information on key performance indicators for the activities laid down in Regulation
2021/2139 as amended by Regulation 2022/1214
The Bank prepares and discloses quantitative information on key performance indicators for the
activities laid down in Regulation 2021/2139 as amended by Regulation 2022/1214 (i.e. for the
original scope of activities that can substantially contribute to the first two environmental
objectives - climate change mitigation and climate change adaptation) in accordance with the
tabular disclosure templates in Annexes VI and XII of Regulation 2021/2178, as amended. The Bank
also uses Regulation 2023/2486 with regard to the eligibility aspect.
Annex V of Regulation 2021/2178 (taking into account the amendments introduced with Regulation
2023/2486) distinguishes between the following (partial) key performance indicators for credit
institutions relating to assets:
1. Total Green Asset Ratio (GAR) for financing activities directed at financial undertakings;
2. Total GAR for financing activities directed at non-financial undertakings;
3. GAR for residential real estate exposures, including house renovation loans (for the objective
of climate change mitigation);
4. Green Asset Ratio (GAR) for retail car loans (for the objective of climate change mitigation);
5. Green Asset Ratio (GAR) for loans to local governments for house financing and other use-of-
proceeds lending;
6. Green Asset Ratio (GAR) for commercial and residential repossessed real estate collateral
held for sale (repossessed in the collection process).
Total GAR is an indicator that accumulates all the partial ratios listed in items 1-6 above.
For each of the above indicators of EU Taxonomy-aligned exposures, the disclosure templates set out
in Annexes VI and XII of Regulation 2021/2178 also provide for the disclosure of the corresponding
percentages of EU taxonomy-eligible assets.
Additionally, Annex V to Regulation 2021/2178 requires the Group to disclose key EU Taxonomy
indicators with respect to off-balance sheet exposures - i.e. for certain financial guarantees issued
and for assets managed by the investment fund company (TFI) belonging to the Bank’s Group.
The Bank discloses quantitative information on the above indicators using detailed tabular formulas
laid down in Annex VI to Regulation 2021/2178.
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For exposures to financial and non-financial undertakings included in the partial indicators on assets
and off-balance sheet items, the Group has adopted the following methodology to assess EU Taxonomy
eligibility and alignment, in accordance with the requirements of Annex V of Regulation 2021/2178:
• for general purpose financing – the assessment of eligibility and alignment is based on the EU
Taxonomy key performance indicators, for revenue and capital expenditure (CapEx) published by
the Group's customers and by identified subsidiaries of the Group's clients or by parent companies
of the Group's clients
15
– therefore, in accordance with the requirements in Regulation
2021/2178, the Group calculates its key performance indicators twice (first on the basis of
its clients’ revenue indicators and second on the basis of its clients’ CapEx indicators),
• for use-of-proceeds financing – the assessment of eligibility and alignment is based on the Bank’s
own analysis of the characteristics of the purpose of the financing and the information needed to
verify compliance with the technical screening criteria of the EU Taxonomy and minimum social
safeguards.
In the process of determining the key performance indicators for the green asset ratio with regard to
flow, the Bank has taken into account the gross carrying amount as at 31 December 2024 only of those
exposures that were first recognised in the Group’s balance sheet in 2024.
Financing of non-financial and financial undertakings
The Bank identifies entities eligible for inclusion in the GAR numerator (i.e. entities required to report
under the EU Taxonomy themselves (as well as identified subsidiaries of such entities) or included in
such reporting through consolidation by the parent entity) based on the database published by Instrat
Foundation and the database maintained on the ESG Platform developed by Biuro Informacji
Kredytowej S.A and based on expert portfolio review (for subsidiaries of entities included in Instrat’s
database and for entities located outside Poland). The same approach was applied to financial
undertakings.
Financing of households
For the purpose of calculating the partial ratio related to the financing of households related to
residential properties, the Group has assumed that:
• all mortgage loans granted for the construction/purchase of a house/apartment are EU
taxonomy-eligible under the “climate change mitigation” environmental objective – activity 7.7,
• the Group assesses the EU Taxonomy alignment of mortgage loans based on the technical
screening criteria as defined in Regulation 2021/2139 (as amended) based on data from building
energy performance certificates and physical risk maps for Poland (Klimada 2.0), making it
possible to assess whether the location where the financed property is located is not significantly
exposed to flooding or inundations. The Bank has adopted the above risks for assessment, guided
by analyses of the Intergovernmental Panel on Climate Change (IPCC), which specify in detail
types of physical risk material for Central and Eastern Europe, including Poland. The Bank has
found that in the local situation, the key physical risk factors which may adversely affect the
value of collateral of mortgage loans are flooding and inundations. Nevertheless, the Bank will
monitor whether the assessment of physical risks material to Poland is still valid. In the physical
risk assessment, the Bank has followed the Methodology for identification of increased physical
risk in the mortgage portfolio, adopted by the Bank. The Bank identifies an increased physical
risk in the mortgage loan portfolio per exposure, according to the location of the collateral in
the form of real property.
15
For the Group’s customers that are financial undertakings, the Group uses the taxonomy indicators published by the Group’s
customers and based on the revenues or on the capital expenditures of the entities financed by the Group’s customers.
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If it follows from our analysis that there is a significant risk for the respective location, the Bank
excludes the exposure from the portfolio of Taxonomy-aligned loans.
• To establish compliance with the technical screening criteria, it has been assessed whether the
financed buildings:
a. built after 31 December 2020 meet the standards of primary energy need at least 10%
lower than the threshold defined for nearly zero-energy buildings under national
measures implementing Directive 2010/31/EU of the European Parliament and of the
Council,
b. built before 31 December 2020 belong to 15% of the most efficient buildings in Poland.
For the purpose of defining qualification thresholds for 15% of the most energy-
efficient buildings in Poland, the Bank has applied the primary energy demand limits
published by the Ministry of Economic Development and Technology (Taxonomy of
sustainable financing of investments – buildings – Ministry of Economic Development
and Technology – gov.pl portal).
• To assess compliance with the above criteria, the Bank has based its decisions on data acquired
from energy performance certificates found in the Central Register of Energy Performance of
Buildings maintained by the Minister of Economic Development and Technology. To ensure the
highest data quality, the Bank has solicited the support of an external firm specializing in data
regarding the Polish real estate market, which has performed an additional verification of the
data from the said register.
• In assessing compliance with the EU Taxonomy for retail mortgage loans, the Bank has taken the
following approach to the issue of investigating minimum social safeguards. The Bank has
concluded that, in respect of real property sellers who are natural persons, investigating this
issue is unfeasible in practice. As for real properties purchased on the primary market, with
regard to property development companies erecting buildings and apartments financed by the
Bank, the Bank has assumed that the minimum social safeguards are met. The justification for
this approach is that the Bank only finances real properties built on the Polish market, and
Poland is a country that observes the UN Guidelines on Business and Human Rights and the OECD
Guidelines for Multinational Enterprises. Poland is also one of the founders of the International
Labour Organization and abides by the principles adopted by this organisation. In particular, the
provisions of the Labour Code ensure respect for human rights in relations with employees. The
Bank has no information about any controversies regarding human rights violations by real
property development companies operating in Poland.
• Household loan products related to improving the energy efficiency of residential properties are
considered EU Taxonomy-eligible under the “climate change mitigation” environmental
objective, while in the current reporting cycle the Bank does not have the source data to reliably
assess the EU Taxonomy alignment of these credit products.
At year-end 2024, the Bank does not identify any assets in its portfolio that could qualify for partial
indices for consumer car financing, for use-of-proceeds financing for local governments, or for real
estate taken into the Bank's ownership in the loan loss recovery process.
Approach to the Bank Millennium Group entities
In the Taxonomy-related disclosures of the Group, the Bank did not single out data about Millennium
Leasing.
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Contextual information on key performance indicators for the activities laid down in Regulations
2023/2485 and 2023/2486
In accordance with Article 10(7) of Regulation 2021/2178, for the period from 1 January 2024 to 31
December 2025, and for the activities laid down in Regulations 2023/2485 and 2023/2486 (i.e. for the
new extended scope of activities that can substantially contribute to one or more of the six
environmental objectives specified in the EU Taxonomy), the Group only discloses the percentage
indicators of EU Taxonomy eligible and non-eligible activities (along with relevant qualitative
information).
The Group has reviewed its portfolio (from a balance sheet and off-balance sheet perspective) with
respect to its eligibility for the above-mentioned activities and concluded that the loans related to
residential real estate granted by the Bank to consumers and use-of-proceeds financing for businesses
qualify only for the original scope of activities under the climate change mitigation objective and do
not qualify for the “new” activities. With regard to general financing for financial and non-financial
undertakings, information about eligibility for other objectives was determined on the basis of non-
financial statements of customers for 2023 because these are the most recent reliable data published
by the Bank’s customers as at the date of the publication of this report.
Description of alignment with EU Taxonomy in the Group's business strategy, product design
processes and engagement with customers and business partners
Over 95% of EU Taxonomy-aligned exposures are mortgage loans for households. The change from the
green asset ratio presented last year is due to the constitution of the alignment assessment approach
for the mortgage portfolio, whereby the Group decided to disclose alignment in this portfolio – in the
previous year, zero Taxonomy alignment was reported for this portfolio. The degree of alignment of
newly issued mortgage financing is dependent on energy performance of residential buildings, which,
according to existing regulations in this area, should improve in the future.
With respect to off-balance sheet exposures, the Group has recorded an increase in the green asset
ratio for managed assets especially visible in the key performance indicator for off-balance sheet
exposures regarding capital expenditures. This shows increased efforts of entities in the Millennium
TFI portfolio to invest in sustainable businesses and the increase in entities reporting sustainability
data compared to the previous year.
The Bank Millennium Group takes steps aimed at developing the portfolio of assets financing
Taxonomy-aligned activities.
The Bank Millennium Group’s Strategy for 2025-2028 – Value and Growth contains objectives of
actively supporting customers in their decarbonization efforts and granting PLN 5 billion of financing
for sustainable for the customers of the Bank’s Group over the next 4 years.
Our goal is to launch an offering of products that would support sustainability in various business
segments in the areas of energy efficiency, the use of renewable energy sources and the circular
economy, as well as to increase the financing allocated to sustainability projects through active
participation in governmental and EU transition programs to reduce adverse environmental impacts.
The Bank is taking proactive measures aiming to build a portfolio of assets that finance
environmentally sustainable activities, while adhering to the Environmental Policy and the
Responsible Financing Policy. The Bank has implemented a comprehensive project to build and
implement a process for classifying green assets – based on the Bank’s internal business criteria based
on best market practices and based on the EU Taxonomy.
