Translation note:

This version of our report is a translation from the original, which was prepared in Polish. All possible care has been taken to ensure that the translation is an accurate representation of the original. However, in all matters of interpretation of information, views or opinions, the original language version of our report takes precedence over this translation.

PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k., ul. Polna 11, 00-633 Warsaw, Poland, T: +48 (22) 746 4000, F: +48 (22) 746 4040

PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k. with registered office at ul. Polna 11, 00-633 Warsaw, entered into National Court Register by the District Court for the Capital City of Warsaw, XII Commercial Division of the National Court Register under KRS No 0000750050, Tax ID No (NIP) 5260210228.

www.pwc.pl

Independent Statutory Auditor’s Report

To the General Shareholders’ Meeting and the Supervisory Board of Santander Bank Polska S.A.

Report on the audit of separate financ ial statements

Our opinion

In our opinion, the annual separate financial statements:

• give a true and fair view of the separate financial position of Santander Bank Polska S.A. (the “Bank”) as at 31 December 2025 and the Bank’s separate

financial performance and separate cash flows for the year then ended in accordance with the applicable International Fin ancial Reporting Standards as adopted by the European Union and the adopted accounting policies;

• comply in terms of form and content with the laws applicable to the Bank and the Bank’s Articles of Association;

• have been prepared on the basis of properly maintained books o f accounts in accordance with the provisions of Chapter 2 of the Accounting Act of 29 September 1994 (the “Accounting A ct”).

Our opinion is consistent with our additional report to the Audit and Compliance Committee of the Bank (“Audit Committee of the Bank”) issued on the date of this report.

What we have audited

We have audited the annual separate financial statements of Santander Bank Polska S.A. which comprise:

• the separate statement of financial position as at 31 December 2025;

• the separate income statement for the financial year then ended;

• the separate statement of comprehensive income for the financial year then end ed;

• the separate statement of changes in equity for the financial year then ende d;

• the separate statement of cash flows for the financial year then ended, and

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• the additional notes to financial statements comprising material accounting p olicy information and other explanatory information.

Basis for opinion

We conducted our audit in accordance with the National Standards on Auditing in the wording of the International Standards on Auditing as adopted by the resolutions of the National Council of Statutory Auditors and the resolution of the Council of the Polish Agency for Audit Oversight (“NSA”) and pursuant to the act of 11 May 2017 on Statutory Auditors, Audit Firms and Public Oversight (the “Act on Statutory Auditors”) and the Regulation (EU) No. 537/2014 of 16 April 2014 on specific requirements regarding the statutory audit of public interest entities and repealing Commission Decision 2005/909/EC (the “EU Regulation”). Our responsibilities under NSA are further described in the Auditor’s responsibilities for the audit of the separate financial statements section.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Independence

We are independent of the Bank in accordance with the ethical requirements of the EU Regulation that are relevant to audits of financial statements of public interest entities, the ethical requirements of the Act on Statutory auditors that are relevant to audits of financial statements in Poland and “the Handbook of the International code of ethics for professional accountants (including International independence standards) (the “Code of ethics”) as adopted by resolution of the National Council of Statutory Auditors as applicable to audits of financial statements of public interest entities. We have also fulfilled our other ethical responsibilities in accordance with ethical requirements of the EU Regulation, ethical requirements of the Act on Statutory Auditors and the Code of ethics. During the audit, the key statutory auditor and the audit firm remained independent of the Bank in accordance with the independence requirements set out in the Act on Statutory Auditors and in the EU Regulation.

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Our audit approach

Overview

Materiality

The overall materiality threshold adopted for our audit was set at PLN 399,000 thousand, which represents approximately 5% of the profit before tax adjusted by the result on sale of subsidiaries.

