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Independent Statutory Auditor’s Report

on the Assurance of Sustainability Reporting of ING Bank

Śląski S. A. Capital Group for 2025

Providing Limited Assurance

Forvis Mazars Audyt Sp. z o.o.

ul. Piękna 18

00-549 Warsaw

Forvis Mazars Audyt Sp. z o.o.

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

NIP: 5260215409, REGON: 011110970 2

INDEPENDENT STATUTORY AUDITOR’S REPORT ON THE ASSURANCE OF

SUSTAINABILITY REPORTING PROVIDING LIMITED ASSURANCE

Translation of the document originally issued in Polish

To the General Meeting and the Supervisory Board of ING Bank Śląski S. A. [a joint stock company]

Opinion

We have conducted an assurance engagement with respect to sustainability reporting providing limited

assurance on the sustainability reporting of the ING Bank Śląski S.A. Group (the "Group"), of which ING

Bank Śląski S. A. is the parent undertaking (the “Parent Undertaking") prepared as of 31 December 2025

and for the period from 1 January 2025 to 31 December 2025, included in a separate section of the

Management Report of ING Bank Śląski S.A. Group in 2025 entitled "Sustainability Statement" (the

"Sustainability Reporting").

Based on the assurance procedures we performed and the evidence we obtained, nothing has come to

our attention that would lead us to believe that:

• the attached Sustainability Reporting does not comply, in all material respects, with the

requirements of Chapter 6c of the Accounting Act of 29 September 1994 (Journal of Laws 2023,

item 120, as amended) (the "Accounting Act"), including the European Sustainability Reporting

Standards ("ESRS"),

• the materiality assessment process carried out by the Parent Undertaking to identify information

included in the Sustainability Reporting (the "Materiality Assessment Process") does not comply,

in all material respects, with the ESRS,

• the attached Sustainability Reporting does not comply, in all material respects, with the reporting

requirements of Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the

Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment,

and amending Regulation (EU) 2019/2088 (Official Journal of the EU L 198, 22.06.2020, p. 13, as

amended).

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Basis for Opinion

We conducted our engagement regarding assurance of sustainability reporting providing limited assurance

in accordance with the National Standard on Sustainability Assurance Services 3002PL - “Assurance

Engagement Providing Limited Assurance on Sustainability Reporting” established by the National Council

of Statutory Auditors by resolution no. 854/20a/2025 of 23 January 2025 (“KSUA 3002PL”) and accordingly

by National Standard on Assurance Engagements Other than Audits and Reviews 3000 (revised) as per

International Standard on Assurance Engagements 3000 (Revised) – ‘Assurance Engagements Other

than Audits or Reviews of Historical Financial Information’ established by the National Council of Statutory

Auditors by resolution no. 3436/52e/2019 of 8 April 2019 (“KSUA 3000 (R)”).

The level of assurance obtained under a limited assurance engagement is significantly lower than under

a reasonable assurance engagement because the procedures performed by the sustainability reporting

assurance auditor under a limited assurance engagement differ in nature and timing and are narrower in

scope than under a reasonable assurance engagement.

Our responsibilities under these standards are further described in the "Responsibilities of the auditor of

sustainability reporting assurance” section.

We are independent of the Group Companies in accordance with the principles of ethics set out in the

“Handbook of the International Code of Ethics for Professional Accountants (including International

Independence Standards)” adopted by resolution of the National Council of Statutory Auditors No.

207/7a/2023 of 17 December 2023 on the establishment of principles of professional ethics for statutory

auditors, as amended (“Code of Ethics”) relating to assurance engagements, and the requirements set

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

text, Journal of Laws of 2025, item 1891) and EU Regulation No. 537/2014 of 16 April 2014 on specific

requirements regarding statutory audit of public-interest entities and repealing Commission Decision

2005/909/EC (Official Journal of the EU L 158, 27.05.2014, p. 77, as amended) that are relevant to the

sustainability reporting assurance engagement, and we have fulfilled our other ethical responsibilities in

accordance with these requirements and the Code of Ethics.