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Quantitative disclosure in accordance with the templates specified in Annex VI to Regulation
2021/2178
1.0 Summary of key performance indicators to be disclosed by credit institutions under Article 8 of
the Taxonomy Regulation
1.1.1 Assets for the calculation of the Green Asset Ratio – turnover-based – for 2024
1.1.2. Assets for the calculation of the Green Asset Ratio – turnover-based – for 2023
1.2.1 Assets for the calculation of the Green Asset Ratio - capital expenditures-based – for 2024
1.2.2 Assets for the calculation of the Green Asset Ratio - capital expenditures-based – for 2023
2.1 GAR sector information - turnover-based
2.2 GAR sector information – capital expenditures-based
3.1.1 GAR KPI stock - turnover-based – for 2024
3.1.2 GAR KPI stock - turnover-based – for 2023
3.2.1 GAR KPI stock - capital expenditures-based – for 2024
3.2.2 GAR KPI stock - capital expenditures-based – for 2023
4.1 GAR KPI flow - turnover-based
4.2 GAR KPI flow - capital expenditures-based
5.1 KPI off-balance sheet exposures - turnover-based
5.2 KPI off-balance sheet exposures - capital expenditures-based
6. Quantitative disclosures prepared in accordance with the formulas laid down in Annex XII of
Regulation 2021/2178 - Nuclear and fossil gas related disclosures
With regard to tables:
1.1.2 Assets for the calculation of the Green Asset Ratio – turnover-based – for 2023
1.2.2 Assets for the calculation of the Green Asset Ratio - capital expenditures-based – for 2023
3.1.2 GAR KPI stock - turnover-based – for 2023
3.2.2 GAR KPI stock - capital expenditures-based – for 2023
an adjustment was made to data presented in 2023 in the item “26. Households/including loans for
renovation of buildings”. The adjustment resulted from an error concerning the failure to disclose
loans for renovation of buildings worth PLN 743,618 thousand.
282
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
1.0 Summary of key performance indicators to be disclosed by credit institutions under Article 8 of the Taxonomy Regulation
Total environmentally
sustainable assets
(PLN '000)
KPI**** KPI***** % coverage (over total assets)***
% of assets excluded from
the numerator of the GAR
(Article 7 (2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded from
the denominator of the GAR
(Article 7 (1)) and Section
1.2.4 of Annex V)
Main KPI Green asset ratio (GAR) stock 1 312 050 1.53% 1.57% 60.66% 17.52% 39.34%
Total environmentally
sustainable activities
(PLN '000)
KPI KPI % coverage (over total assets)
% of assets excluded from
the numerator of the GAR
(Article 7 (2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded from
the denominator of the GAR
(Article 7 (1)) and Section
1.2.4 of Annex V)
Additional
KPIs
GAR (flow) 232 513 1.19% 1.26% 48.03% 19.01% 51.97%
Trading book* n/a n/a n/a
Financial guarantees 0 0.00% 0.00%
Assets under management 69 273 1.93% 7.46%
Fees and commissions income** n/a n/a n/a
* For credit institutions that do not meet the conditions of Article 94(1) of the CRR or the conditions set out in Article 325a(1) of the CRR
** Fees and commissions income from services other than lending and AuM
*** % of assets covered by the KPI over banks´ total assets
**** Based on the Turnover KPI of the counterparty
***** Based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
283
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
1.1.1 Assets for the calculation of the Green Asset Ratio – turnover-based – for 2024
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
61 117 549 33 759 730 1 262 442 1 248 699 6 912 0 50 270 49 588 0 49 587 0 0 0 0 5 785 0 0 0 222 20 0 0 1 049 0 0 0 33 817 056 1 312 050 1 248 699 6 912 50 636
2 FINANCIAL UNDERTAKINGS 10 000 7 900 40 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 7 900 40 0 0 0
3 Credit institutions 10 000 7 900 40 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 7 900 40 0 0 0
4 Loans and advances 10 000 7 900 40 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 7 900 40 0 0 0
5 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
6 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
7 Other financial corporations 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
8 of which investment firms 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
9 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
10 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
11 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
12 of which management companies 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
13 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
14 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
15 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
16 of which insurance undertakings 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
17 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
18 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
19 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
20 NON-FINANCIAL UNDERTAKINGS 2 142 263 219 182 14 753 1 050 6 912 0 50 270 49 588 0 49 587 0 0 0 5 785 0 0 0 222 20 0 0 1 049 0 0 0 276 508 64 361 1 050 6 912 50 636
21 Loans and advances 2 142 263 219 182 14 753 1 050 6 912 0 50 270 49 588 0 49 587 0 0 0 0 5 785 0 0 0 222 20 0 0 1 049 0 0 0 276 508 64 361 1 050 6 912 50 636
22 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
23 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
24 HOUSEHOLDS 58 945 050 33 532 510 1 247 649 1 247 649 0 0 0 0 0 0 0 0 0 0 0 33 532 510 1 247 649 1 247 649 0 0
25 of which loans collateralised by residential immovable property 38 972 436 32 811 481 1 247 649 1 247 649 0 0 0 0 0 0 0 0 0 0 32 811 481 1 247 649 1 247 649 0 0
26 of which building renovation loans 721 030 721 030 0 0 0 0 0 0 0 0 0 0 0 0 0 0 721 030 0 0 0 0
27 of which motor vehicle loans 0 0 0 0 0 0 0 0 0 0 0
28 LOCAL GOVERNMENTS FINANCING 20 098 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
29 Housing financing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
30 Other local government financing 20 098 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
31
Collateral obtained by taking possession: residential and commercial
immovable properties
137 137 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 137 0 0 0 0
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
24 827 606
33 FINANCIAL AND NON-FINANCIAL UNDERTAKINGS 16 145 685
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure
16 093 892
35 Loans and advances 16 046 050
36 of which loans collateralised by commercial immovable property 2 146 391
37 of which building renovation loans 0
38 Debt securities 4 996
39 Equity instruments 42 845
40
Non-EU country counterparties not subject to NFRD disclosure
51 793
41 Loans and advances 4
42 Debt securities 51 790
43 Equity instruments 0
44 Derivatives 112 365
45 On demand interbank loans 278 897
46 Cash and cash-related assets 1 065 998
47 Other categories of assets (e.g. Goodwill, commodities etc.) 7 224 660
48 Total GAR assets 85 945 155 33 759 730 1 262 442 1 248 699 6 912 0 50 270 49 588 0 49 587 0 0 0 0 5 785 0 0 0 222 20 0 0 1 049 0 0 0 33 817 056 1 312 050 1 248 699 6 912 50 636
49 Assets not covered for GAR calculation 55 745 359
50 Central governments and Supranational issuers 42 128 826
51 Central banks exposure 12 805 210
52 Trading book 811 324
53 Total assets 141 690 514 33 759 730 1 262 442 1 248 699 6 912 0 50 270 49 588 0 49 587 0 0 0 0 5 785 0 0 0 222 20 0 0 1 049 0 0 0 33 817 056 1 312 050 1 248 699 6 912 50 636
54 Financial guarantees 7 017 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
55 Assets under management 3 587 357 286 112 60 016 0 151 46 109 29 486 9 257 0 3 108 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 315 598 69 273 0 151 49 217
56 Of which debt securities 1 457 593 226 098 44 567 0 61 37 137 7 902 61 0 61 0 0 0 0 160 0 0 0 0 0 0 0 0 0 0 0 234 161 44 627 0 61 37 197
57 Of which equity instruments 2 144 352 60 013 15 449 0 90 8 972 21 584 9 197 0 3 047 0 0 0 0 735 0 0 0 10 1 0 0 9 0 0 0 82 352 24 646 0 90 12 020
PLN '000
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
Climate Change Mitigation (CCM)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Total [gross] carrying
amount
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
2024-12-31
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
284
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
1.1.2. Assets for the calculation of the Green Asset Ratio – turnover-based – for 2023
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
60 810 439 34 756 120 8 736 1 384 7 006 0 111 509 16 933 0 3 799 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 34 867 629 25 669 1 384 7 006 3 799
2 FINANCIAL UNDERTAKINGS 45 028 6 305 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6 305 0 0 0 0
3 Credit institutions 45 000 6 305 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6 305 0 0 0 0
4 Loans and advances 45 000 6 305 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6 305 0 0 0 0
5 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
6 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
7 Other financial corporations 28 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
8 of which investment firms 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
9 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
10 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
11 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
12 of which management companies 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
13 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
14 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
15 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
16 of which insurance undertakings 28 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
17 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
18 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
19 Equity instruments 28 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
20 NON-FINANCIAL UNDERTAKINGS 2 247 842 290 923 8 736 1 384 7 006 0 111 509 16 933 0 3 799 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 402 432 25 669 1 384 7 006 3 799
21 Loans and advances 2 247 791 290 923 8 736 1 384 7 006 0 111 509 16 933 0 3 799 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 402 432 25 669 1 384 7 006 3 799
22 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
23 Equity instruments 51 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
24 HOUSEHOLDS 58 501 637 34 458 893 0 0 0 0 0 0 0 0 0 0 0 0 0 34 458 893 0 0 0 0
25 of which loans collateralised by residential immovable property 39 718 308 33 715 274 0 0 0 0 0 0 0 0 0 0 0 0 33 715 274 0 0 0 0
26 of which building renovation loans 743 618 743 618 0 0 0 0 0 0 0 0 0 0 0 0 0 0 743 618 0 0 0 0
27 of which motor vehicle loans 0 0 0 0 0 0 0 0 0 0 0
28 LOCAL GOVERNMENTS FINANCING 15 793 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
29 Housing financing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
30 Other local government financing 15 793 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
