STATEMENT OF COMPLIANCE WITH THE CORPORATE GOVERNANCE PRINCIPLES Corporate governance principles and scope of application Controls in the process of preparing financial statements Articles of Association of PKO Bank Polski S.A. General Meeting of PKO Bank Polski S.A. Supervisory Board of PKO Bank Polski S.A. during the reporting period Management Board of PKO Bank Polski S.A. during the reporting period 1. CORPORATE GOVERNANCE PRINCIPLES AND SCOPE OF APPLICATION CORPORATE GOVERNANCE PRINCIPLES INCLUDED IN THE DOCUMENT TITLED “BEST PRACTICE FOR WSE LISTED COMPANIES 2016” The Bank has adopted for application the principles and recommendations contained in the collection titled “Best Practice for WSE Listed Companies 2016” (hereinafter: Best Practice), with the reservation that recommendation IV.R.2., which concerns enabling shareholders to participate in the General Shareholders’ Meeting by means of electronic communication, will not be applied. The Bank applies recommendation IV.R.2 only in part concerning the real-time broadcast of General Shareholders’ Meetings. The text of the Best Practice is publicly available on the official website of the Warsaw Stock Exchange, at https://www.gpw.pl/dobre-praktyki. The information on the Bank’s application of recommendations and principles included in the Best Practice is available on the Bank’s website (https://www.pkobp.pl/investor-relations/corporate-governance/best-practice-for-gpw- listed-companies-2016/). This information is prepared on the form provided by the Warsaw Stock Exchange and shows the detailed status of compliance or non-compliance with each of the recommendations and principles of the Best Practice. On this website, the Bank also discloses reports on possible, incidental non-application of any rule contained in the Best Practice. COMPLIANCE WITH THE RULES CONTAINED IN THE “BEST PRACTICE FOR WSE LISTED COMPANIES 2016” In 2020, the Bank incidentally violated rule II.Z.11 of the Best Practice, which indicates that the Supervisory Board must consider and give its opinion on matters to be the subject of resolutions of the General Shareholders’ Meeting. In connection with this fact, pursuant to § 29 section 3 of the WSE Rules, the Bank published a report regarding an incidental breach of the above-mentioned rule. The Bank indicated that the breach consisted in the Bank Supervisory Board’s failure to express an opinion on the draft resolutions of the Bank’s General Shareholders’ Meeting in connection with the drafts sent by the Bank’s shareholder two days before the meeting. It became impossible to express an opinion on the drafts sent, due to the very short time for the Supervisory Board to make a formal decision. COMPLIANCE WITH THE RECOMMENDATIONS CONTAINED IN THE “BEST PRACTICE FOR WSE LISTED COMPANIES 2016” INFORMATION POLICY AND COMMUNICATION WITH INVESTORS The Bank’s overriding aim regarding information activities is to guarantee high standards of communication with the participants of the capital market, which are a sign of respect for the principles of universal and equal access to information. To achieve this aim, the Bank pursues its information policy in a manner that ensures proper, reliable and complete access to information about the Bank for all investors, with no preferences as regards any of them. The above rules have been formally adopted by the Bank in the “Principles of the information policy of PKO Bank Polski S.A. regarding contacts with investors and customers”, which can be found on the Bank’s website. While implementing this policy the Bank takes special care to enable investors and analysts to ask questions and obtain explanations on issues of interest to them. To this end, cyclical individual meetings of investors with Bank representatives are organized, as well as conferences connected with the presentation of the Bank (among investors and capital market analysts) and conferences and teleconferences every time immediately after the publication of interim reports of PKO Bank Polski S.A. (in 2020 due to the pandemic mainly in electronic form using available applications). On an ongoing basis, answers are provided to investors’ questions in writing, by e-mail (including a dedicated mailbox) or by telephone. In order to inform the market about the situation of PKO Bank Polski S.A. as soon as possible, the financial results are published as soon as possible after the end of the reporting period. The successive shortening of publication deadlines in this respect was disrupted in 2020 by the need to determine the impact of the pandemic on the results of the Bank and the Bank’s Group. The Bank also has recommended internal regulations with regard to providing explanations and rectifications relating to untrue, imprecise or harmful information