Our audit firm applies National Standard on Quality Control 1 as per International Standard on Quality

Management (PL) 1 - “Quality Management for Firms that Perform Audits or Reviews of Financial

Statements, or Other Assurance or Related Services” introduced by the resolution of the Council of the

Polish Agency for Audit Oversight no 38/I/2022 of 15 November 2022, which requires the audit firm to

design, implement and operate a system of quality management, including policies or procedures relating

to compliance with ethical requirements, professional standards and applicable legal and regulatory

requirements.

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

opinion of the assurance engagement performed providing limited assurance.

Forvis Mazars Audyt Sp. z o.o. 4

Responsibility for Sustainability Reporting

The Parent Undertaking’s Management Board is responsible for:

• preparation of Sustainability Reporting in accordance with Chapter 6c of the Accounting Act,

including ESRS,

• conducting a Materiality Assessment Process in accordance with the ESRS,

• preparation of Sustainability Reporting in accordance with Article 8 of Regulation (EU) 2020/852 of

the European Parliament and of the Council of 18 June 2020 on the establishment of a framework

to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (Official Journal of

the EU L 198, 22.06.2020, p. 13, as amended),

• designing, implementing and maintaining such internal control as the Management Board deems

necessary for the preparation of Sustainability Reporting in accordance with Chapter 6c of the

Accounting Act, including ESRS and Article 8 of Regulation (EU) 2020/852 of the European

Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate

sustainable investment, and amending Regulation (EU) 2019/2088 (Official Journal of the EU L

198, 22.06.2020, p. 13, as amended), which does not contain material misstatements, whether due

to fraud or error,

including the Parent Undertaking's Management Board is responsible for developing and implementing

the Materiality Assessment Process and for presenting the process in Sustainability Reporting. These

responsibilities include, but are not limited to:

• understanding the context in which the Group's business activities and relationships are conducted,

as well as understanding the stakeholders affected by the Group,

• identification of actual and potential impacts (both negative and positive) related to sustainability

issues, as well as risks and opportunities that affect or can reasonably be expected to affect the

Group’s financial position, financial performance, cash flows, access to financing or cost of capital

in the short, medium or long term,

• assessing the materiality of identified impacts, risks and opportunities related to sustainability

issues by selecting and applying appropriate thresholds, and

• making assumptions that are reasonable under the circumstances.

The Parent Undertaking's Management Board is also responsible for selecting and applying appropriate

methods for reporting sustainability issues and determining estimates or preparing forward-looking

information in individual disclosures in Sustainability Reporting that are reasonable under the

circumstances.

The Supervisory Board is responsible for overseeing the Group's Sustainability Reporting process.

Inherent Limitations in Preparing Sustainability Reporting and Measuring and Evaluating

Sustainability Issues

There are inherent limitations to measuring or evaluating Sustainability Reporting subject to assurance

providing limited assurance, which are outlined below:

• When reporting forward-looking information in accordance with the ESRS, the Parent

Undertaking's Management Board is required to prepare forward-looking information based on

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disclosed assumptions about events that may occur in the future and possible future activities of

the Group. The actual outcome may be different, as anticipated events often do not occur as

expected.

• In determining disclosures in Sustainability Reporting, the Parent Undertaking's Management

Board interprets undefined legal terms and other concepts. Undefined legal terms and other

concepts can be interpreted in different ways, including the legality of their interpretation, and are

therefore subject to uncertainty.

Sustainability Reporting Assurance Auditor’s Responsibility

Our objectives are to plan and perform the sustainability reporting assurance engagement so as to obtain

limited assurance that the Sustainability Reporting does not contain material misstatements, whether due

to fraud or error, and to issue a sustainability reporting assurance report providing limited assurance that

includes our opinion. Misstatements can arise from fraud or error and are considered material if,

individually or in the aggregate, they could reasonably be expected to influence the economic decisions of

users taken on the basis of this Sustainability Reporting.