31
Collateral obtained by taking possession: residential and commercial
immovable properties
137 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
22 816 411
33 FINANCIAL AND NON-FINANCIAL UNDERTAKINGS 18 055 270
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure
15 090 354
35 Loans and advances 15 068 392
36 of which loans collateralised by commercial immovable property 2 510 843
37 of which building renovation loans 0
38 Debt securities 4 996
39 Equity instruments 16 966
40
Non-EU country counterparties not subject to NFRD disclosure
81 016
41 Loans and advances 2
42 Debt securities 81 014
43 Equity instruments 0
44 Derivatives 74 213
45 On demand interbank loans 571 581
46 Cash and cash-related assets 919 265
47 Other categories of assets (e.g. Goodwill, commodities etc.) 3 115 065
48 Total GAR assets 83 626 850 34 756 120 8 736 1 384 7 006 0 111 509 16 933 0 3 799 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 34 867 629 25 669 1 384 7 006 3 799
49 Assets not covered for GAR calculation 44 429 960
50 Central governments and Supranational issuers 29 848 241
51 Central banks exposure 13 972 795
52 Trading book 608 923
53 Total assets 128 056 809 34 756 120 8 736 1 384 7 006 0 111 509 16 933 0 3 799 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 34 867 629 25 669 1 384 7 006 3 799
54 Financial guarantees 7 589 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
55 Assets under management 2 920 117 178 578 26 603 0 114 18 146 2 115 2 543 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 180 694 29 146 0 114 18 146
56 Of which debt securities 1 027 682 146 238 14 119 0 0 12 489 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 146 238 14 119 0 0 12 489
57 Of which equity instruments 1 834 630 32 340 12 484 0 114 5 657 2 115 2 543 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 34 456 15 027 0 114 5 657
PLN '000
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
Climate Change Mitigation (CCM)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Total [gross] carrying
amount
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
2023-12-31
285
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
1.2.1 Assets for the calculation of the Green Asset Ratio - capital expenditures-based – for 2024
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not eligible
for GAR calculation
61 117 549 34 313 620 1 345 094 1 248 699 22 738 4 655 46 416 5 710 0 5 594 6 0 0 0 33 943 0 0 222 533 40 0 0 1 310 0 0 0 34 395 829 1 350 844 1 248 699 22 738 10 471
2 FINANCIAL UNDERTAKINGS 10 000 8 100 50 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8 100 50 0 0 0
3 Credit institutions 10 000 8 100 50 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8 100 50 0 0 0
4 Loans and advances 10 000 8 100 50 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8 100 50 0 0 0
5 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
6 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
7 Other financial corporations 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
8 of which investment firms 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
9 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
10 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
11 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
12 of which management companies 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
13 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
14 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
15 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
16 of which insurance undertakings 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
17 Loans and advances 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
18 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
19 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
20 NON-FINANCIAL UNDERTAKINGS 2 142 263 772 872 97 395 1 050 22 738 4 655 46 416 5 710 0 5 594 6 0 0 33 943 0 0 222 533 40 0 0 1 310 0 0 0 855 081 103 145 1 050 22 738 10 471
21 Loans and advances 2 142 263 772 872 97 395 1 050 22 738 4 655 46 416 5 710 0 5 594 6 0 0 0 33 943 0 0 222 533 40 0 0 1 310 0 0 0 855 081 103 145 1 050 22 738 10 471
22 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
23 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
24 HOUSEHOLDS 58 945 050 33 532 510 1 247 649 1 247 649 0 0 0 0 0 0 0 0 0 0 0 33 532 510 1 247 649 1 247 649 0 0
25 of which loans collateralised by residential immovable property 38 972 436 32 811 481 1 247 649 1 247 649 0 0 0 0 0 0 0 0 0 0 32 811 481 1 247 649 1 247 649 0 0
26 of which building renovation loans 721 030 721 030 0 0 0 0 0 0 0 0 0 0 0 0 0 0 721 030 0 0 0 0
27 of which motor vehicle loans 0 0 0 0 0 0 0 0 0 0 0
28 LOCAL GOVERNMENTS FINANCING 20 098 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
29 Housing financing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
30 Other local government financing 20 098 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
31
Collateral obtained by taking possession: residential and commercial
immovable properties
137 137 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 137 0 0 0 0
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
24 827 606
33 FINANCIAL AND NON-FINANCIAL UNDERTAKINGS 16 145 685
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure
16 093 892
35 Loans and advances 16 046 050
36 of which loans collateralised by commercial immovable property 2 146 391
37 of which building renovation loans 0
38 Debt securities 4 996
39 Equity instruments 42 845
40 Non-EU country counterparties not subject to NFRD disclosure obligations 51 793
41 Loans and advances 4
42 Debt securities 51 790
43 Equity instruments 0
44 Derivatives 112 365
45 On demand interbank loans 278 897
46 Cash and cash-related assets 1 065 998
47 Other categories of assets (e.g. Goodwill, commodities etc.) 7 224 660
48 Total GAR assets 85 945 155 34 313 620 1 345 094 1 248 699 22 738 4 655 46 416 5 710 0 5 594 6 0 0 0 33 943 0 0 222 533 40 0 0 1 310 0 0 0 34 395 829 1 350 844 1 248 699 22 738 10 471
49 Assets not covered for GAR calculation 55 745 359
50 Central governments and Supranational issuers 42 128 826
51 Central banks exposure 12 805 210
52 Trading book 811 324
53 Total assets 141 690 514 34 313 620 1 345 094 1 248 699 22 738 4 655 46 416 5 710 0 5 594 6 0 0 0 33 943 0 0 222 533 40 0 0 1 310 0 0 0 34 395 829 1 350 844 1 248 699 22 738 10 471
54 Financial guarantees 7 017 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
55 Assets under management 3 587 357 483 349 253 090 0 25 717 190 682 90 811 15 066 0 706 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 574 160 268 156 0 25 717 191 388
56 Of which debt securities 1 457 593 377 760 222 332 0 23 062 174 145 53 732 663 0 0 244 0 0 0 319 0 0 0 46 0 0 0 0 0 0 0 432 100 222 996 0 23 062 174 145
57 Of which equity instruments 2 144 352 105 589 30 758 0 2 655 16 537 37 080 14 403 0 706 123 0 0 0 9 974 0 0 0 28 2 0 0 12 0 0 0 152 805 45 162 0 2 655 17 243
2024-12-31
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
PLN '000
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
Climate Change Mitigation (CCM)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Total [gross]
carrying
amount
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
286
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
1.2.2 Assets for the calculation of the Green Asset Ratio - capital expenditures-based – for 2023
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
60 810 439 35 194 563 72 847 1 384 1 737 1 895 126 400 4 639 0 3 550 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 35 320 963 77 487 1 384 1 737 5 445
2
FINANCIAL UNDERTAKINGS
45 028 3 231 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 231 0 0 0 0
3
Credit institutions
45 000 3 231 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 231 0 0 0 0
4
Loans and advances
45 000 3 231 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 231 0 0 0 0
5
Debt securities, including UoP
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
6
Equity instruments
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
7
Other financial corporations
28 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
8
of which investment firms
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
9
Loans and advances
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
10
Debt securities, including UoP
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
11
Equity instruments
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
12
of which management companies
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
13
Loans and advances
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
14
Debt securities, including UoP
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
15
Equity instruments
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
16
of which insurance undertakings
28 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
17
Loans and advances
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
18
Debt securities, including UoP
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
19
Equity instruments
28 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
20
NON-FINANCIAL UNDERTAKINGS
2 247 842 732 439 72 847 1 384 1 737 1 895 126 400 4 639 0 3 550 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 858 839 77 487 1 384 1 737 5 445
21
Loans and advances
2 247 791 732 439 72 847 1 384 1 737 1 895 126 400 4 639 0 3 550 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 858 839 77 487 1 384 1 737 5 445
22
Debt securities, including UoP
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
23
Equity instruments
51 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
24
HOUSEHOLDS
58 501 637 34 458 893 0 0 0 0 0 0 0 0 0 0 0 0 0 34 458 893 0 0 0 0
25
of which loans collateralised by residential immovable property
39 718 308 33 715 274 0 0 0 0 0 0 0 0 0 0 0 0 33 715 274 0 0 0 0
26
of which building renovation loans
743 618 743 618 0 0 0 0 0 0 0 0 0 0 0 0 0 0 743 618 0 0 0 0
27
of which motor vehicle loans
0 0 0 0 0 0 0 0 0 0 0
28
LOCAL GOVERNMENTS FINANCING
15 793 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
29
Housing financing
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
30
Other local government financing
15 793 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
31
Collateral obtained by taking possession: residential and commercial
immovable properties
137 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
22 816 411
33
FINANCIAL AND NON-FINANCIAL UNDERTAKINGS
18 055 270
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure
15 090 354
35
Loans and advances
15 068 392
36
of which loans collateralised by commercial immovable property
2 510 843
37
of which building renovation loans
0
38
Debt securities
4 996
39
Equity instruments
16 966
40
Non-EU country counterparties not subject to NFRD disclosure
81 016
41
Loans and advances
2
42
Debt securities
81 014
43
Equity instruments
0
44
Derivatives
74 213
45
On demand interbank loans
571 581
46
Cash and cash-related assets
919 265
47
Other categories of assets (e.g. Goodwill, commodities etc.)
