Evaluation of the Bank's standing on a consolidated basis, including the assessment of adequacy and effectiveness of the internal control system, risk management system, compliance and the internal audit function

Poland's economic growth accelerated to 2.9 per cent in 2024 from 0.1 per cent in 2023, mainly as a consequence of a rebound in household consumption, supported by falling inflation amid double-digit growth in nominal wages. This translated into a clearcut improvement in real household disposable income. At the same time, however, the savings rate was elevated in an environment of high interest rates, limiting expenditure growth despite the strong improvement in the rate of income. Household consumption increased by 3.1% in 2024. Investment activity, however, remained low, especially in businesses. In contrast, investment growth was in the public sector, including defence spending in particular. Total investment increased by 1.3% in 2024. Economic activity in the main Polish export markets was weak (recession in Germany for the second year in a row), which limited export dynamics. Domestic demand grew faster than foreign demand, resulting in a deterioration of the foreign trade balance. As a result, the negative contribution of net exports to GDP amounted to 1 p.p. In contrast, there was little support from the recovery of inventories (positive contribution of 0.5 p.p.).

The subsiding of the energy shock encouraged disinflation in the first half of last year. In March 2024, consumer price growth slowed to 2% y/y before starting to pick up again, largely due to administrative decisions. VAT on food was reintroduced in April and, from July, some of the protective measures (the so-called energy shield) were withdrawn. By the end of 2024, inflation had risen to 4.7% y/y. Core inflation excluding food and energy prices remained elevated, buoyed by robust growth in services prices amid still high wage growth. In December 2024, core inflation stood at 4% y/y. The National Bank of Poland kept interest rates at 5.75% in 2024.

In 2024, the performance of the banking sector was very good, with the sector's net profit increasing y/y by approximately 51% to PLN 42 billion. The banking sector's return on equity (ROE) also increased by nearly 4 p.p. y/y to approximately 16%. This was mainly due to high interest rates, which translated into higher interest earnings of banks (despite the negative impact of loan holidays), mitigating the still high risk costs of the FX mortgage portfolio and operating costs. Banks continued to offer attractive deposit interest rates, prompting customers to place funds on term deposits. On the other hand, high interest rates contributed to low demand for loans, particularly corporate ones - their sales were 1% lower y/y. Sales of mortgage loans recorded a 43% increase y/y. Consumer loan activity also improved, with sales increasing by 13% y/y.

In 2024, banks continued to work on enabling their customers - holders of FX mortgages - to enter into bank settlements, whether in line with the PFSC Chairman's proposal or based

In light of the above-mentioned factors impacting the condition of the Polish economy and the banking sector, in 2024 ING Bank Śląski Group achieved a net profit of PLN 4 369 million, a 2% decrease compared with 2023. ING Bank Śląski Group's net profit was mainly driven by high interest income (+PLN 554m y/y, +7% y/y) and commission income (+PLN 130m y/y, +6% y/y) and a decrease in other income (-PLN 83m y/y, -24% y/y), with an increase in the bank's total costs (including bank tax) by PLN 354m y/y (+8%). Consequently, the bank's overheads including bank levy to income ratio increased by 1 p.p. to 41.7%. The bank's risk costs including legal risk costs of FX mortgage loans increased by PLN 422 million y/y (+69%), which was related to sustaining credit losses on several customers of the corporate segment. Legal risk costs alone decreased by PLN 14 million y/y. In line with the increase in the cost of risk, the cumulative cost of risk margin changed to 0.64% at the end of 2024 compared to 0.39% at the end of 2023, and the provision coverage ratio of Stage 3 and POCI loans and other receivables decreased y/y by 12 p.p. to 48.7%.

The Supervisory Board exercises oversight over the bank’s operations by keeping watch over the bank’s adherence to the relevant regulations in the area of accounting, finance and reporting of public companies. The powers of the Supervisory Board also include supervision of the individual risk management processes at ING Bank Śląski S.A. with the support of the Risk Committee and Audit Committee. Based on the recommendations of these Committees, the Supervisory Board accepts and approves, among other things, the risk management strategy for the Bank's activities, the main principles of the risk management policy, as well as the level of risk appetite. Further, the Supervisory Board monitors the utilisation of internal limits vis-à- vis the current strategy of the bank.

