Powszechna Kasa Oszczednosci Bank Polski SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	PKO Bank Polski provides only minimal insight into how it governs lobbying. It states that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," indicating an intention to align any policy engagement with climate objectives. However, the Bank also discloses that "At present, the Bank has not appointed a representative from its management or supervisory bodies responsible for lobbying and political influence" and that the Group "does not identify any additional risks related to political influence, including lobbying activities." Beyond these statements, the detailed governance structures it describes—such as the "Sustainable Development Committee [which] supports the Management Board in setting priorities, defining strategic directions, and establishing goals related to sustainability and energy transition"—relate to product development, ESG risk, and green-bond oversight rather than to lobbying or advocacy. There is no evidence of processes for reviewing or monitoring direct or indirect lobbying, no description of how lobbying positions are assessed for climate alignment, and no individual or committee tasked with overseeing lobbying activities. Consequently, the disclosure amounts to a broad commitment without a supporting governance framework, suggesting only limited transparency and accountability over lobbying alignment. View Sources	D

Overall Assessment

Analysis

Score

Limited

PKO Bank Polski provides only minimal insight into how it governs lobbying. It states that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," indicating an intention to align any policy engagement with climate objectives. However, the Bank also discloses that "At present, the Bank has not appointed a representative from its management or supervisory bodies responsible for lobbying and political influence" and that the Group "does not identify any additional risks related to political influence, including lobbying activities." Beyond these statements, the detailed governance structures it describes—such as the "Sustainable Development Committee [which] supports the Management Board in setting priorities, defining strategic directions, and establishing goals related to sustainability and energy transition"—relate to product development, ESG risk, and green-bond oversight rather than to lobbying or advocacy. There is no evidence of processes for reviewing or monitoring direct or indirect lobbying, no description of how lobbying positions are assessed for climate alignment, and no individual or committee tasked with overseeing lobbying activities. Consequently, the disclosure amounts to a broad commitment without a supporting governance framework, suggesting only limited transparency and accountability over lobbying alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	PKO Bank Polski S.A. is fully transparent in stating that it carried out no climate-related lobbying in 2024. The company explicitly notes, "In 2024, no active participation of the Bank's representatives in meetings with the European Commission or the European Parliament was recorded in the transparency register. No contributions to public consultations or activities in expert groups were recorded either," thereby making clear that it did not engage with any specific climate policies or legislative proposals. It also explains the absence of lobbying mechanisms, confirming that there were no letters, meetings, consultations or industry-association interventions aimed at policymakers. Finally, it clarifies that it sought no policy outcomes, adding, "At present, the Bank has not appointed a representative from its management or supervisory bodies responsible for lobbying and political influence. The Bank’s Group does not identify any additional risks related to political influence, including lobbying activities." By explicitly identifying the lack of activity and providing the context for this non-engagement, the bank demonstrates a high level of transparency across the policies lobbied, the mechanisms used, and any outcomes sought.	A