in the media. Page 1/28 Within the framework of its widely understood information policy, the Bank describes its major policies in respect of its sponsorship and charitable activities in the annual Directors’ Report on the operations of the Bank’s Group. In this Directors’ Report the said information can be found in chapter 13.4.1. As a confirmation of the quality of the Bank’s information activities, in 2020, in the largest survey of investor relations of WIG30 companies in Poland, prepared by Parkiet and the Chamber of Brokerage Houses (Izba Domów Maklerskich), the Bank was ranked third among companies which, according to institutional investors and analysts, communicate best with the market. MANAGEMENT BOARD AND SUPERVISORY BOARD Members of the Management Board and Supervisory Board of PKO Bank Polski S.A. are appointed in a manner allowing for the selection of persons having high qualifications and experience. The above is reflected in the suitability assessment policies for members of both these authorities adopted by the Bank in 2020. These policies are implemented at the Bank taking into account the principle of diversity of members of both the Management Board and the Supervisory Board. The diversity principle is designed to ensure that Members of the Management Board or the Supervisory Board are appropriately selected to obtain a broad range of competences, knowledge and skills that are adequate for the position and guarantee that the members of the Management Board or the Supervisory Board, individually and as a body, issue independent opinions and decisions on the whole range of the Bank’s activities. The principle of diversity of selection is based on objective substantive criteria in terms of education and professional experience. Should the need arise, the Bank provides the Supervisory Board with professional, independent advisory services. Both members of the Management Board and Supervisory Board devote the necessary amount of time to perform their duties. Attendance at meetings of the Supervisory Board is high, and absences are justified in resolutions of the Supervisory Board. Serving on the Bank’s Management Board is the main area of activity for the members of this body, while membership on the bodies of other entities mainly involves supervisory functions in the companies of the Bank’s Group. The Bank’s Supervisory Board, as part of succession management, makes decisions regarding the selection of new Members of the Bank’s Management Board keeping in mind the objective to ensure continuity in decision making with regard to the area of the Bank’s operations supervised by a given Member of the Bank’s Management Board and the entire Management Board of the Bank. Following this principle, due to the fact that the term of office of the Board of Executives expires in mid 2020, the Supervisory Board selected the members of this body well in advance. The Bank’s statutory obligation to maintain the composition of the Supervisory Board is the need to convene the General Shareholders’ Meeting in order to supplement the composition of the Supervisory Board in the event that the number of members of this body decreases below 5. INTERNAL SYSTEMS AND FUNCTIONS The Bank has separated in its structure units responsible for the performance of tasks in particular systems and functions, especially units dealing with internal control, risk management and compliance. The main assumptions of the internal control system and risk management rules at the Bank are presented in chapter 11.2.2 and 9.1 of the Report. GENERAL SHAREHOLDERS’ MEETING AND SHAREHOLDER RELATIONS The Bank aims to hold annual general meetings as soon as possible after the publication of the annual report. Over the past five years, this period has shortened by approximately one month. The exception is the date of the 2020 Annual General Meeting of the Bank, which due to the pandemic fell at the end of August 2020. Each General Meeting is broadcast in real time. CONFLICT OF INTERESTS AND RELATED PARTY TRANSACTIONS The internal regulations of PKO Bank Polski S.A. guarantee compliance with the recommendations and principles included in the “Best Practice for WSE Listed Companies 2016”. The Bank has internal regulations regarding the management of conflicts of interest. According to those regulations, both a member of the Supervisory Board and a Member of the Management Board should refrain from any professional or non-professional activity that could lead to a conflict of interests or otherwise have an adverse effect on his reputation as a member of the supervisory or management body. There are also rules regarding the obligation to disclose conflicts, abstaining from making decisions and excluding members of these bodies from participating in the