MBank SA

The Sustainable Development Committee of mBank Group has been founded in December 2020. It is a platform for making decisions, issuing recommendations and dialogue on sustainable development. The Committee shapes, promotes and monitors sustainable development in the mBank Group. These tasks comprise analysis of the impact of ESG factors. The Committee supervises the implementation of the new ESG strategy. The Committee is chaired by Vice-President of the Management Board, Chief Risk Officer and includes senior-level representatives from all mBank business lines and Group subsidiaries. The ESG strategy is implemented by the "ESG Programme", which coordinates the work of various organisational units of mBank Group. One of the programme's streams is the "Responsible Bank" stream directly responsible for the implementation of the UNEP FI Principles for Responsible Banking. The Committee meets on a quarterly basis, or more frequently if necessary. In 2022 there have been seven sittings of the Committee. The Committee approved, i.a. a map of ESG goals for the organization, classification criteria and a pool of contracts financing RES for the purpose of green bonds issuance, criteria for a marketing ecosymbol, criteria for sustainable financing for corporate clients transactions, mBank's ethical programme, ESG criteria in a product process. During the meetings, committee members also discussed the objectives of mBank's ESG strategy for 2023, the results of greenwashing risk scenario, the UNEP FI "Commitment to Financial Health and Inclusion" declaration and ESG standards for investment funds. The ESG issues are an essential part of business processes in mBank Group, such as risk management, introduction and sale of new financial products, recruitment and development of employees or relations with suppliers.

Strategic, directional decisions on ESG are taken by mBank's Management Board. They are preceded by consultations and arrangements with various stakeholders within the organisation. We also engage with external consultants who help us to develop the best solutions in terms of calculating the carbon footprint or methodologies related to the measurement and management of physical risks. Senior executives at mBank are also involved in the reporting process. [...] In December 2020, the bank appointed the mBank Group Sustainable Development Committee. It oversees the implementation of the ESG strategy, identifies the main directions of activities and proposes them to the Management Board, organizes the ESG management system and supervises the course of initiatives in this area. The Committee issues decisions and recommendations regarding ESG policies and guidelines. Moreover, it coordinates the work of various organisational units of mBank Group and is a platform for dialogue on sustainable development. The Committee is chaired by the vice-president of the management board, Chief Risk Officer, and is composed of representatives of all mBank areas and Group subsidiaries. In 2022 there have been seven sittings of the Committee. [...] Every quarter, mBank's Management Board discusses ESG topics with the Supervisory Board. Also, the Risk Committee of the Supervisory Board regularly deals with ESG issues. Management Board members and senior executives expand their knowledge and competences in the field of sustainability. Competence in this area is enhanced through, among other things, participation in training courses, analysis of good practice and market trends, or attendance at conferences and industry events. In addition, Professor Agnieszka Słomka-Gołębiowska, Chairwoman of the Supervisory Board of mBank, is a member of the Board of Chapter Zero Poland, a programme to develop the competencies of management and supervisory bodies of companies, under the auspices of the Responsible Business Forum.

The Sustainable Development Committee of mBank Group has been founded in December 2020. It is a platform for making decisions, issuing recommendations and dialogue on sustainable development. The Committee shapes, promotes and monitors sustainable development in the mBank Group. These tasks comprise analysis of the impact of ESG factors. The Committee supervises the implementation of the new ESG strategy. The Committee is chaired by Vice-President of the Management Board, Chief Risk Officer and includes senior-level representatives from all mBank business lines and Group subsidiaries. The ESG strategy is implemented by the "ESG Programme", which coordinates the work of various organisational units of mBank Group. One of the programme's streams is the "Responsible Bank" stream directly responsible for the implementation of the UNEP FI Principles for Responsible Banking. The Committee meets on a quarterly basis, or more frequently if necessary. In 2022 there have been seven sittings of the Committee. The Committee approved, i.a. a map of ESG goals for the organization, classification criteria and a pool of contracts financing RES for the purpose of green bonds issuance, criteria for a marketing ecosymbol, criteria for sustainable financing for corporate clients transactions, mBank's ethical programme, ESG criteria in a product process. During the meetings, committee members also discussed the objectives of mBank's ESG strategy for 2023, the results of greenwashing risk scenario, the UNEP FI "Commitment to Financial Health and Inclusion" declaration and ESG standards for investment funds. The ESG issues are an essential part of business processes in mBank Group, such as risk management, introduction and sale of new financial products, recruitment and development of employees or relations with suppliers.