3 115 065
48
Total GAR assets
83 626 850 35 194 563 72 847 1 384 1 737 1 895 126 400 4 639 0 3 550 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 35 320 963 77 487 1 384 1 737 5 445
49
Assets not covered for GAR calculation
44 429 960
50
Central governments and Supranational issuers
29 848 241
51
Central banks exposure
13 972 795
52
Trading book
608 923
53
Total assets
128 056 809 35 194 563 72 847 1 384 1 737 1 895 126 400 4 639 0 3 550 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 35 320 963 77 487 1 384 1 737 5 445
54 Financial guarantees 7 589 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
55 Assets under management 2 920 117 208 129 91 771 0 3 042 66 636 6 580 5 431 0 628 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 214 709 97 201 0 3 042 67 264
56 Of which debt securities 1 027 682 128 447 66 621 0 1 860 56 658 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 128 447 66 621 0 1 860 56 658
57 Of which equity instruments 1 834 630 79 682 25 149 0 1 182 9 978 6 580 5 431 0 628 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 86 262 30 580 0 1 182 10 606
PLN '000
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
Climate Change Mitigation (CCM)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Total [gross]
carrying amount
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which environmentally sustainable (Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
2023-12-31
287
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
2.1 GAR sector information – turnover-based
a b c
d e f g h i j k l m n o p q r s t u v w x y z aa ab
PLN '000
Of which
environmentally
sustainable (CCM)
PLN '000
Of which
environmentally
sustainable (CCM)
PLN '000
Of which
environmentally
sustainable (CCA)
PLN '000
Of which
environmentally
sustainable (CCA)
PLN '000
Of which
environmentally
sustainable (W TR)
PLN '000
Of which
environmentally
sustainable (W TR)
PLN '000
Of which
environmentally
sustainable (CE)
PLN '000
Of which
environmentally
sustainable (CE)
PLN '000
Of which
environmentally
sustainable (PPC)
PLN '000
Of which
environmentally
sustainable (PPC)
PLN '000
Of which
environmentally
sustainable (BIO)
PLN '000
Of which
environmentally
sustainable (BIO)
PLN '000
Of which environmentally
sustainable (CCM + CCA +
WTR + CE + PPC + BIO)
PLN '000
Of which
environmentally
sustainable (CCM + CCA
+ WTR + CE + PPC +
BIO)
1
21.20 - M anufacture of medicines and other pharmaceutical
products
328 0 0 0 0 0 0 0 0 0 0 0 327,65 0,01
2
22.22 - M anufacture of plas tic packing goods 546 0 0 0 0 0 0 0 0 0 0 0 546,46 0,00
3
24.10 - M anufacture of pig iron, ferro-alloys, basic iron and steel
and metallurgic articles
1 054 0 0 0 0 0 0 0 0 0 0 0 1 053,69 0,00
4
24.51 - Casting of iron 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
5
25.11 - M anufacture of metal structures and parts of s tructures 917 93 0 0 0 0 0 0 0 0 0 0 916,99 93,32
6
25.12 - M anufacture of metal elements of building woodwork 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
7
25.29 - M anufacture of other tanks, reservoirs and containers of
metal
0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
8
26.51 - M anufacture of instruments and appliances for measuring,
testing and navigation
0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
9
27.51 - M anufacture of electric domestic appliances 3 842 0 159 1 0 0 122 0 0 0 21 0 4 144,00 0,97
10
29.32 - M anufacture of other parts and accessories for motor
vehicles excluding motorcycles
8 0 8 0 0 0 30 0 0 0 0 0 46,66 0,00
11
30.20 - M anufacture of railway locomotives and rolling stock 5 4 0 0 0 0 0 0 0 0 0 0 4,66 3,89
12
33.13 - Repair and maintenance of electronic and optical
equipment
0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
13
33.20 - Installation of industrial machinery and equipment 2 646 0 0 0 0 0 0 0 0 0 0 0 2 645,84 0,00
14
38.11 - Collection of non-hazardous waste 1 347 0 0 0 0 0 0 0 0 0 0 0 1 347,33 0,00
15
38.22 - Hazardous waste processing and neutralizing 501 0 0 0 0 0 0 0 0 0 0 0 501,11 0,00
16
41.10 - Realization of building projects related to erection of
buildings
289 0 0 0 0 0 0 0 0 0 0 0 288,51 0,00
17
41.20 - Building works related to erection of residential and non-
residential buildings
5 092 71 0 0 0 0 0 0 0 0 0 0 5 091,68 71,31
18
42.11 - W orks related to construction of roads and motorways 5 155 0 0 0 0 0 0 0 0 0 0 0 5 155,00 0,00
19
42.12 - W orks related to construction of railways and underground
railways
43 751 0 0 0 0 0 0 0 0 0 0 0 43 751,22 0,00
20
42.99 - W orks related to construction of other civil engineering
projects not elsewhere classified
594 0 0 0 0 0 0 0 0 0 0 0 594,02 0,00
21
43.99 - Other specialised construction activities not elsewhere
classified
2 580 77 0 0 0 0 0 0 0 0 0 0 2 579,90 76,73
22
46.18 - Agents specialised in the sale of other particular products 31 0 0 0 0 0 0 0 0 0 0 0 30,88 0,00
23
46.35 - W holesale of tobacco products 12 0 0 0 0 0 0 0 0 0 0 0 12,47 0,00
24
46.46 - W holesale of pharmaceutical goods 5 901 0 60 0 0 0 0 0 222 20 0 0 6 183,23 20,14
25
46.51 - W holesale of computers, peripheral equipment and
software
596 0 35 0 0 0 2 306 0 0 0 0 0 2 937,56 0,00
26
46.71 - W holesale of fuels and related products 6 868 0 0 0 0 0 0 0 0 0 0 0 6 868,47 0,00
27
46.90 - Non-specialised wholesale trade 1 303 0 0 0 0 0 0 0 0 0 0 0 1 303,33 0,00
28
47.11 - Retail sale in non-specialised stores with food, beverages
or tobacco predominating
70 70 0 0 0 0 0 0 0 0 0 0 69,51 69,51
29
47.19 - Other retail sale in non-specialised stores 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
30
47.99 - Other retail sale not in stores, stalls or markets 251 0 0 0 0 0 0 0 0 0 0 0 250,85 0,00
31
49.50 - Transport via pipeline 1 0 0 0 0 0 0 0 0 0 0 0 0,63 0,21
32
52.21 - S ervice activities incidental to land transportation 7 854 0 0 0 0 0 0 0 0 0 0 0 7 853,51 0,00
33
52.24 - Cargo handling 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
34
52.29 - Other transportation support activities 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
35
60.20 - Public and licence television programmes broadcasting 0 0 0 0 0 0 0 0 0 0 0 0 0,16 0,15
36
61.10 - W ired telecommunications activities 979 979 0 0 0 0 0 0 0 0 0 0 979,14 979,14
37
61.20 - W ireless telecommunications activities, excluding satellite
telecommunications activities
14 518 11 242 44 935 44 935 0 0 0 0 0 0 931 0 60 384,48 56 177,22
38
61.30 - S atellite telecommunications activities 1 503 1 164 4 652 4 652 0 0 0 0 0 0 96 0 6 251,19 5 815,64
39
62.01 - Computer programming activities 37 0 0 0 0 0 0 0 0 0 0 0 36,60 0,00
40
65.12 - Other personal and property insurance 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
41
68.20 - Rental and operating of own or leased real estate 172 0 0 0 0 0 0 0 0 0 0 0 171,76 0,00
42
71.12 - Engineering activities and related technical consultancy 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
43
72.11 - Research and experimental development on biotechnology 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
[Gross] carrying amount
[Gross] carrying amount
TOTAL (CCM + CCA + WMR + CE + PPC + BIO)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Breakdown by sector - NACE 4 digits level (code and label)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and mar ine resources (WTR)
Circular economy (CE)
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
288
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
2.2 GAR sector information – capital expenditures-based
a b c
d e f g h i j k l m n o p q r s t u v w x y z aa ab
PLN '000
Of which
environmentally
sustainable (CCM)
PLN '000
Of which
environmentally
sustainable (CCM)
PLN '000
Of which
environmentally
sustainable (CCA)
PLN '000
Of which
environmentally
sustainable (CCA)
PLN '000
Of which
environmentally
sustainable (W TR)
PLN '000
Of which
environmentally
sustainable (W TR)
PLN '000
Of which
environmentally
sustainable (CE)
PLN '000
Of which
environmentally
sustainable (CE)
PLN '000
Of which
environmentally
sustainable (PPC)
PLN '000
Of which
environmentally
sustainable (PPC)
PLN '000
Of which
environmentally
sustainable (BIO)
PLN '000
Of which
environmentally
sustainable (BIO)
PLN '000
Of which environmentally
sustainable (CCM + CCA +
WTR + CE + PPC + BIO)
PLN '000
Of which
environmentally
sustainable (CCM + CCA
+ WTR + CE + PPC +
BIO)
1
21.20 - M anufacture of medicines and other pharmaceutical
products
339 1 0 0 0 0 0 0 0 0 0 0 338,84 1,26
2
22.22 - M anufacture of plas tic packing goods 546 0 0 0 0 0 0 0 0 0 0 0 546,46 0,00
3
24.10 - M anufacture of pig iron, ferro-alloys, basic iron and steel
and metallurgic articles
1 054 0 0 0 0 0 0 0 0 0 0 0 1 053,69 0,00
4
24.51 - Casting of iron 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
5
25.11 - M anufacture of metal structures and parts of s tructures 123 11 0 0 0 0 0 0 0 0 0 0 122,79 10,56
6
25.12 - M anufacture of metal elements of building woodwork 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
7
25.29 - M anufacture of other tanks, reservoirs and containers of
metal
0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
8
26.51 - M anufacture of instruments and appliances for measuring,
testing and navigation
0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
9
27.51 - M anufacture of electric domestic appliances 5 312 0 2 117 0 0 0 0 0 0 0 17 0 7 445,36 0,00
10
29.32 - M anufacture of other parts and accessories for motor
vehicles excluding motorcycles
18 6 18 0 0 0 10 0 0 0 0 0 45,78 6,17
11
30.20 - M anufacture of railway locomotives and rolling stock 4 3 0 0 0 0 0 0 0 0 0 0 4,13 3,22
12
33.13 - Repair and maintenance of electronic and optical
equipment
0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
13
33.20 - Installation of industrial machinery and equipment 2 646 0 0 0 0 0 0 0 0 0 0 0 2 645,84 0,00
14
38.11 - Collection of non-hazardous waste 1 347 0 0 0 0 0 0 0 0 0 0 0 1 347,33 0,00
15
38.22 - Hazardous waste processing and neutralizing 501 0 0 0 0 0 0 0 0 0 0 0 501,11 0,00
16
41.10 - Realization of building projects related to erection of
buildings
289 0 0 0 0 0 0 0 0 0 0 0 288,51 0,00
17
41.20 - Building works related to erection of residential and non-
residential buildings
5 092 71 0 0 0 0 0 0 0 0 0 0 5 091,68 71,31
18
42.11 - W orks related to construction of roads and motorways 5 155 0 0 0 0 0 0 0 0 0 0 0 5 155,00 0,00
19
42.12 - W orks related to construction of railways and underground
railways
43 751 0 0 0 0 0 0 0 0 0 0 0 43 751,22 0,00
20
42.99 - W orks related to construction of other civil engineering
projects not elsewhere classified
594 0 0 0 0 0 0 0 0 0 0 0 594,02 0,00
21
43.99 - Other specialised construction activities not elsewhere
classified
1 927 9 0 0 0 0 0 0 0 0 0 0 1 926,85 8,68
22
46.18 - Agents specialised in the sale of other particular products 32 0 0 0 0 0 0 0 0 0 0 0 32,08 0,14
23
46.35 - W holesale of tobacco products 6 107 0 0 0 0 0 0 0 0 0 0 0 6 107,02 0,00
24
46.46 - W holesale of pharmaceutical goods 31 356 2 659 0 0 0 0 0 0 524 40 0 0 31 879,68 2 698,84
25
46.51 - W holesale of computers, peripheral equipment and
software
21 427 1 962 643 0 0 0 0 0 0 0 0 0 22 069,60 1 962,34
26
46.71 - W holesale of fuels and related products 6 868 0 0 0 0 0 0 0 0 0 0 0 6 868,47 0,00
27
46.90 - Non-specialised wholesale trade 24 939 0 0 0 0 0 0 0 0 0 0 0 24 939,49 0,00
28
47.11 - Retail sale in non-specialised stores with food, beverages
or tobacco predominating
37 536 209 37 328 0 0 0 33 783 0 0 0 0 0 108 646,61 208,53
29
47.19 - Other retail sale in non-specialised stores 388 366 33 480 0 0 0 0 0 0 0 0 0 0 388 366,19 33 479,84
30
47.99 - Other retail sale not in stores, stalls or markets 251 0 0 0 0 0 0 0 0 0 0 0 250,85 0,00
31
49.50 - Transport via pipeline 3 2 0 0 0 0 0 0 0 0 0 0 2,75 1,94
32
52.21 - S ervice activities incidental to land transportation 7 854 0 0 0 0 0 0 0 0 0 0 0 7 853,51 0,00
33
52.24 - Cargo handling 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
34
52.29 - Other transportation support activities 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
35
60.20 - Public and licence television programmes broadcasting 0 0 0 0 0 0 0 0 0 0 0 0 0,15 0,13
36
61.10 - W ired telecommunications activities 979 979 0 0 0 0 0 0 0 0 0 0 979,14 979,14
37
61.20 - W ireless telecommunications activities, excluding satellite
telecommunications activities
49 142 45 280 5 104 5 069 0 0 0 0 0 0 1 173 0 55 418,53 50 349,13
38
61.30 - S atellite telecommunications activities 5 087 4 688 528 525 0 0 0 0 0 0 121 0 5 737,10 5 212,30
39
62.01 - Computer programming activities 34 0 0 0 0 0 0 0 0 0 0 0 33,87 0,00
40
65.12 - Other personal and property insurance 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
41
68.20 - Rental and operating of own or leased real estate 172 0 0 0 0 0 0 0 0 0 0 0 171,76 0,00
42
71.12 - Engineering activities and related technical consultancy 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
43
72.11 - Research and experimental development on biotechnology 0 0 0 0 0 0 0 0 0 0 0 0 0,00 0,00
Breakdown by sector - NACE 4 digits level (code and label)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and mar ine resources (WTR)
Circular economy (CE)
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WMR + CE + PPC + BIO)
Pollution (PPC)
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
SMEs and other NFC not subject to NFRD
Non-financial corporates
(subject to NFRD)
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
289
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
3.1.1 GAR KPI stock - turnover-based – for 2024
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
39.28% 1.47% 1.45% 0.01% 0.00% 0.06% 0.06% 0.00% 0.06% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 39.35% 1.53% 1.45% 0.01% 0.06% 71.11%
2 FINANCIAL UNDERTAKINGS 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.01%
3 Credit institutions 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.01%
4 Loans and advances 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.01%
5 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
6 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
7 Other financial corporations 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
8 of which investment firms 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
9 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
10 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
11 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
12 of which management companies 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
13 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
14 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
15 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
16 of which insurance undertakings 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
17 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
18 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
19 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
20 NON-FINANCIAL UNDERTAKINGS 0.26% 0.02% 0.00% 0.01% 0.00% 0.06% 0.06% 0.00% 0.06% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.32% 0.07% 0.00% 0.01% 0.06% 2.49%
21 Loans and advances 0.26% 0.02% 0.00% 0.01% 0.00% 0.06% 0.06% 0.00% 0.06% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.32% 0.07% 0.00% 0.01% 0.06% 2.49%
22 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
23 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
24 HOUSEHOLDS 39.02% 1.45% 1.45% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 39.02% 1.45% 1.45% 0.00% 0.00% 68.58%
25 of which loans collateralised by residential immovable property 38.18% 1.45% 1.45% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 38.18% 1.45% 1.45% 0.00% 0.00% 45.35%
26 of which building renovation loans 0.84% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.84% 0.00% 0.00% 0.00% 0.00% 0.84%
27 of which motor vehicle loans 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
28 LOCAL GOVERNMENTS FINANCING 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
29 Housing financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
30 Other local government financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
32 Total GAR assets 39.28% 1.47% 1.45% 0.01% 0.00% 0.06% 0.06% 0.00% 0.06% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 39.35% 1.53% 1.45% 0.01% 0.06% 100.00%
Climate Change Adaptation (CCA)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
% (compared to total covered assets in the denominator)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
2024-12-31
Water and marine resources (WTR)
Proportion of
total assets
covered
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
290
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
3.1.2 GAR KPI stock - turnover-based – for 2023
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments
not HfT eligible for GAR calculation
41.56% 0.01% 0.00% 0.01% 0.00% 0.13% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 41.69% 0.03% 0.00% 0.01% 0.00% 72.72%
2 Financial undertakings 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.05%
3 Credit institutions 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.05%
4 Loans and advances 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.05%
5 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
6 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
7 Other financial corporations 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
8 of which investment firms 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
9 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
10 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