As part of the sustainability reporting assurance engagement providing limited assurance, conducted in

accordance with KSUA 3002PL, we use professional judgment and maintain professional skepticism

throughout the service.

Our responsibilities with respect to Sustainability Reporting in connection with the Materiality Assessment

Process include:

• obtaining an understanding of the Materiality Assessment Process solely for the purpose of

assessing its compliance with the ESRS, and not to express an opinion on the effectiveness of the

process, including its outcome,

• designing and performing procedures to assess whether the Materiality Assessment Process is

consistent with the description of the Materiality Assessment Process outlined in Sustainability

Reporting.

Our other responsibilities with respect to Sustainability Reporting include:

• gaining an understanding of the control environment, processes and information systems relevant

to the preparation of Sustainability Reporting, but do not include evaluating the design of individual

controls, or obtaining evidence of their implementation or testing their effectiveness,

• identifying disclosures in which material misstatements may arise, whether due to fraud or error,

• designing and performing procedures for disclosures in Sustainability Reporting where material

misstatements may arise. The risk of not detecting a material misstatement resulting from fraud is

higher than for one resulting from error, as fraud may involve collusion, forgery, intentional

omissions, misrepresentations, or the override of internal control.

Summary of the Work Performed

The sustainability reporting assurance engagement providing limited assurance involves performing

procedures to obtain evidence on Sustainability Reporting. The type, timing and extent of procedures

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selected depend on professional judgment, including the identification of disclosures in Sustainability

Reporting where material misstatements may arise, whether due to fraud or error.

In performing our assurance engagement providing limited assurance on the Materiality Assessment

Process, we performed the following work:

• we gained an understanding of the Materiality Assessment Process through:

 directing inquiries to understand the sources of information used by the Parent Undertaking's

Management Board (e.g., stakeholder engagement, business plans and strategic documents),

 review of the Parent Undertaking's internal documentation regarding its Materiality Assessment

Process,

• we assessed whether the evidence obtained from our procedures for the Materiality Assessment

Process was consistent with its description as presented in in the "Process for assessing material

sustainability impacts, opportunities and risks" section of Sustainability Reporting.

In performing our assurance engagement providing limited assurance on Sustainability Reporting, we

performed the following procedures:

• we gained an understanding of the Group’s reporting processes relevant to the preparation of

Sustainability Reporting by understanding the Group’s internal control system, its processes and

IT systems, but not for the purpose of expressing an opinion on the effectiveness of the Group's

internal control,

• we assessed whether the material information identified through the Materiality Assessment

Process was included in Sustainability Reporting,

• we assessed whether the structure and presentation of Sustainability Reporting complies with the

ESRS,

• we directed inquiries to personnel involved in the preparation of Sustainability Reporting and

performed analytical procedures on selected disclosures in Sustainability Reporting,

• we performed substantive procedures on a sample of selected disclosures included in

Sustainability Reporting,

• we obtained evidence regarding the methods, assumptions and data used to develop significant

estimates and forward-looking information,

• we gained an understanding of the process related to the identification of taxonomy-eligible and

taxonomy-compliant business activities and the corresponding disclosures in Sustainability

Reporting,

• we gained an understanding of the process of collecting, preparing and aggregating data used in

the process of preparing Sustainability Reporting,

• where appropriate, we have compared the disclosures in the Sustainability Reporting with the

corresponding disclosures in the consolidated financial statements and the Group management

report,

• we obtained evidence on the methods and assumptions used to assess the compliance of the

Group operations with the minimum safeguards.

Forvis Mazars Audyt Sp. z o.o. 7

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

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

sustainability reporting assurance engagement.

Warsaw, 5

March 2026

Małgorzata Pek

Key Auditor of Sustainability Reporting Assurance

No 13 070