We do not provide financial support in the form of donations to political parties and politically oriented organisations. This principle is described in our Anti-Corruption Policy. We also generally do not give donations to other organisations (with the exception of the mFoundation and WOŚP). In the case of organisations of which mBank is a member, the application for joining the organisation and for paying membership fees is checked and registered each time. [...] In December 2020, we established the mBank Group Sustainability Committee. The Committee is chaired by the Vice-President of the Management Board responsible for risk (CRO) and includes representatives from all mBank business lines and Group subsidiaries. The Committee identifies the main lines of action and proposes them to the Management Board, organises the ESG management system, supervises the progress of ESG initiatives, and monitors key ESG indicators. The Committee issues decisions and recommendations on ESG policies and guidelines. The Committee coordinates the work of mBank Group's organisational units and serves as a forum for dialogue, decision-making and recommendations on sustainability. [...] ESG factors are among the aspects we take into account when assessing the performance of mBank's more than 100 top employees, including the members of the Management Board. Every quarter, ESG topics are discussed by mBank's Management Board with the Supervisory Board. ESG factors are also regularly discussed by the Risk Committee of the Supervisory Board. From among the members of the Management Board, its President is directly responsible for implementing and maintaining ethical standards at mBank. In turn, the Vice-President acting as Chief Risk Officer directly supervises the ESG risk area.

At mBank, we believe that sustainability is our collective responsibility, embraced not just by the Supervisory Board and Management Board, but by every employee of our organisation. We recognise that the role of leadership is to support this commitment and to build an organisation fully equipped to achieve our goals. In 2023, we took significant steps to accomplish this mission. Sustainable development and progress in strategy implementation are regular items on the agenda of meetings of the Supervisory Board and its commissions. The implementation of the ESG programme at mBank is the responsibility of the Management Board and its Sustainability Committee. Additionally, the Supervisory Board and Management Board members undergo targeted training on key topics, such as the Corporate Sustainability Reporting Directive (CSRD). These actions underscore our dedication to making sustainability a core aspect of our operations and culture. [...] The implementation of the ESG strategy is overseen by the Sustainable Development Committee of the mBank S.A. Group, which is responsible for making decisions and formulating recommendations, and conducts a dialogue on sustainable development between the bank's organisational units and between the bank and Group companies. The Committee's decisions and recommendations support the consistent approach of other Group bodies to sustainable development. In addition, the Committee coordinates the alignment of the Group with regulatory and market requirements for ESG. [...] As part of these activities, the Committee: identifies the main lines of action and organises the ESG management system, sets the bank's ESG framework – policies and procedures, supervises the Group's ESG management system, defines the structure and organises the process of managing proceeds from the issue of 'green' debt instruments, in 2023, the Committee was chaired by the Vice-President of the Management Board, Chief Risk Officer (CRO), and it is composed of representatives of all mBank divisions and Group companies. In November 2023, its composition was extended to include the Vice-President of the Management Board, Chief People & Regulatory Officer, the Vice-President of the Management Board, Chief Financial Officer (CFO), and the Vice-President of the Management Board, Head of Corporate and Investment Banking. In 2023, four meetings of the Committee were held. In 2024, Julia Nusser, Vice-President of the Management Board, Chief People & Regulatory Officer, became the Committee's Chairwoman.