Key audit matters

• Estimating the allowances for expected credit losses for loans and advances to customers

• Estimating the cost of legal risk related to the portfolio of mortgage loans in Swiss franc (CHF)

As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the separate financial statements. In particular, we considered where the Bank’s Management Board made subjective judgements; for example, in respect of significant accounting estimates that involved making assumptions and considering future events that are inherently uncertain. As in all of our audits we also addressed the risk of management override of internal controls, including among other matters, consideration of whether there was evidence of bias that represented a risk of material misstatement due to fraud.

We tailored the scope of our audit in order to perform sufficient work to enable us to provide an opinion on the separate financial statements as a whole, taking into account the structure of the Bank, the accounting processes and controls, and the industry in which the Bank operates.

Materiality

The scope of our audit was influenced by our application of materiality. An audit is designed to obtain reasonable assurance whether the separate financial statements are free from material misstatement. Misstatements may arise due to fraud or error. They are considered material if, individually or in aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of the separate financial statements.

Based on our professional judgement, we determined certain quantitative thresholds for materiality, including the overall materiality for the separate financial statements as a whole, as set out in the table below. These, together with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and extent of our audit procedures and to evaluate the effect of misstatements, if any, both individually and in aggregate on the separate financial statements as a whole.

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Overall Bank materiality

PLN 399,000 thousand

How we determined it

Approximately 5% of the profit before tax adjusted by the result on sale of subsidiaries

Rationale for the materiality benchmark applied

We chose profit before tax as the benchmark because, in our view, it is the benchmark against which the performance of the Bank is most commonly measured by users, and is a generally accepted benchmark. We adjusted this value by the result on sale of subsidiaries due to the one-off nature of the sales transaction.

We adopted the level of 5% because based on our professional judgement they are within the range of acceptable quantitative materiality thresholds.

We agreed with the Audit Committee of the Bank that we would report to them misstatements of the separate financial statements identified during our audit above PLN 19,950 thousand, as well as misstatements below that amount that, in our view, warranted reporting for qualitative reasons.

Key audit matters

Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the separate financial statements of the current period. These matters were addressed in the context of our audit of the separate financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

Key audit matter

How our audit addressed the key audit matter

Estimating the allowances for expected credit losses for loans and advances to customers

In accordance with the provisions of International Financial Reporting Standard 9, Financial Instruments, (“IFRS 9”) the Bank’s Management Board is required to determine

As part of the procedures performed, we updated our understanding of the Bank’s policies and procedures related to the estimation of allowances for expected credit losses.

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expected credit loss (“ECL”) that may occur over either a 12 month period or the remaining life of a financial asset, depending on the classification of individual assets into risk categories ("stages"), taking into account the impact of future macroeconomic conditions on the level of credit risk allowances.

The Bank’s loan portfolio consists of exposures assessed for expected credit losses:

• on an individual basis for individually significant credit exposures; and

• with the use of statistical models which estimate allowances for credit losses for each of the homogenous portfolios identified by the Bank.

Expected credit losses as at 31 December 2025 amounted to PLN 3,654,058 thousand in the portfolio of loans and advances to customers with a gross book value of PLN 160,674,158 thousand.

The Bank's Management Board monitors the correct functioning of the models, among others by comparing the results estimated by the models to actual credit losses (backtesting procedures) and performing periodic quantitative validation of the models.

In the models of expected credit losses, the Bank uses large amounts of data, therefore the completeness and reliability of data may significantly affect the accuracy of allowances for credit losses.

We tested the effectiveness of controls applied by the management related to the recognition and measurement of credit losses including, among others, controls over:

• the completeness and accuracy of input data used;

• verification of the models of probability of default (PD), loss given default (LGD) and other parameters;

• the application of future macroeconomic scenarios, forecasted macroeconomic variables and the probabilities applied for particular scenarios.

As part of the work on statistical models, we performed the following procedures, for which we engaged our internal credit risk modelling specialists:

• assessment whether the Bank’s methodology related to the estimation of expected credit losses is in line with the requirements of IFRS 9, in particular applying the criteria to identify significant increase in credit risk, default definition, PD and LGD parameters and including forward-looking information when calculating expected credit losses;

• challenging key judgments and assumptions, including macroeconomic scenarios and the probability-weightings assigned to particular scenarios;

• independent tests of the selected credit risk parameters.