11 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
12 of which management companies 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
13 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
14 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
15 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
16 of which insurance undertakings 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
17 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
18 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
19 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
20 Non-financial undertakings 0.35% 0.01% 0.00% 0.01% 0.00% 0.13% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.48% 0.03% 0.00% 0.01% 0.00% 2.69%
21 Loans and advances 0.35% 0.01% 0.00% 0.01% 0.00% 0.13% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.48% 0.03% 0.00% 0.01% 0.00% 2.69%
22 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
23 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
24 Households 41.21% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 41.21% 0.00% 0.00% 0.00% 0.00% 69.96%
25 of which loans collateralised by residential immovable property 40.32% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 40.32% 0.00% 0.00% 0.00% 0.00% 47.49%
26 of which building renovation loans 0.89% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.89% 0.00% 0.00% 0.00% 0.00% 0.89%
27 of which motor vehicle loans 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
28 Local governments financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
29 Housing financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
30 Other local government financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
32 Total GAR assets 41.56% 0.01% 0.00% 0.01% 0.00% 0.13% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 41.69% 0.03% 0.00% 0.01% 0.00% 100.00%
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
2023-12-31
Water and marine resources (WTR)
Proportion of
total assets
covered
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
% (compared to total covered assets in the denominator)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Climate Change Adaptation (CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
291
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
3.2.1 GAR KPI stock - capital expenditures-based – for 2024
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
39.93% 1.57% 1.45% 0.03% 0.01% 0.05% 0.01% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.04% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 40.02% 1.57% 1.45% 0.03% 0.01% 71.11%
2 FINANCIAL UNDERTAKINGS 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.01%
3 Credit institutions 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.01%
4 Loans and advances 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.01%
5 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
6 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
7 Other financial corporations 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
8 of which investment firms 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
9 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
10 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
11 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
12 of which management companies 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
13 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
14 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
15 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
16 of which insurance undertakings 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
17 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
18 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
19 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
20 NON-FINANCIAL UNDERTAKINGS 0.90% 0.11% 0.00% 0.03% 0.01% 0.05% 0.01% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.04% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.99% 0.12% 0.00% 0.03% 0.01% 1.51%
21 Loans and advances 0.90% 0.11% 0.00% 0.03% 0.01% 0.05% 0.01% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.04% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.99% 0.12% 0.00% 0.03% 0.01% 1.51%
22 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
23 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
24 HOUSEHOLDS 39.02% 1.45% 1.45% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 39.02% 1.45% 1.45% 0.00% 0.00% 41.60%
25 of which loans collateralised by residential immovable property 38.18% 1.45% 1.45% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 38.18% 1.45% 1.45% 0.00% 0.00% 27.51%
26 of which building renovation loans 0.84% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.84% 0.00% 0.00% 0.00% 0.00% 0.51%
27 of which motor vehicle loans 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
28 LOCAL GOVERNMENTS FINANCING 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01%
29 Housing financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
30 Other local government financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01%
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
32 Total GAR assets 39.93% 1.57% 1.45% 0.03% 0.01% 0.05% 0.01% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.04% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 40.02% 1.57% 1.45% 0.03% 0.01% 100.00%
Climate Change Adaptation (CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
% (compared to total covered assets in the denominator)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
2024-12-31
Water and marine resources (WTR)
Proportion of
total assets
covered
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
292
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
3.2.2 GAR KPI stock - capital expenditures-based – for 2023
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
42.09% 0.09% 0.00% 0.00% 0.00% 0.15% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 42.24% 0.09% 0.00% 0.00% 0.01% 72.72%
2 Financial undertakings 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.04%
3 Credit institutions 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.04%
4 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.04%
5 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
6 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
7 Other financial corporations 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
8 of which investment firms 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
9 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
10 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
11 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
12 of which management companies 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
13 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
14 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
15 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
16 of which insurance undertakings 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
17 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
18 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
19 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
20 Non-financial undertakings 0.88% 0.09% 0.00% 0.00% 0.00% 0.15% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 1.03% 0.09% 0.00% 0.00% 0.01% 1.76%
21 Loans and advances 0.88% 0.09% 0.00% 0.00% 0.00% 0.15% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 1.03% 0.09% 0.00% 0.00% 0.01% 1.76%
22 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
23 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
24 Households 41.21% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 41.21% 0.00% 0.00% 0.00% 0.00% 45.68%
25 of which loans collateralised by residential immovable property 40.32% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 40.32% 0.00% 0.00% 0.00% 0.00% 31.02%
26 of which building renovation loans 0.89% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.89% 0.00% 0.00% 0.00% 0.00% 0.58%
27 of which motor vehicle loans 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
28 Local governments financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01%
29 Housing financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
30 Other local government financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01%
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
32 Total GAR assets 42.09% 0.09% 0.00% 0.00% 0.00% 0.15% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 42.24% 0.09% 0.00% 0.00% 0.01% 100.00%
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
2023-12-31
Water and marine resources (WTR)
Proportion of
total assets
covered
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
% (compared to total covered assets in the denominator)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Climate Change Adaptation (CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
293
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
4.1 GAR KPI flow - turnover-based
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
21.88% 1.19% 1.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 21.90% 1.19% 1.19% 0.00% 0.00% 60.43%
2 FINANCIAL UNDERTAKINGS 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.05%
3 Credit institutions 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.05%
4 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.05%
5 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
6 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
7 Other financial corporations 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
8 of which investment firms 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
9 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
10 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
11 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
12 of which management companies 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
13 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
14 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
15 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
16 of which insurance undertakings 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
17 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
18 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
19 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
20 NON-FINANCIAL UNDERTAKINGS 0.15% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.17% 0.00% 0.00% 0.00% 0.00% 3.58%
21 Loans and advances 0.15% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.17% 0.00% 0.00% 0.00% 0.00% 3.58%
22 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
23 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
24 HOUSEHOLDS 21.73% 1.19% 1.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 21.73% 1.19% 1.19% 0.00% 0.00% 56.78%
25 of which loans collateralised by residential immovable property 21.29% 1.19% 1.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 21.29% 1.19% 1.19% 0.00% 0.00% 13.98%
26 of which building renovation loans 0.44% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.44% 0.00% 0.00% 0.00% 0.00% 0.44%
27 of which motor vehicle loans 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
28 LOCAL GOVERNMENTS FINANCING 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
29 Housing financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
30 Other local government financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
32 Total GAR assets 21.88% 1.19% 1.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 21.90% 1.19% 1.19% 0.00% 0.00% 100.00%
Climate Change Adaptation (CCA)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
% (compared to flow of total eligible assets)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
2024-12-31
Water and marine resources (WTR)
Proportion of
total new
assets covered
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
294
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
4.2 GAR KPI flow - capital expenditures-based
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instruments not HfT
eligible for GAR calculation
22.41% 1.26% 1.19% 0.03% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 22.41% 1.26% 1.19% 0.03% 0.02% 60.43%
2 FINANCIAL UNDERTAKINGS 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.05%
3 Credit institutions 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.05%
4 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.05%
5 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
6 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
7 Other financial corporations 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
8 of which investment firms 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
9 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
10 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
11 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
12 of which management companies 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
13 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
14 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
15 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
16 of which insurance undertakings 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
17 Loans and advances 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
18 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
19 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
20 NON-FINANCIAL UNDERTAKINGS 0.68% 0.07% 0.00% 0.03% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.68% 0.07% 0.00% 0.03% 0.02% 3.58%
21 Loans and advances 0.68% 0.07% 0.00% 0.03% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.68% 0.07% 0.00% 0.03% 0.02% 3.58%
22 Debt securities, including UoP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
23 Equity instruments 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
24 HOUSEHOLDS 21.73% 1.19% 1.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 21.73% 1.19% 1.19% 0.00% 0.00% 56.78%
25 of which loans collateralised by residential immovable property 21.29% 1.19% 1.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 21.29% 1.19% 1.19% 0.00% 0.00% 13.98%
26 of which building renovation loans 0.44% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.44% 0.00% 0.00% 0.00% 0.00% 0.44%
27 of which motor vehicle loans 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
28 LOCAL GOVERNMENTS FINANCING 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
29 Housing financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
30 Other local government financing 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.02%
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
32 Total GAR assets 22.41% 1.26% 1.19% 0.03% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 22.41% 1.26% 1.19% 0.03% 0.02% 100.00%
Climate Change Adaptation (CCA)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
% (compared to flow of total eligible assets)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
2024-12-31
Water and marine resources (WTR)
Proportion of
total new
assets covered
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
295
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
5.1 KPI off-balance sheet exposures - turnover-based
5.2 KPI off-balance sheet exposures - capital expenditures-based
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1 Financial guarantees (FinGuar KPI) 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
2 Assets under management (AuM KPI) 7.96% 1.67% 0.00% 0.00% 1.28% 0.82% 0.26% 0.00% 0.09% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 8.78% 1.93% 0.00% 0.00% 1.37%
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
% (compared to total eligible off-balance sheet assets)
2024-12-31
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Climate Change Adaptation (CCA)
Circular economy (CE)
Pollution (PPC)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1 Financial guarantees (FinGuar KPI) 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
2 Assets under management (AuM KPI) 9.09% 1.85% 0.00% 0.00% 1.50% 0.57% 0.14% 0.00% 0.05% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 9.67% 1.99% 0.00% 0.00% 1.55%
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
% (compared to flow of eligible off-balance sheet assets)
2024-12-31
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1 Financial guarantees (FinGuar KPI) 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
2 Assets under management (AuM KPI) 13.45% 7.04% 0.00% 0.72% 5.31% 2.53% 0.42% 0.00% 0.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 15.97% 7.46% 0.00% 0.72% 5.32%
% (compared to total eligible off-balance sheet assets)
Climate Change Mitigation (CCM)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Biodiversity and Ecosystems (BIO)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
2024-12-31
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Pollution (PPC)
a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1 Financial guarantees (FinGuar KPI) 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
2 Assets under management (AuM KPI) 15.57% 8.78% 0.00% 0.93% 6.78% 2.47% 0.22% 0.00% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 18.04% 9.00% 0.00% 0.93% 6.79%
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
% (compared to flow of eligible off-balance sheet assets)
2024-12-31
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
296
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
6. Quantitative disclosures prepared in accordance with the formulas laid down in Annex XII
of Regulation 2021/2178 - Nuclear and fossil gas related disclosures
1.
