Management of own workforce

The purpose of the Human capital management policy is to ensure consistent and integrated principles governing HR processes across the entire PZU Group, based on the assumption that the organization’s key resource consists of employees and collaborators building the PZU Group’s human capital. The policy constitutes a management framework for activities related to employment, competence development, talent retention, and shaping the organizational culture.

The Human capital management policy applies to employees employed under an employment contract, while cooperation with persons providing services under civil law contracts and managerial contracts is regulated separately in the agreements concluded with them. All relationships within the PZU Group, regardless of the basis of employment, are carried out with respect for human rights and the principles set out in the Human Rights Policy of the PZU Group.

The Human capital management policy takes into account legal conditions, business realities, and organizational diversity within the PZU Group, while ensuring respect for employees’ dignity.

Main objectives of the Human capital management policy:

• supporting the implementation of the PZU Group’s strategy through proper management of human capital;
• ensuring consistency of HR principles across the entire PZU Group;
• building an organizational culture based on values, employee well-being, and engagement;
• developing competencies and leadership at every level of the organization;
• ensuring equal treatment and a work environment free from discrimination and mobbing;
• attracting, developing, and retaining talent by building the image of an employer of choice and offering attractive development and internship programs;
• ensuring transparency of remuneration processes, consistent job evaluation principles, and market benchmarks;
• motivating the achievement of strategic objectives, efficiency, and continuous improvement;
• ensuring succession of competencies key to the organization;
• standardizing HR processes and metrics within the PZU Group.

Principles of human capital management in the PZU Group:

• HR operates based on the PZU Group’s values, placing people and their development at the center;
• workplace relationships are based on respect, trust, and social dialogue;
• equal treatment is ensured, along with equal access to development and promotion and the right to equal pay for equal work;
• HR processes are conducted transparently and in compliance with applicable regulations; the work environment is inclusive and conducive to engagement and building positive employee experiences.

Implementation mechanisms:

• work regulations and remote work regulations;
• recruitment procedure;
• organizational principles;
• financial planning and training organization procedures;
• HR systems for conducting and monitoring recruitment, promotions, and training.

The substantive owner of the Human capital management policy is the PZU HR Office. The PZU Management Board oversees its implementation.

The implementation of the Human capital management policy is monitored through engagement surveys, audits of HR procedures, and the analysis of employment and turnover metrics. The Human capital management policy refers to identified impacts, opportunities, and risks, in particular the risk of competence shortages, the high level of workforce diversity, and the opportunity related to development within the PZU Group.

The Human capital management policy is an internal document available to the PZU Group companies implementing its provisions and to persons involved in HR processes.

The Human capital management policy was updated in the reporting year. The Human capital management policy strengthens mechanisms related to equality and diversity, clarifies the division of HR responsibilities within the PZU Group, streamlines cooperation and reporting processes, and further develops areas related to organizational culture, succession, and pay transparency. The changes to the Human capital management policy include, in particular:

• the expansion and clarification of provisions concerning equal opportunities and diversity.

Access to development for all employees was emphasized, highlighting gender balance, the prevention of discrimination, and the inclusion of new provisions on pay equality and transparency of remuneration principles;

• the strengthening of elements related to organizational culture and leadership.

Provisions concerning the building of a people-centered culture, mentoring, talent succession, and leadership development at all levels of the organization were updated;

• the clarification of rules governing cooperation and reporting between the PZU Group companies.

Rules were defined for sharing documents, consulting HR decisions, and issuing opinions on HR matters. The objective of these changes is to increase the consistency and transparency of oversight of HR practices;

• the reorganization of the document structure and definitions.

Clear definitions of key concepts were introduced, increasing the clarity of the provisions and facilitating consistent interpretation of the Human capital management policy across the PZU Group.

Two complementary policies concerning the composition of the Management and Supervisory Boards are in place at PZU:

• the Diversity policy for members of bodies of PZU SA (Diversity Policy) and
• the Gender balance policy in the Management and Supervisory Boards of PZU SA (Gender Balance Policy).

The Diversity Policy was formally adopted by the General Meeting of PZU in 2022.

The Gender Balance Policy was adopted by the General Meeting of PZU on 25 June 2025, and has been effective since that date.