In the area of the individually assessed exposures, we performed the following procedures:

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We considered allowances for expected credit losses for loans and advances portfolio as a key audit matter due to:

• high degree of uncertainty related to the estimation of the allowance for expected credit losses due to dynamic changes in the economic environment which affect the credit risk parameters used in the models for estimating expected credit losses;

• judgement used by the Bank’s Management Board in modelling future scenarios and forecasting macroeconomic variables;

• the complexity of the audit procedures and the audit evidence obtained due to the complexity of the calculations and the amount of data used to estimate the allowances for expected credit losses.

Note 2.6 Use of estimates, Note 2.8 Material accounting policy information, Note 3 Risk management and Note 21 Loans and advances to customers in the separate financial statements provide information on the models and assumptions used and the level of allowances for the expected credit losses in the portfolio of loans and advances to customers.

• we selected a sample taking into account various risk criteria based on our professional judgement;

• for selected loans and advances we checked the correct stage classification as at the balance sheet date;

• for selected impaired loans and advances (stage 3) we tested the assumptions used in the expected credit loss allowances’ calculation, particularly expected scenarios and probabilities assigned to them and the timing and amount of expected cash flows, including cash flows from repayments and realisation of collaterals.

Moreover, we performed the following procedures:

• we reconciled selected input data used for determining default parameters and estimating expected credit losses;

• in relation to individual portfolios, we verified, on the sample basis, the assignment of exposures to appropriate stages based on selected quantitative parameters;

• we performed a recalculation of expected credit losses for selected loan portfolios;

• we performed analytical procedures over provision coverage of the credit portfolio, its changes in 2025 and transfers between stages in 2025;

• we analysed the results of the Management Board of the Bank's sensitivity analysis of the level of allowances for expected credit losses due to deterioration or improvement of risk parameters.

Additionally, we assessed adequacy and completeness of disclosures in the separate financial

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statements in accordance with applicable accounting standards.

Estimating the cost of legal risk related to the portfolio of mortgage loans in CHF

As at the balance sheet date, the Bank had a portfolio of mortgage loans denominated in or indexed to the Swiss franc (CHF), in the total gross book value of PLN 2,358,619 thousand before taking into account the adjustment for the reduction of contractual cash flows due to legal risk in the amount of PLN 2,350,380 thousand and a portfolio of mortgage loans in PLN that were previously mortgage loans denominated or indexed to CHF in the gross book value of PLN 283,348 thousand before taking into account the adjustment for the reduction of contractual cash flows due to legal risk in the amount of PLN 221,208 thousand. As described in the Note 45 Legal risk connected with CHF mortgage loans in the separate financial statements, the loan agreements based on which these loans were granted, contain clauses questioned by customers in courts due to abusiveness. A negative trend for banks in relation to court judgments is observed (with the dominant line of jurisprudence declaring the invalidity of loan agreements), which affects the increase in the number of court cases brought by the bank’s clients. At the same time, banks decide to offer voluntary settlements. The Bank also developed settlement proposals and presented them to particular groups of

As part of our audit procedures, we assessed whether the accounting approach applied by the Bank is in line with the International Financial Reporting Standards as adopted by the European Union. Our audit procedures were mainly aimed at assessing the model and the particular assumptions adopted by the Bank’s Management Board that had a significant impact on the level of estimated provisions.

In particular, we carried out the following procedures:

• we discussed with the Bank’s Management Board and specialists involved in estimating the provision, including the Bank's external legal experts, the assumptions made, taking into account historical observations, including information on court judgments, completed court cases and the current number of new claims and settlements, as well as the existing and possible legal decisions, in particular the decisions of the CJEU;

• we assessed the scenarios adopted by the Bank in terms of the expected number of lawsuits against the Bank, prepared, among others, based on the number of currently filed lawsuits against the Bank based on the built statistical model (so-called behavioural model). We conducted an assessment of the assumptions made in the behavioural model;

• we assessed the assumptions adopted by the Bank based on historical data to estimate the

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clients, which was also taken into account in the applied model for estimating the costs of legal risk.

