I. GENERAL PROVISIONS

 § 1.

The principles of the disclosure policy, hereinafter called the “Principles”, concern the communication of PKO Bank Hipoteczny S.A. (the “Bank”) with investors, customers and the media, in particular they define the scope and manner of communication, including communication channels and disclosure-related powers.

II. DEFINITIONS

  § 2.

The terms used herein shall have the following meaning:

  1.  investor – an entity taking up, purchasing, as well as interested in taking up or purchasing, on the primary or secondary market, securities issued by the Bank;
  2. customer – the person referred to in Article 221 of the Act of 23 April 1964 – the Civil Code, which uses or has used the Bank’s products or interested in purchasing such products;
  3. media – institutions and companies disseminating information to a mass audience, including: information agencies, newspaper publishers, radio and television stations, editorial offices of web portals, social media.
  4. current reports – information published by the Bank, drawn up in the form and scope defined in the Regulation on current and periodic information;
  5. periodic reports – information published by the Bank, drawn up in the form and scope defined in the Regulation on current and periodic information;
  6. Corporate Governance Principles – the document “Principles of Corporate Governance for Supervised Institutions” adopted by Resolution No. 2018/2014 of the Polish Financial Supervision Authority of 22 July 2014;
  7. Regulation on current and periodic information – the regulation of the Minister of Finance of 29 March 2018 on current and periodic information provided by issuers of securities and conditions for considering equivalent the information required under the legislation of a non-Member State;
  8. MAR – Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (market abuse regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC and technical standards;
  9. Act on trading in financial instruments – the Act of 29 July 2005 on trading in financial instruments, as amended;
  10. Act on Public Offering – the Act of 29 July 2005 on public offering and conditions governing the introduction of financial instruments to organized trading and on public companies, as amended;
  11. ESMA Guidelines – the Guidelines of the European Securities and Markets Authority relating to MAR;
  12. ESPI – Electronic Information Transfer System used for the publication of reports on confidential information, notifications of a delay in the disclosure of confidential information, as well as current and periodic reports by issuers on the WSE Main Market.
  13. Code of Ethics of PKO Bank Hipoteczny S.A. – PKO Bank Polski S.A. Group Company – the Code of Ethics is a set of the most important values, principles, standards of behaviour and ethical attitudes defining the ways of building mutual relations between the Bank’s employees and persons acting on its behalf, on the basis of a civil law contract or on the basis of another legal relationship. Adopted by Resolution No. 94/2021 of the Supervisory Board of PKO Bank Hipoteczny S.A. of 17 December 2021.

III. THE BANK’S COMMUNICATION WITH INVESTORS, CUSTOMERS AND THE MEDIA

 § 3.

 

  1. Disclosures made by the Bank to investors, customers and the media are an important element of a broadly understood outbound communication of the Bank.
  2. The task of the disclosure policy is to:
    a) ensure effective communication of the Bank with external recipients;
    b) develop desirable relations with investors, customers, as well as the media;
    c) provide equal access to information;
    d) provide information which is up-to-date, precise and comprehensible to the target recipient;
    e) build a positive image of the Bank as an honest and reliable institution.

 

  1. The principal objective of the Bank’s disclosure activities is to guarantee high standards of communication expressed through transparency, reliability and timeliness, with respect for the principles of equal access to information about the Bank for customers, investors and the media, without giving preference to any of them.

RESPONSIBILITY FOR THE PERFORMANCE OF DISCLOSURE ACTIVITIES TOWARDS INVESTORS

§ 4.

  1. The task of the Bank’s disclosure activities towards investors is to provide information about the Bank’s activities, especially in a manner which allows the Bank’s financial position to be assessed.
  2. The disclosure obligations of the Bank as an issuer of securities are discharged in accordance with the applicable laws, including, in particular:
    a) the Act on public offering;
    b) the Regulation on current and periodic information;
    c) the MAR;
    d) the ESMA Guidelines.
  3. The Bank’s disclosure activities also take into account the provisions of the Corporate Governance Principles and the Code of Ethics of PKO Bank Hipoteczny S.A.

§ 5.

Responsibility for the pursuit of the Bank’s disclosure policy towards investors lies with the Head of Treasury, and the Communication and IR Expert carries out the tasks laid down in this regulation.

COMMUNICATION WITH INVESTORS

§ 6.