**Marek Lusztyn, Vice-President** **of mBank's Management Board,** **Chairman of mBank Group's Sustainability Committee** This is why, while raising our own ESG standards, we are also increasing the requirements for our suppliers and business partners. In early 2022, we introduced an ESG code that applies to you. [...] **Iwona Ryniewicz, Vice-Chairman** **of mBank Group's Sustainability** **Committee** [...] All companies which participate in a procurement process organised by mBank [or another mBank Group company are subject to our Rules for Suppliers.](https://www.mbank.pl/pdf/relacje-inwestorskie/principles-for-suppliers.pdf) By accepting them they confirm that: #### ■ comply with the law, ■ abide by employee rights. They take care of the health and safety of employees, do not profit from forced labour and child labour, #### ■ respect human rights and ensure workers' freedom of association in trade union organisations, #### ■ protect the environment. They comply with environmental legislation and take measures to minimise their negative impact on the environment, #### ■ do not discriminate against any person on the basis of their distinguishing characteristics, #### ■ comply with anti-corruption laws. They also ensure that there are no conflicts of interest in their activities. During the procurement process, the supplier, acting on its own behalf and for its subcontractors, undertakes to comply with the guidelines defined in: #### ■ the Universal Declaration of Human Rights, ■ the Standards of the International Labour Organisation, ■ the Guidelines of the OECD (especially on the fight against corruption), ■ Agenda 21 adopted at the UN Conference on Environment and Development in Rio de Janeiro in 1992, #### ■ the United Nations Convention against Corruption, ■ international trade sanctions and UN and EU embargoes, ■ Polish legislation that transposes these guidelines into national law, ■ provisions of mBank's rules and regulations, in particular on conflicts of interest. Sustainability code for mBank suppliers and partners [In addition to the Rules for Suppliers, we also apply the Sustainable Development](https://www.mbank.pl/pdf/CSR/mbank_kodeks-dostawcow_2021_en_.pdf) [Code for Suppliers and Partners of mBank. It describes the specific ESG](https://www.mbank.pl/pdf/CSR/mbank_kodeks-dostawcow_2021_en_.pdf) requirements. [...] The code presents rules with which we ourselves comply. We expect the same from our suppliers and partners. We want to build relationships with them based on mutual trust. This means that: #### ■ we prioritise openness in cooperation and contacts, ■ we respect agreements and obligations, ■ we share information which will help our suppliers and partners develop sustainably.

2.1.4. The mBank S.A. Group Green Bond Framework includes a process for project evaluation and selection in which its Sustainable Finance Committee is responsible for selecting and managing eligible green buildings, wind energy and solar energy projects. [...] 4.1.3. The mBank S.A. Group Green Bond Framework provides detail on its decision-making process, which is overseen by the Sustainable Finance Committee. The committee will strive to ensure that the allocation of proceeds into the eligible assets pool matches or exceeds the total proceeds raised from the bond. mBank will monitor the use of net proceeds with its internal systems.

At mBank, we believe that sustainability is our collective responsibility, embraced not just by the Supervisory Board and Management Board, but by every employee of our organisation. We recognise that the role of leadership is to support this commitment and to build an organisation fully equipped to achieve our goals. In 2023, we took significant steps to accomplish this mission. Sustainable development and progress in strategy implementation are regular items on the agenda of meetings of the Supervisory Board and its commissions. The implementation of the ESG programme at mBank is the responsibility of the Management Board and its Sustainability Committee. Additionally, the Supervisory Board and Management Board members undergo targeted training on key topics, such as the Corporate Sustainability Reporting Directive (CSRD). These actions underscore our dedication to making sustainability a core aspect of our operations and culture. [...] The implementation of the ESG strategy is overseen by the Sustainable Development Committee of the mBank S.A. Group, which is responsible for making decisions and formulating recommendations, and conducts a dialogue on sustainable development between the bank's organisational units and between the bank and Group companies. The Committee's decisions and recommendations support the consistent approach of other Group bodies to sustainable development. In addition, the Committee coordinates the alignment of the Group with regulatory and market requirements for ESG. [...] As part of these activities, the Committee: identifies the main lines of action and organises the ESG management system, sets the bank's ESG framework – policies and procedures, supervises the Group's ESG management system, defines the structure and organises the process of managing proceeds from the issue of 'green' debt instruments, in 2023, the Committee was chaired by the Vice-President of the Management Board, Chief Risk Officer (CRO), and it is composed of representatives of all mBank divisions and Group companies. In November 2023, its composition was extended to include the Vice-President of the Management Board, Chief People & Regulatory Officer, the Vice-President of the Management Board, Chief Financial Officer (CFO), and the Vice-President of the Management Board, Head of Corporate and Investment Banking. In 2023, four meetings of the Committee were held. In 2024, Julia Nusser, Vice-President of the Management Board, Chief People & Regulatory Officer, became the Committee's Chairwoman.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]We have enstablished an ESG management system, with key decisions being made by relevant bodies, such as Sustainable Development Committee of mBank Group or our Management Board. This covers key ESG partnerships, including those which may have infuence on public policy. On operational level, our collaboration through these partnerships is coordinated by mBank's ESG team, which is at the same time responsible for effecting out ESG strategy, incl. in terms of our net-zero targets.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]No, and we do not plan to have one in the next two years

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]We have established an ESG management system, with key decisions being made by relevant bodies, such as Sustainable Development Committee of mBank Group or our Management Board. This covers key ESG partnerships, including those which may have influence on public policy. On operational level, our collaboration through these partnerships is coordinated by mBank's ESG team, which is at the same time responsible for effecting out ESG strategy, incl. in terms of our net-zero targets.