The Bank funds or has exposures to research, development, demonstration and
deployment of innovative electricity generation facilities that produce energy from
nuclear processes with minimal waste from the fuel cycle.
NO
2.
The Bank funds or has exposures to construction and safe operation of new nuclear
installations to produce electricity or process heat, including for the purposes of
district heating or industrial processes such as hydrogen production, as well as their
safety upgrades, using best available technologies.
NO
3.
The Bank funds or has exposures to safe operation of existing nuclear installations
that produce electricity or process heat, including for the purposes of district
heating or industrial processes such as hydrogen production from nuclear energy, as
well as their safety upgrades.
NO
4.
The Bank funds or has exposures to construction or operation of electricity
generation facilities that produce electricity using fossil gaseous fuels.
NO
5.
The Bank funds or has exposures to construction, refurbishment, and operation of
combined heat/cool and power generation facilities using fossil gaseous fuels.
YES
6.
The Bank funds or has exposures to construction, refurbishment and operation of
heat generation facilities that produce heat/cool using fossil gaseous fuels.
NO
Nuclear energy related activities
Fossil gas related activities
297
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy-aligned economic activity (denominator) - turnover-based
PLN '000 % PLN '000 % PLN '000 %
1.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.26 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
2.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
3.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
4.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
5.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
6.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.31 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator
of the applicable KPI
1 312 030 0.00% 1 262 442 0.00% 49 588 0.00%
8. Total applicable KPI 1 312 030 0.00% 1 262 442 0.00% 49 588 0.00%
Row
Economic activities
Amount and proportion
Climate change adaptation
(CCA)
CCM+CCA
Climate change mitigation
(CCM)
298
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy-aligned economic activity (numerator) - turnover-based
PLN '000 % PLN '000 % PLN '000 %
1.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.26 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
2.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
3.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
4.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
5.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
6.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.31 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the numerator
of the applicable KPI
1 312 030 100.00% 1 262 442 100.00% 49 588 100.00%
8.
Total amount and proportion of taxonomy-aligned economic
activities in the numerator of the applicable KPI
1 312 030 100.00% 1 262 442 100.00% 49 588 100.00%
Economic activities
Amount and proportion
CCM+CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
299
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy-eligible but not Taxonomy-aligned economic activity - in terms of turnover
PLN '000 % PLN '000 % PLN '000 %
1.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.26 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0.00% 0 0.00% 0 0.00%
2.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.27 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
3.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.28 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
4.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.29 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
5.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.30 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
1 645 0.00% 1 645 0.00% 0 0.00%
6.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.31 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
7.
Amount and proportion of other taxonomy-eligible but not
taxonomy-aligned economic activities not referred to in rows 1 to
6 above in the denominator of the applicable KPI
32 496 325 0.04% 32 495 642 0.04% 683 0.00%
8.
Total amount and proportion of taxonomy eligible but not
taxonomy-aligned economic activities in the denominator of the
applicable KPI
32 497 970 0.04% 32 497 288 0.04% 683 0.00%
Amount and proportion
CCM+CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Economic activities
300
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy non-eligible economic activities - turnover-based
Economic activity PLN '000 %
1.
Amount and proportion of economic activity referred to in row 1 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
2.
Amount and proportion of economic activity referred to in row 2 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
3.
Amount and proportion of economic activity referred to in row 3 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
4.
Amount and proportion of economic activity referred to in row 4 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
5.
Amount and proportion of economic activity referred to in row 5 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
6.
Amount and proportion of economic activity referred to in row 6 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
7.
Amount and proportion of other taxonomy-non-eligible economic
activities not referred to in rows 1 to 6 above in the denominator
of the applicable KPI
52 185 425 100.00%
8.
Total amount and proportion of taxonomy-non-eligible economic
activities in the denominator of the applicable KPI
52 185 425 100.00%
301
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy-aligned economic activity (denominator) - capital expenditures-based
PLN '000 % PLN '000 % PLN '000 %
1.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.26 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
2.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
3.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
4.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
5.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
6.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.31 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator
of the applicable KPI
1 350 804 0.00% 1 345 094 0.00% 5 710 0.00%
8. Total applicable KPI 1 350 804 0.00% 1 345 094 0.00% 5 710 0.00%
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Economic activities
Amount and proportion
CCM+CCA
302
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy-aligned economic activity (numerator) - capital expenditures-based
PLN '000 % PLN '000 % PLN '000 %
1.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.26 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
2.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
3.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
4.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
5.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
6.
Amount and proportion of taxonomy-aligned economic activity
referred to in Section 4.31 of Annexes I and II to Delegated
Regulation 2021/2139 in the numerator of the applicable KPI
0 0.00% 0 0.00% 0 0.00%
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the numerator
of the applicable KPI
1 350 804 100.00% 1 345 094 100.00% 5 710 100.00%
8.
Total amount and proportion of taxonomy-aligned economic
activities in the numerator of the applicable KPI
1 350 804 100.00% 1 345 094 100.00% 5 710 100.00%
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Economic activities
Amount and proportion
CCM+CCA
303
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy-eligible but not Taxonomy-aligned economic activity - in terms of capital expenditures
PLN '000 % PLN '000 % PLN '000 %
1.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.26 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
2.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.27 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
3.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.28 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
4.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.29 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
5.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.30 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
195 0.00% 195 0.00% 0 0.00%
6.
Amount and proportion of taxonomy-eligible but not taxonomy-
aligned economic activity referred to in Section 4.31 of Annexes I
and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0 0.00% 0 0.00% 0 0.00%
7.
Amount and proportion of other taxonomy-eligible but not
taxonomy-aligned economic activities not referred to in rows 1 to
6 above in the denominator of the applicable KPI
33 009 037 0.04% 32 968 332 0.04% 40 706 0.00%
8.
Total amount and proportion of taxonomy eligible but not
taxonomy-aligned economic activities in the denominator of the
applicable KPI
33 009 232 0.04% 32 968 526 0.04% 40 706 0.00%
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Economic activities
Amount and proportion
CCM+CCA
304
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Taxonomy non-eligible economic activities -capital expenditures-based
Economic activity PLN '000 %
1.
Amount and proportion of economic activity referred to in row 1 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
2.
Amount and proportion of economic activity referred to in row 2 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
3.
Amount and proportion of economic activity referred to in row 3 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
4.
Amount and proportion of economic activity referred to in row 4 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
5.
Amount and proportion of economic activity referred to in row 5 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
6.
Amount and proportion of economic activity referred to in row 6 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0 0.00%
7.
Amount and proportion of other taxonomy-non-eligible economic
activities not referred to in rows 1 to 6 above in the denominator
of the applicable KPI
51 631 535 100.00%
8.
Total amount and proportion of taxonomy-non-eligible economic
activities in the denominator of the applicable KPI
51 631 535 100.00%
306
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
22. APPENDICES
List of disclosure requirements fulfilled in the preparation of the sustainability statement following
a materiality assessment.
ESRS
Disclosure
requireme
nt
Chapter in the sustainability statement
ESRS 2
BP-1
15.1.
15.4.1.
Basis of preparation
Description of the process for identifying and assessing material
impacts, risks and opportunities
BP-2
15.1.
Basis of preparation
GOV-1
15.3.1.
Governance structure
GOV-2
15.3.1.
Governance structure
GOV-3
15.3.2.
Integration of sustainability-related performance in incentive
schemes
GOV-4
15.2.
Corporate governance
GOV-5
15.3.3.
Sustainability reporting
SBM-1
15.2.1.
15.2.2.
Business model and value chain
Sustainability strategy
SBM-2
15.4.2.
Key stakeholders
SBM-3
15.4.3.
Identified impacts, risks and opportunities
IRO-1
15.4.1.
15.4.3.
Description of the process for identifying and assessing material
impacts, risks and opportunities
Identified impacts, risks and opportunities
IRO-2
15.4.4.
22.
List of requirements
Appendices
E1
SBM-3
16.1.
Strategy
IRO-1
15.4.3.
Identified impacts, risks and opportunities
GOV-3
15.3.2.
Integration of sustainability-related performance in incentive
schemes
E1-1
16.1.
Strategy
E1-2
16.2.
Management of impacts, risks and opportunities
E1-3
16.2.