The Risk Committee supports the Supervisory Board in monitoring the risk management process, including (non-financial) operational risk, liquidity risk, credit risk and market risk. The Committee also supervises the risk management process as well as the assessment of internal capital, capital adequacy, and of the risk of capital-related models and other models. The Committee voices its opinion about the overall readiness of the bank to take the risk in the current and long term perspective. In addition, the Committee periodically approves the interim qualitative and quantitative information on capital adequacy disclosed by the bank to the Bank Group on a quarterly basis. The Chair of the Risk Committee - who is also an independent member of the Supervisory Board - holds regular meetings with people in charge of the various risk areas, as well as with the Director of the Internal Audit Department and the Centre of

Monitoring of the financial reporting process is among the tasks of the Audit Committee. In this context, the Audit Committee periodically analyses the bank financial statements and the results of their audit. Further, the Chair of the Audit Committee – who is an independent member of the Board at the same time – holds periodic meetings with the Vice-President of the Management Board in charge of the CFO Division duriing which the Chair is updated on the interim financial results of the bank prior to their publication. The Chair of the Audit Committee also holds periodic meetings with the Director of the Internal Audit Department on the specifics of the internal audit function and the Centre of Expertise Lead III - Compliance on issues concerning compliance risk management. The Audit Committee actively participates in the process of selecting an entity authorised to audit financial statements of the company and analyses the results of the auditor's work, ensuring its independence and effectiveness. In addition, the Audit Committee monitors the adequacy and effectiveness of the internal control and internal audit system and assesses the effectiveness of the measures used to mitigate risks, including compliance risks, and the quality of the management of these risks.

The Supervisory Board also has a Remuneration and Nomination Committee, which monitors, among other things, the situation on the labour market in terms of remuneration, employee turnover processes, Management Board succession plans, as well as the results of employee satisfaction surveys. The Committee regularly monitors the remuneration system in place at the Bank, including the salary and bonus policy. The Chair of the Remuneration and Nomination Committee - who is also an independent member of the Supervisory Board - holds periodic meetings with key HR people. In 2024, following the resignation of Ms Katarzyna Zajdel-Kurowska as a member of the Supervisory Board as of 29 February 2024, which affected the composition of the Risk Committee and the Audit Committee, the Committee carried out a process of individual assessment of the Chair of the Supervisory Board, i.e. Mr Aleksander Galos, in terms of serving on both Committees and a collective assessment of both Committees. As a result of the assessment, the Committee confirmed the individual competence of the current members of the Audit Committee and the Risk Committee, as well as the candidate for a member of the Audit Committee and the Risk Committee. In addition, it was confirmed that the individual committees fulfilled the adequacy criteria, including the criterion of independence of a sufficient number of members of each committee and the chair of the respective committee. For the Audit Committee, it was also confirmed that this

Due to the fact that the term of office of the Supervisory Board expired on 11 April 2024, i.e. on the date of the General Meeting approving the financial statements for 2023, and in connection with the resignation of Mr Aleksander Galos, Chair of the Supervisory Board, from applying to be elected to the Supervisory Board for the next term, the Committee conducted the process of evaluating the existing members of the Supervisory Board running for the next term of office, i.e. Ms Małgorzata Kołakowska, Mr Stephen Creese, Ms Dorota Dobija, Ms Monika Marcinkowska, Mr Hans De Munck and Mr Michał Szczurek. In addition, the Committee conducted a process of individual assessment of the candidates for the Supervisory Board, i.e. Ms Aneta Hryckiewicz-Gontarczyk, Mr Arkadiusz Krasowski and Mr Serge Offers. The relevant recommendations were forwarded to the General Meeting, which on 11 April 2024 adopted resolutions to change the number of members of the Supervisory Board from eight to nine members and, following the expiry of the Supervisory Board's term of office, to appoint the Supervisory Board for a new term of office consisting of: Mr Stephen Creese, Ms Dorota Dobija, Ms Aneta Hryckiewicz-Gontarczyk, Ms Małgorzata Kołakowska, Mr Arkadiusz Krasowski, Ms Monika Marcinkowska, Mr Hans De Munck, Mr Serge Offers and Mr Michał Szczurek.

At the first meeting of the new term, the Supervisory Board appointed Ms Monika Marcinkowska as Chair of the Supervisory Board, Ms Małgorzata Kołakowska as First Deputy Chair of the Supervisory Board and Mr Michał Szczurek as Deputy Chair of the Supervisory Board. At the same meeting, the Supervisory Board appointed the members of the Board Committees for the new term of office, namely: Audit Committee, Risk Committee and Remuneration and Nomination Committee. In view of the above and the recommendation of the Supervisory Board to carry out an additional adequacy assessment for the newly appointed Chair of the Supervisory Board and the newly appointed Chairs of the Board Committees, as well as collective assessments of the Board Committees in their new compositions, the Committee - with the participation of an external company - carried out the relevant assessments, making appropriate recommendations to the Supervisory Board.