The Bank estimated the impact of this situation on the recoverability of the assumed cash flows resulting from the concluded agreements for the active portfolio of mortgage loans in CHF based on paragraph B5.4.6 of IFRS 9 by adjusting the gross carrying amount of the portfolio by reducing contractual cash flows from mortgage loans denominated or indexed to CHF and recognized a provision for the legal risk of the CHF loan portfolio in accordance with IAS 37 Provisions, Contingent Liabilities and Contingent Assets for fully repaid loans and when the gross carrying amount of the active loan was lower than the value of the identified risk. The level of deduction of the gross carrying amount of the active portfolio estimated as at 31 December 2025 and the level of provisions created amounted to PLN 2,571,589 thousand and PLN 2,194,704 thousand, respectively, and the costs of legal risk recognized in the separate income statement amounted to PLN 1,596,631 thousand.

Estimation of the cost of legal risk related to the portfolio of mortgage loans in CHF is complex and requires a significant degree of judgement due to the high degree of uncertainty of the assumptions made by the Bank’s Management Board in the model to calculate the costs of legal risk, including forecasted number of lawsuits in the future,

likelihood of future settlements and the level of losses incurred due to them;

• we obtained directly from the Bank’s external legal experts their assessment of the expected scenarios of the resolution of court cases together with an assessment of the probability of these scenarios broken down into homogeneous portfolios identified by the Bank, grouped on the basis of individual clauses in contracts;

• in cooperation with our internal legal experts, we analysed the documentation and legal opinions received directly from the Bank's external legal experts for the purposes of assessing the risk of losing the court proceedings, as well as the probabilities of particular scenarios of the court verdicts and settlements;

• we analysed the method of estimating the probable losses for each scenario assumed by the Bank based on the historical data;

• we assessed the adequacy of the model used by the Bank to estimate the costs of legal risk (including checking the correctness and completeness of the data constituting the basis for the calculation and confirming the mathematical correctness of the calculation).

Moreover, we assessed the adequacy and completeness of the disclosures in the separate financial statements in accordance with the applicable accounting standards.

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Responsibility of the Management and Supervisory Board of the Bank for the separate financial statements

The Management Board of the Bank is responsible for the preparation, based on the properly maintained books of accounts of the annual separate financial statements that give a true and fair view of the Bank’s financial position and financial performance, in accordance with International Financial Reporting Standards as adopted by the European Union, the adopted accounting policies, the applicable laws and the Bank’s Articles of Association, and for such internal control as the Bank’s Management Board determines is necessary to enable the preparation of separate financial statements that are free from material misstatement, whether due to fraud or error.

as well as possible court settlement scenarios and estimated levels of expected losses on their basis.

Due to the uncertainty as to the assumptions described above, as well as the significant value of the portfolio of loans denominated and indexed to CHF and significant impact of the cost of legal risk on the Bank’s financial result, we considered this area to be the key audit matter.

Note 45 Legal risk connected with CHF mortgage loans in the separate financial statements contains detailed information on the assumptions adopted in the model to calculate the costs of legal risk related to the portfolio of mortgage loans in CHF and possible alternative results presented in as part of the estimation sensitivity analysis as well as current and possible legal decisions, including decisions of the Court of Justice of the European Union (“CJEU”).

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In preparing the separate financial statements, the Bank’s Management Board is responsible for assessing the Bank’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting

unless the Bank’s Management Board either intends to liquidate the Bank or to cease operations, or has no realistic alternative but to do so.