Management of impacts, risks and opportunities
E1-4
16.3.1.
Climate-related targets
E1-5
16.3.2.
Energy consumption and mix
E1-6
16.3.3.
Gross Scopes 1, 2, 3 and total GHG emissions
E1-7
16.3.4.
GHG removals and GHG mitigation projects financed through
carbon credits
E1-8
16.3.5.
Internal carbon pricing
E1-9
15.4.3.
Identified impacts, risks and opportunities
E2
IRO-1
15.4.1.
Description of the process for identifying and assessing material
impacts, risks and opportunities
E3
IRO-1
15.4.1.
Description of the process for identifying and assessing material
impacts, risks and opportunities
E4
IRO-1
15.4.1.
Description of the process for identifying and assessing material
impacts, risks and opportunities
E5
IRO-1
15.4.1.
Description of the process for identifying and assessing material
impacts, risks and opportunities
S1
SBM-2
17.1.1.
Interests and views of stakeholders
SBM-3
17.1.2.
Material impacts, risks and opportunities and their interaction
with strategy and business model
S1-1
17.1.3.
17.3.1.
17.4.1.
Policies related to own workforce
Policies related to employment security
Policies related to employee compensation
307
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
ESRS
Disclosure
requireme
nt
Chapter in the sustainability statement
17.5.1.
17.6.1.
17.7.1.
17.8.1.
17.9.1.
17.10.1.
Policies related to working time
Policies related to employee health and safety
Policies related to compensation and diversity
Policies related to training and development
Policies related to countering violations
Policies related to privacy
S1-2
17.1.4.
Procedures for cooperation with own workforce and employee
representatives regarding impacts
S1-3
17.9.4.
Processes for remediation of negative impacts and channels for
reporting violations
S1-4
17.3.2.
17.4.2.
17.5.2.
17.6.2.
17.7.2.
17.8.2.
17.9.2.
17.10.2.
Actions taken to implement policy objectives
Actions taken to implement policy objectives
Actions taken to implement policy objectives
Actions taken to implement policy objectives
Actions taken to implement policy objectives
Actions taken to implement policies
Actions taken to implement policies
Actions taken to implement policies
S1-5
17.3.3.
17.4.3.
17.5.3.
17.6.3.
17.7.3.
17.8.3.
17.9.3.
17.10.3.
Objectives related to the implementation of policies and
activities
Objectives related to the implementation of policies and
activities
Objectives related to the implementation of policies and
activities
Objectives related to the implementation of policies and
activities
Objectives related to the implementation of policies and
activities
Objectives related to the implementation of policies and
activities
Objectives related to the implementation of policies and
activities
Objectives related to the implementation of policies and
activities
S1-6
17.2.1.
Characteristics of the entity’s workforce
S1-7
17.2.2.
Characteristics of non-employees constituting own employee
resources
S1-9
17.7.4.
Diversity metrics
S1-10
17.4.4.
Adequate wages
S1-11
17.3.2.
Actions taken to implement policies
S1-13
17.8.4.
Training and skills development metrics
S1-14
17.6.4.
Occupational health and safety metrics
S1-15
17.3.4.
Work-life balance metrics
S1-16
17.4.5.
Compensation metrics
S1-17
17.9.4.
Processes for remediation of negative impacts and channels for
reporting violations
S2
SBM-2
15.4.2.
Key stakeholders
SBM-3
18.1.
Strategy
S2-1
18.2.
Management of impacts, risk and opportunities
S2-2
18.2.
Management of impacts, risk and opportunities
S2-3
18.2.
Management of impacts, risk and opportunities
S2-4
18.1.
Strategy
308
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
ESRS
Disclosure
requireme
nt
Chapter in the sustainability statement
18.2.
Management of impacts, risk and opportunities
S2-5
18.3.
Benchmarks and objectives
S4
SBM-2
19.1.1.
Interests and views of stakeholders
SBM-3
19.1.2.
Material impacts, risks and opportunities and their interaction
with strategy and business model
S4-1
19.3.
19.4.1.
19.5.1.
19.6.1.
19.7.1.
19.8.1.
Respect for human rights in customer relations
Policies related to the safety of deposited funds
Policies related to privacy
Policies related to access to (high quality) information
Policies related to responsible marketing practices
Policies related to non-discrimination
S4-2
19.2.
19.4.2.
19.5.2.
19.6.2.
General customer engagement processes
General customer engagement processes in terms of the safety
of deposited funds
Customer engagement processes in terms of privacy
Customers engagement processes in terms of access
to information
S4-3
19.9.
Remediation of negative impacts
S4-4
19.4.3.
19.5.3.
19.6.3.
19.7.2.
19.8.2.
Activities related to the security of entrusted funds
Measures related to privacy
Measures related to access to information
Measures related to responsible marketing practices
Measures related to non-discrimination
S4-5
19.4.4.
19.5.4.
19.6.4.
19.7.3.
19.8.3.
Objectives related to the pursuit of policies and activities
Objectives related to the pursuit of policies and activities
Objectives related to the pursuit of policies and activities
Objectives related to the pursuit of policies and activities
Objectives related to the pursuit of policies and activities
G1
IRO-1
20.1.
15.4.1.
Corporate culture and business ethics
Description of the process of identifying and assessing material
impacts, risks and opportunities
GOV-1
15.3.1.
Governance structure
G1-1
20.1.
20.2.
20.3.
Corporate culture and business ethics
Anti-corruption
Whistleblower reporting and protection
G1-3
20.2.
Anti-corruption
G1-4
20.2.
Anti-corruption
310
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Table consistent with Appendix B: List of datapoints in cross-cutting and topical standards that derive from other EU legislation
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS 2 GOV-1 Board’s
gender diversity, sec.
21(d)
Indicator 13 in Table 1 of
Annex I
Annex II to Commission
Delegated Regulation (EU)
2020/1816
15.3.1. Governance
structure
ESRS 2 GOV-1 Percentage
of independent board
members, sec. 21(e)
Annex II to Commission
Delegated Regulation (EU)
2020/1816
15.3.1. Governance
structure
ESRS 2 GOV-4 Statement
on due diligence, sec. 30
Indicator 10 in Table 3 of
Annex I
15.2. Governance
ESRS 2 SBM-1 Involvement
in activities related to
fossil fuel activities, sec.
40 (d)(i)
Indicator 4 in Table 1 of
Annex I
Article 449a of Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453, Table 1:
Qualitative information on
Environmental risk, and
Table 2: Qualitative
information on Social risk
Annex II to Commission
Delegated Regulation (EU)
2020/1816
Immaterial
ESRS 2 SBM-1 Involvement
in activities related to
chemical production, sec.
40(d)(ii)
Indicator 9 in Table 2 of
Annex I
Annex II to Commission
Delegated Regulation (EU)
2020/1816
Immaterial
ESRS 2 SBM-1 Involvement
in activities related to
controversial weapons,
sec. 40(d)(iii)
Indicator 14 in Table 1 of
Annex I
Article 12(1) of Delegated
Regulation (EU)
2020/1818, Annex II to
Delegated Regulation (EU)
2020/1816
Immaterial
ESRS 2 SBM-1 Involvement
in activities related to
cultivation and production
of tobacco, sec. 40(d)(iv)
Article 12(1) of Delegated
Regulation (EU)
2020/1818, Annex II to
Delegated Regulation (EU)
2020/1816
Immaterial
311
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS E1-1 Transition plan
to reach climate neutrality
by 2050, sec. 14
Article 2(1) of
Regulation (EU)
2021/1119
16.1. Strategy
ESRS E1-1 Undertakings
excluded from Paris-
aligned Benchmarks, sec.
16(g)
Article 449a of Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453, Template 1:
Banking book – Climate
change transition risk:
Credit quality of exposures
by sector, emissions and
residual maturity
Articles 12(1)(d) to (g) and
Article 12(2) of Delegated
Regulation (EU) 2020/1818
Data point material,
however not applicable
due to lack of
transformation plan
disclosure in Section 16.1.
Strategy.
ESRS E1-4 GHG emission
reduction targets, sec. 34
Indicator 4 in Table 2 of
Annex I
Article 449a of Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453, Template 3:
Banking book – Climate
change transition risk:
alignment metrics
Article 6 of Delegated
Regulation (EU) 2020/1818
16.3.1. Climate-related
objectives
ESRS E1-5 Energy
consumption from fossil
sources disaggregated by
sources (only high climate
impact sectors), sec. 38
Indicator 5 in Table 1 and
Indicator 5 in Table 2 of
Annex I
16.3.2. Energy
consumption and mix
ESRS E1-5 Energy
consumption and mix, sec.
37
Indicator 5 in Table 1 of
Annex I
16.3.2. Energy
consumption and mix
ESRS E1-5 Energy intensity
associated with activities
in high climate impact
sectors, sec. 40–43
Indicator 6 in Table 1 of
Annex I
16.3.2. Energy
consumption and mix
312
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS E1-6 Gross Scope 1, 2,
3 and Total GHG emissions,
sec. 44
Indicators 1 and 2 in Table
1 of Annex I
Article 449a of Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453, Template 1:
Banking book – Climate
change transition risk:
Credit quality of exposures
by sector, emissions and
residual maturity
Articles 5(1), 6 and 8(1) of
Delegated Regulation (EU)
2020/1818
16.3.3. Gross Scope 1, 2, 3
and Total GHG emissions
ESRS E1-6 Gross GHG
emissions intensity, sec.
53–55
Indicator 3 in Table 1 of
Annex I
Article 449a of Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453, Template 3:
Banking book – Climate
change transition risk:
alignment metrics
Article 8(1) of Delegated
Regulation (EU) 2020/1818
16.3.3. Gross Scope 1, 2, 3
and Total GHG emissions
ESRS E1-7 GHG removals
and carbon credits, sec. 56
Article 2(1) of
Regulation (EU)
2021/1119
16.3.4. GHG removals and
GHG mitigation projects
financed through carbon
credits
ESRS E1-9 Exposure of the
benchmark portfolio to
climate-related physical
risks, sec. 66
Annex II to Delegated
Regulation (EU)
2020/1818, Annex II to
Delegated Regulation (EU)
2020/1816
Material, but the
information is not
disclosed due to
transitional provision
313
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS E1-9 Disaggregation
of monetary amounts by
acute and chronic physical
risk, sec. 66(a)
ESRS E1-9 Location of
significant assets at
material physical risk, sec.
66(c)
Article 449a of Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453, sec. 46 and 47;
Template 5: Banking book
– Climate change physical
risk: Exposures subject to
physical risk.