In 2024, the Supervisory Board's attention was also drawn to, among other things, the recruitment process for the position of President of the Bank Management Board. As the mandate of Mr Bruno Bartkiewicz expires in 2025, at the end of his current term as President of the Bank Management Board, i.e. on the date of the General Meeting approving the financial statements for 2024, at its meeting on 11 April 2024 the Supervisory Board also decided to initiate the recruitment process for the position of President of the Bank Management Board.

In addition, on 29 November 2024, the Supervisory Board noted the resignation of Mr Sławomir Soszyński, Vice President of the Bank Management Board in charge of the CIO Division, from seeking election to the Bank Management Board for the next term of office, which will commence on the date of the General Meeting of ING Bank Śląski S.A. approving the financial statements for 2024.

The Supervisory Board assesses that the risk management system in ING Bank Śląski S.A Group is adequate and effective. It covers all material risks and the processes for their identification, measurement, management and reporting use risk-specific instruments and techniques. The main objectives of the risk management system have been achieved in 2024 and the independence of the organisational units for risk management is ensured, as well as adequate human resources necessary for the effective performance of tasks by these units. In 2024, ING Bank Śląski S.A. satisfied all the requirements of sound business operations and capital adequacy, and in particular the Bank:

• pursued prudent lending policy. The lending processes and procedures were compliant with the regulatory requirements and best practices on the market. In 2024, the bank took account of the economic situation in its lending policy and applied more restrictive procedures towards sectors characterised by increased risk. The bank’s lending portfolio was diversified with a significant share of high-quality loans granted to business entities. Within the Bank Group, credit receivables in Stage 3 represented 3.9% of the total gross exposure (measured at amortised cost), which is significantly less than the average for the entire banking sector (4.7% as at the end of 2024);

• had procedures and systems in the market risk management area (for interest rate or currency risk, among others) that meet the top market standards. Throughout 2024, individual market risk categories were managed actively so that their levels were within the limits effective at the bank. The balance sheet structure of the Bank was balanced

from the currency perspective; its distinctive feature is the low share of FX receivables in the total mortgage receivables, among other things;

• maintained an adequate level of liquidity. In 2024, the regulatory limits were not exceeded and the bank's secure liquidity position is due to one of the largest stable household deposit bases among Polish banks; an important element of the bank's liquidity management is the maintenance of an adequate liquidity buffer;

• effectively managed operational risks, including model risks, meeting market standards in this respect;

• had an adequate level of own funds meeting supervisory requirements. In December 2024, the total capital ratio of the ING Bank Śląski S.A. Group was 14.85%, while the Tier 1 ratio stood at 13.76%;

• had clearly defined duties and responsibilities within its organisational structure for the development and implementation of ESG risk management mechanisms and was developing and introducing new ESG risk management methods and tools. The Bank had mechanisms in place to mitigate ESG risks as part of the KYC process and was developing an ESG risk sensitive approach to RAS limits. The Bank also has mechanisms in place to manage ESG risk as part of its standard retail and corporate lending processes, and as part of its operational risk management, reputation risk included. The Bank has developed an approach to collect the data necessary to manage ESG risks and is steadily implementing it.

The internal control system in place at the Bank adequately and effectively ensures the achievement of the main objectives of the internal control system, which were achieved at a high or very high level in 2024. This system covers all business units of the Bank and all three lines of defence. The Bank has a formal reporting path for the scale and nature of the identified irregularities and the status of corrective actions and disciplinary measures taken. Corrective actions and disciplinary measures are implemented in a timely and effective manner. The independence of the Internal Audit Department and the Centre of Expertise - Compliance is ensured, as well as the adequate human resources necessary for these units to perform their tasks effectively.

Keeping in mind moderate economic growth and geopolitical and regulatory uncertainty, the Supervisory Board believes that the Bank's attention should continue to be focused on maintaining adequate capital levels and on measures to ensure accessibility and competitiveness in terms of products and customer service quality, such as:

• adequate capital management in order to ensure safe lending growth as well as fulfilment of all present and future regulatory requirements;

• further development of the product offer, including sustainable products and electronic service channels;

• increase lending, while maintaining a prudent assessment of customer risk, which will contribute to maintaining a high quality portfolio and increasing interest income;

• maintaining an adequate level of stable deposits to provide the necessary liquidity for credit expansion;

• improvement of cost effectiveness while maintaining high quality of processes through optimal use of resources and benefits resulting from the increased scale of operations.

According to the Supervisory Board, the strategy pursued by the Bank over the last few years to increase the scale of its operations proved to be successful which is reflected in the achieved financial and commercial results. Consequently, while maintaining an adequate level of equity, the bank intends to continue it next year.