The Bank’s Management Board and members of the Supervisory Board are obliged to ensure that the separate financial statements comply with the requirements specified in the Accounting Act. Members of the Supervisory Board are responsible for overseeing the financial reporting process.

Auditor’s responsibility for the audit of the separate financial statements

Our objectives are to obtain reasonable assurance about whether the separate financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with the NSA will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in aggregate, they could reasonably be expected to influence economic decisions of users taken on the basis of these separate financial statements.

The scope of the audit does not include an assurance on the Bank’s future profitability nor the efficiency and effectiveness of conducting its affairs by the Bank’s Management Board, now or in future.

As part of an audit in accordance with NSA, we exercise professional judgement and maintain professional scepticism throughout the audit. We also:

• identify and assess the risks of material misstatement of the separate financial statements, whethe r due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opin ion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override o f internal control;

• obtain an understanding of internal control relevant to the audit in order to d esign audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opin ion on the effectiveness of the Bank’s internal control;

• evaluate the appropriateness of accounting policies used and th e reasonableness of accounting estimates and related disclosures made by the Bank’s Management Board ;

• conclude on the appropriateness of the Bank’s Management Board’s u se of the going concern basis of accounting and, based on the audit evidence obtained , whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Bank’s ability to continue a s a going

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concern. If we conclude that a material uncertainty exists, we are required to draw attention i n our auditor’s report to the related disclosures in the separate financial statements or, if such d isclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause th e Bank to cease to continue as a going concern;

• evaluate the overall presentation, structure and content of the separate financial sta tements, including the disclosures, and whether the separate financial statements represent the unde rlying transactions and events in a manner that achieves fair presentation.

We communicate with the Audit Committee of the Bank regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

We also provide the Audit Committee of the Bank with a statement that we have complied with relevant ethical requirements regarding independence, and communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, actions taken to eliminate threats or safeguards applied.

From the matters communicated to the Audit Committee of the Bank, we determine those matters that were of most significance in the audit of the separate financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor’s report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

Other information, including the report on operations

Other information comprises:

• a Management Board Report on Santander Bank Polska Group Performance in 2025 (including a Report on Santander Bank Polska S.A. Performance (“the Report on the operations”) together with the corporate governance statement and the consolidated sustainability statement of Santander Bank Polska Group for 2025 which are separate parts of the Report on the operations,

• other documents included in the Annual Report for the financial year e nded 31 December 2025

(together “Other Information”).

Other information does not include the separate financial statements and our auditor’s report thereon.

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Responsibility of the Management and Supervisory Board of the Bank

The Management Board of the Bank is responsible for the preparation of the Other Information in accordance with the law.

The Bank’s Management Board and the members of the Supervisory Board are obliged to ensure that the Report on the operations including its separate parts complies with the requirements of the Accounting Act.

Statutory auditor’s responsibility

Our opinion on the separate financial statements does not cover the Other Information.

In connection with our audit of the separate financial statements, our responsibility under NSA is to read the Other Information and, in doing so, consider whether the Other Information is materially inconsistent with the information in the separate financial statements, our knowledge obtained in our audit, or otherwise appears to be materially misstated. If, based on the work performed, we identified a material misstatement in the Other Information, we are obliged to inform about it in our audit report.

In accordance with the requirements of the Act on Statutory Auditors, we are also obliged to issue an opinion on whether the Report on the operations, to the extent not related to sustainability reporting, has been prepared in accordance with the requirements of Article 49 of the Accounting Act and para. 72 of the Regulation of the Minister of Finance dated 6 June 2025 on current and periodical information submitted by issuers of securities and conditions for considering as equivalent the information required under the legislation of a non-Member State (“Regulation on current information”) and Article 111(1–2) of the act of 29 August 1997 – the Banking Law (“the Banking Law”), is consistent with information included in financial statements and to issue a statement as to whether, in the light of the knowledge about the Bank and its environment obtained during the audit, any material misstatements have been identified in the Report on the operations, to the extent not related to sustainability reporting, and an indication of what any such material misstatement is.