  1. The Bank’s disclosure activities towards investors are carried out, in particular, through:
    a) the Bank’s website which contains an investor relations section;
    b) provision of information through the Electronic Information Transfer System of the Polish Financial Supervision Authority (ESPI);
    c) provision of information, explanations and comments on the Bank’s current operations, including its financial results and business activities;
    d) meetings of the Bank’s representatives with investors;
    e) answering questions asked in writing, by e-mail or by telephone.
  2. Periodic reports are published in accordance with the relevant laws, in accordance with the schedule in the current report available on the Bank’s website.
  3. Current reports are published immediately after the occurrence of the event resulting in a reporting obligation or as soon as it comes to the Bank’s attention, in recognition of the exceptions provided for in the applicable laws.
  4. Reports containing confidential information within the meaning of the MAR are published immediately after the occurrence of the event resulting in a reporting obligation, except for situations in which, under the legal regulations, information about the event is provided at a date later than the occurrence of the event.

 § 7.

  1. The Bank’s investor relations webpage is available at pkobh.pl/relacje-inwestorskie/ [www.pkobh.pl/en/investor-relations/]
  2. The Bank’s investor relations webpage contains basic information about the Bank, including, in particular, the Bank’s corporate documents, as well as financial statements. The investor relations webpage is updated immediately and regularly in connection with the occurrence of the events affecting the contents or scope of published information and disclosure obligations.
  3. Investors may contact the Communication and IR Expert in the following manner:
    a) by sending an e-mail to the address provided on the website: pko.bh@pkobh.pl;
    b) by telephone at: +48 721 200 079.
  1. The Communication and IR Expert answers investors’ questions, taking into account the restrictions on the scope and period of the information provided, arising from the applicable laws. Investors’ questions are answered as soon as they are received.

 § 8.

  1. In conducting disclosure activities aimed at investors, the Bank provides:
    a) reliable and transparent information about the Bank;
    b) equal access to information;
    c) data comparability – the Bank applies the provisions of International Financial Reporting Standards (IFRS) and the European Single Electronic Format (ESEF) in its reporting.

VII. COMMUNICATION WITH CUSTOMERS

 § 9.

  1. Communication with customers concerns:
    a) informing customers of the Bank’s product mix;
    b)providing information about a customer’s products;
    c) providing answers and explanations to customers’ enquiries submitted in the form of requests, complaints and appeals.
  2. A customer may obtain information about the Bank’s product mix by calling the PKO Bank Polski S.A. call center, at PKO Bank Polski S.A. outlets and in the information available on the website of PKO Bank Hipoteczny: pkobh.pl/kredyty-hipoteczne_7/

 § 10.

As regards complaints, the aim of the disclosure policy is to provide public access to information about the rules for lodging and handling complaints and appeals, which is available on pkobh.pl/zglaszanie-reklamacji/.

VIII. COMMUNICATION WITH THE MEDIA

 § 11.

  1. The Bank follows a transparent and coherent disclosure policy towards the media.
  2. Responsibility for the pursuit of the disclosure policy regarding communication with the media lies with the Head of Treasury, and the Communication and IR Expert carries out the tasks laid down in this regulation.
  3. The basic principle for providing information to the media is to offer equal access to reliable and up-to-date information about the Bank.

§ 12.

  1. The following persons may speak on behalf of the Bank:
    a) Members of the Bank’s Management Board;
    b) representatives of the Supervisory Board;
    c) Head of Treasury;
    d) other employees of the Bank after gaining the consent of the Member of the Bank’s Management Board responsible for communication or the President of the Management Board.
  2. Information about the Bank may be provided to the media:
    a) by electronic mail;
    b) during face-to-face meetings;
    c) by telephone;
    d) through social media.
  3. Information about current events of importance to the Bank is provided to the media in the form of a press release sent by electronic mail to editorial offices dealing with topics related to the Bank’s activities, and published on the Bank’s website, in the “News” section.
  4. Press releases are published on the Bank’s website in Polish and in English.
  5. Media representatives may contact the Communication and IR Expert in the following manner:
    a) in writing – by sending an e-mail to: komunikacja@pkobh.pl;
    b)by telephone at: +48 721 200 079.
  6. Contact details for the media are placed on the website of the Press Center of the PKO Bank Polski S.A. Group at: https://media.pkobp.pl/69059-kontakt-dla-mediow
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