Material, but the
information is not
disclosed due to
transitional provision
ESRS E1-9 Breakdown of
the carrying value of its
real estate assets by
energy-efficiency classes,
sec. 67(c)
Article 449a of Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453, sec. 34;
Template 2: Banking book
– Climate change transition
risk: Loans collateralised
by immovable property –
Energy efficiency of the
collateral
Material, but the
information is not
disclosed due to
transitional provision
ESRS E1-9 Degree of
exposure of the portfolio
to climate-related
opportunities, sec. 69
Annex II to Delegated
Regulation (EU) 2020/1818
Material, but the
information is not
disclosed due to
transitional provision
ESRS E2-4 Amount of each
pollutant listed in Annex II
of the EPRTR Regulation
(European Pollutant
Release and Transfer
Register) emitted to air,
water and soil, sec. 28
Indicator 8 in Table 1 of
Annex I, Indicator 2 in
Table 2 of Annex I,
Indicator 1 in Table 2 of
Annex I, Indicator 3 in
Table 2 of Annex I
Immaterial
ESRS E3-1 Water and
marine resources, sec. 9
Indicator 7 in Table 2 of
Annex I
Immaterial
314
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS E3-1 Dedicated
policy, sec. 13
Indicator 8 in Table 2 of
Annex I
Immaterial
ESRS E3-1 Sustainable
oceans and seas, sec. 14
Indicator 12 in Table 2 of
Annex I
Immaterial
ESRS E3-4 Total water
recycled and reused, sec.
28(c)
Indicator 6.2 in Table 2 of
Annex I
Immaterial
ESRS E3-4 Total water
consumption in m
3
per net
revenue on own
operations, sec. 29
Indicator 6.1 in Table 2 of
Annex I
Immaterial
ESRS 2 SBM 3-E4, sec.
16(a)(i)
Indicator 7 in Table 1 of
Annex I
Immaterial
ESRS 2 SBM 3-E4, sec. 16(b)
Indicator 10 in Table 2 of
Annex I
Immaterial
ESRS 2 SBM 3-E4, sec. 16(c)
Indicator 14 in Table 2 of
Annex I
Immaterial
ESRS E4-2 Sustainable
land/agriculture practices
or policies, sec. 24(b)
Indicator 11 in Table 2 of
Annex I
Immaterial
ESRS E4-2 Sustainable
oceans/seas practices or
policies, sec. 24(c)
Indicator 12 in Table 2 of
Annex I
Immaterial
ESRS E4-2 Policies to
address deforestation, sec.
24(d)
Indicator 15 in Table 2 of
Annex I
Immaterial
ESRS E5-5 Non recycled
waste, sec. 37(d)
Indicator 13 in Table 2 of
Annex I
Immaterial
ESRS E5-5 Hazardous waste
and radioactive waste,
sec. 39
Indicator 9 in Table 1 of
Annex I
Immaterial
ESRS 2 SBM-3-S1 Risk of
incidents of forced labour,
sec. 14(f)
Indicator 13 in Table 3 of
Annex I
Immaterial
315
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS 2 SBM-3-S1 Risk of
incidents of child labour,
sec. 14(g)
Indicator 12 in Table 3 of
Annex I
Immaterial
ESRS S1-1 Human rights
policy commitments, sec.
20
Indicator 9 in Table 3 and
Indicator 11 in Table 1 of
Annex I
17.1.3. Policies related to
own workforce
ESRS S1-1 Due diligence
policies on issues
addressed by the
fundamental International
Labour Organisation
Conventions 1 to 8, sec. 21
Annex II to Commission
Delegated Regulation (EU)
2020/1816
17.1.3. Policies related to
own workforce
ESRS S1-1 Processes and
measures for preventing
trafficking in human
beings, sec. 22
Indicator 11 in Table 3 of
Annex I
17.1.3. Policies related to
own workforce
ESRS S1-1 Workplace
accident prevention policy
or management system,
sec. 23
Indicator 1 in Table 3 of
Annex I
17.1.3. Policies related to
own workforce
ESRS S1-3
Grievance/complaints
handling mechanisms, sec.
32(c)
Indicator 5 in Table 3 of
Annex I
17.9.4. Processes for
remediation of negative
impacts and channels for
reporting violations
ESRS S1-14 Number of
fatalities and number and
rate of work-related
accidents, sec. 88(b) and
(c)
Indicator 2 in Table 3 of
Annex I
Annex II to Commission
Delegated Regulation (EU)
2020/1816
17.6.4. Occupational
health and safety metrics
ESRS S1-14 Number of days
lost to injuries, accidents,
fatalities or illness, sec.
88(e)
Indicator 3 in Table 3 of
Annex I
17.6.4. Occupational
health and safety metrics
316
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS S1-16 Unadjusted
gender pay gap, sec. 97(a)
Indicator 12 in Table 1 of
Annex I
Annex II to Commission
Delegated Regulation (EU)
2020/1816
17.4.5. Compensation
metrics
ESRS S1-16 Excessive CEO
pay ratio, sec. 97(b)
Indicator 8 in Table 3 of
Annex I
17.4.5. Compensation
metrics
ESRS S1-17 Incidents of
discrimination, sec. 103(a)
Indicator 7 in Table 3 of
Annex I
17.9.4. Processes for
remediation of negative
impacts and channels for
reporting violations
ESRS S1-17 Non-respect of
UNGPs on Business and
Human Rights and OECD
Guidelines, sec. 104(a)
Indicator 10 in Table 1 and
Indicator 14 in Table 3 of
Annex I
Annex II to Delegated
Regulation (EU)
2020/1816, Article 12(1) of
Delegated Regulation (EU)
2020/1818
17.9.4. Processes for
remediation of negative
impacts and channels for
reporting violations
ESRS 2 SBM-3-S2 Significant
risk of child labour or
forced labour in the value
chain, sec. 11(b)
Indicators 12 and 13 in
Table 3 of Annex I
Immaterial
ESRS S2-1 Human rights
policy commitments, sec.
17
Indicator 9 in Table 3 and
Indicator 11 in Table 1 of
Annex I
18.2. Management of
impacts, risks and
opportunities
ESRS S2-1 Policies related
to value chain workers,
sec. 18
Indicators 11 and 4 in
Table 3 of Annex I
18.2. Management of
impacts, risks and
opportunities
ESRS S2-1 Non-respect of
UNGPs on Business and
Human Rights and OECD
Guidelines, sec. 19
Indicator 10 in Table 1 of
Annex I
Annex II to Delegated
Regulation (EU)
2020/1816, Article 12(1) of
Delegated Regulation (EU)
2020/1818
18.2. Management of
impacts, risks and
opportunities
317
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS S2-1 Due diligence
policies on issues
addressed by the
fundamental International
Labour Organisation
Conventions 1 to 8, sec. 19
Annex II to Commission
Delegated Regulation (EU)
2020/1816
18.2. Management of
impacts, risks and
opportunities
ESRS S2-4 Human rights
issues and incidents
connected to its upstream
and downstream value
chain, sec. 36
Indicator 14 in Table 3 of
Annex I
18.2. Management of
impacts, risks and
opportunities
ESRS S3-1 Human rights
policy commitments, sec.
16
Indicator 9 in Table 3 of
Annex I and Indicator 11 in
Table 1 of Annex I
Immaterial
ESRS S3-1 Non-respect of
UNGPs on Business and
Human Rights, ILO
principles or OECD
Guidelines, sec. 17
Indicator 10 in Table 1 of
Annex I
Annex II to Delegated
Regulation (EU)
2020/1816, Article 12(1) of
Delegated Regulation (EU)
2020/1818
Immaterial
ESRS S3-4 Human rights
issues and incidents, sec.
36
Indicator 14 in Table 3 of
Annex I
Immaterial
ESRS S4-1 Policies related
to consumers and end-
users, sec. 16
Indicator 9 in Table 3 and
Indicator 11 in Table 1 of
Annex I
19.3. Respect for human
rights in customer relations
ESRS S4-1 Non-respect of
UNGPs on Business and
Human Rights and OECD
Guidelines, sec. 17
Indicator 10 in Table 1 of
Annex I
Annex II to Delegated
Regulation (EU)
2020/1816, Article 12(1) of
Delegated Regulation (EU)
2020/1818
19.3. Respect for human
rights in customer relations
ESRS S4-4 Human rights
issues and incidents, sec.
35
Indicator 14 in Table 3 of
Annex I
19.3. Respect for human
rights in customer relations
318
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
Disclosure requirement
and related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law
reference
Sustainability statement
– section
ESRS G1-1 United Nations
Convention against
Corruption, sec. 10(b)
Indicator 15 in Table 3 of
Annex I
Not applicable – the entity
has the adequate policy –
more detailed information
in section 20.2. Anti-
corruption
ESRS G1-1 Protection of
whistle-blowers, sec. 10(d)
Indicator 6 in Table 3 of
Annex I
Not applicable – the entity
has the adequate policy –
more detailed information
in section 20.3.
Whistleblower reporting
and protection
ESRS G1-4 Fines for
violation of anti-corruption
and anti-bribery laws, sec.
24(a)
Indicator 17 in Table 3 of
Annex I
Annex II to Commission
Delegated Regulation (EU)
2020/1816
20.2. Anti-corruption
ESRS G1-4 Standards of
anti-corruption and anti-
bribery, sec. 24(b)
Indicator 16 in Table 3 of
Annex I
20.2. Anti-corruption
319
Management Board report on the activities of Bank Millennium S.A.
and the Bank Millennium S.A. Group in 2024
III. STATEMENTS OF MANAGEMENT BOARD
Presentation of asset and financial position of the Bank and Capital Group in the financial reports
According to the best knowledge, the Annual Financial Statements of Bank Millennium and Capital
Group of Bank Millennium S.A. as at 31 December 2024 and the comparable data, were prepared in
line with the accounting principles, and reflect, truly, reliably, and clearly, the asset and financial
position of the Bank and Capital Group of Bank Millennium and their financial results. This Annual
Management Board Report on the activity of Bank Millennium and the Group contains a true picture
of development, achievements and condition of Bank Millennium and the Capital Group of Bank
Millennium.
Selection of an entity authorized to audit financial reports
The entity authorized to review financial reports that audits Annual Financial Statements of Bank
Millennium and the Capital Group of Bank Millennium SA as at 31 December 2024, was selected in
accordance with the regulations of law. The entity and chartered accountants, who performed the
audit, satisfied all the conditions required to issue an unbiased and independent audit report, as
required by the national law.
SIGNATURES:
Date
Name and surname
Position/Function
Signature
24.02.2025
Joao Bras Jorge
Chairman of the
Management Board
signed with a qualified electronic signature
24.02.2025
Fernando Bicho
Deputy Chairman of
the Management Board
signed with a qualified electronic signature
24.02.2025
Wojciech Haase
Member of the
Management Board
signed with a qualified electronic signature
24.02.2025
Andrzej Gliński
Member of the
Management Board
signed with a qualified electronic signature
24.02.2025
Wojciech Rybak
Member of the
Management Board
signed with a qualified electronic signature
24.02.2025
António Pinto Júnior
Member of the
Management Board
signed with a qualified electronic signature
24.02.2025
Jarosław Hermann
Member of the
Management Board
signed with a qualified electronic signature