Moreover, we are obliged to issue an opinion on whether the Bank provided the required information in its corporate governance statement.

In addition, we are required to audit the financial information included in chapter X of the Report on the operations in accordance with the scope described in this audit report and the requirements of the Banking Law.

Statement on the Other information

We declare that, based on the knowledge of the Bank and its environment obtained during our audit:

13 Independent Statutory Auditor’s Report

• we have nothing to report regarding identification of material misstatements i n the Other information;

• that we have not identified any material misstatements in the Report on the operations, to th e extent not related to sustainability reporting.

Opinion on the Report on the operations, to the extent not related to sustainability reporting

Based on the work we carried out during our audit, in our opinion, the Report on the operations, to the extent not related to sustainability reporting:

• has been prepared in accordance with the requirements of Article 49 of the Accoun ting Act and para. 72 of the Regulation on current information and Article 111(1–2) of the Banking Law;

• is consistent with the information in the separate financial statements.

Opinion on the corporate governance statement

In our opinion, in its corporate governance statement, the Bank included information set out in para. 72.7 (5) of the Regulation on current information. In addition, in our opinion, information specified in paragraph 72.7 (5)(c)–(f), (h) and (i) of the said Regulation included in the corporate governance statement are consistent with the applicable provisions of the law and with information included in the separate financial statements.

Report on other legal and regulatory requirements

Information on compliance with prudential regulations

The Management Board of the Bank is responsible for complying with the applicable prudential regulations set out in separate legislation, and in particular, for correct determination of the capital ratios.

The capital ratios as at 31 December 2025 have been presented in point 9 of chapter XI of the Report on the operations and include Tier 1 capital ratio and the total capital ratio.

We are obliged to inform in our report on the audit of the separate financial statements whether the Bank has complied with the applicable prudential regulations set out in separate legislation, and in particular, whether the Bank has correctly determined its capital ratios. For the purposes of the said information, the following legal acts are understood as separate legislation: Regulation (EU) no. 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012, as amended (“CRR”), the Banking Law and the Act of 5 August 2015 on macro-prudential supervision over the financial system and on crisis management in the financial system (“the Act on macro-prudential supervision”).

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It is not the purpose of an audit of the separate financial statements to present an opinion on compliance with the applicable prudential regulations specified in the separate legislation specified above, and in particular, on the correct determination of the capital ratios, and therefore, we do not express such an opinion.

Based on the work performed by us, we inform you that we have not identified:

• any cases of non-compliance by the Bank with the applicable prudential re gulations set out in separate legislation referred to above, in the period from 1 January to 31 December 2025;

• any irregularities in the determination by the Bank of the capital ratios as at 31 Decemb er 2025 in accordance with the separate legislation referred to above;

which would have a material impact on the separate financial statements.

Statement on the provision of non-audit services

To the best of our knowledge and belief, we declare that the non-audit services that we provided to the Bank and its controlled entities within the European Union are in accordance with the applicable laws and regulations in Poland and that we have not provided non-audit services that are prohibited under Article 5(1) of the EU regulation and Article 136 of the Act on Statutory Auditors.

The non-audit services which we have provided to the Bank and its controlled entities during the period from the beginning of the audited period to the date of issuing this report are disclosed in the Report on the operations.

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Appointment

We were first appointed to audit the annual separate financial statements of the Bank by resolution of the Supervisory Board of the Bank dated 22 March 2016 and re-appointed by resolution dated 11 December 2024. We have been auditing the Bank’s separate financial statements without interruption since the financial year ended 31 December 2016, i.e. for ten consecutive years.

The Key Statutory Auditor responsible for the audit on behalf of PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k., a company entered on the list of audit firms with the number 144., is Maciej Wałęga.

Original report is signed in Polish.

Maciej Wałęga

Key Statutory Auditor

No. in the registry 90147

Warsaw, 23 February 2026