The first policy focuses on ensuring diversity of competencies among persons serving on the governing bodies of PZU. The second aims to ensure gender balance in the composition of these bodies and to promote the professional development of women and men, thereby supporting an increase in the representation of the underrepresented gender.

The regulatory scope of the policies covers:

• members of the Management Board and Supervisory Board of PZU;
• rules governing nomination, appointment, succession, and competence development;
• qualification criteria and the obligation to take diversity into account in personnel decisions;
• measures promoting gender balance and access to managerial positions.

Main principles arising from both policies:

• taking into account competence, knowledge and experience when selecting candidates;
• striving for diversity in the composition of the management and supervisory bodies;
• establishing gender ratios in accordance with legal requirements;
• promoting equal access to nomination processes and managerial positions;
• supporting the development of competencies of women and men;
• applying succession procedures and mentoring mechanisms.

Implementation and oversight:

Both policies form part of PZU’s corporate governance framework and address legal requirements as well as risks related to the lack of gender balance in management and supervisory bodies. The Supervisory Board and Management Board supervise their implementation and regularly monitor the composition of the bodies. As part of its reporting, the company analyzes the extent to which policies are implemented, including the share of the underrepresented gender and the level of competency diversity.

The policy documents are publicly available on PZU’s website, ensuring transparency with respect to the applicable corporate governance principles.

Within the Pekao Group, a Gender Equality and Diversity Policy is in place with respect to the Bank’s employees, including Supervisory Board Members, Management Board Members and Key Officers at Bank Polska Kasa Opieki Spółka Akcyjna. Within Alior Bank, these matters are governed by policies concerning the selection and assessment of the responsibilities of members of the Management Board and the Supervisory Board.

The procedure defines key concepts such as mobbing and discrimination and states that PZU does not tolerate any forms of such behavior in employment – whether in the establishment or termination of the employment relationship, employment conditions, promotions, or access to training. The procedure provides protection against unequal treatment on the grounds of gender, age, disability, race, religion, nationality, political beliefs, trade union membership, ethnic origin, faith, sexual orientation, type of contract (fixed-term or indefinite-term), or working time arrangement. The procedure applies to all employees, including particularly vulnerable groups.

Main principles:

• prohibition of all forms of mobbing and discrimination (direct and indirect);
• equal treatment in employment, promotions, remuneration and access to training;
• confidentiality and protection of whistleblowers.

In the other PZU Group companies, separate procedures of the same type are in place, adapted to the specific characteristics of each employer, but with analogous content and structure.

Implementation mechanisms:

• reporting channels (dedicated email address, written submissions);
• the establishment of an Anti-Mobbing and AntiDiscrimination Committee to examine reports. In the event of a report, a committee is appointed to analyze the case, conduct evidentiary proceedings, and make decisions by a majority vote. The Committee examines reports on a confidential basis;
• remedial measures: mediation, training, disciplinary sanctions.

The HR Office is responsible for handling reports. The Anti-Mobbing Committee is responsible for analyzing reports and making decisions.

Monitoring

Registers of reports are maintained within the PZU Group, and reports are prepared following each assessment. These reports contain a summary of the identified issues and a remedial action plan, taking into account the following principles:

• assessments and remedial actions are carried out with the involvement of the responsible units and functions and include an appropriate budget for their implementation;
• remedial measures must adequately address the identified irregularities, in line with the priorities established by the relevant PZU Group company.

These reports are internal in nature and are submitted to the Management Board after each assessment.

The procedure is linked to mandatory anti-mobbing training for all employees, delivered periodically through the internal training portal.

The procedure is available to all employees on the intranet, and information about updates is communicated through internal announcements.

Complaint procedures have been implemented to address cases of discrimination and mobbing, taking into account both formal structures and informal cultural barriers. The mechanisms ensure confidentiality and protection against retaliation.

Within the PZU Group, implemented policies and procedures ensure that recruitment, training, and promotion are based on qualifications, skills, and experience. The processes are transparent and monitored in HR systems. The PZU Group assesses whether job-related requirements have been defined in a way that could systematically place certain groups at a disadvantage. Recruitment processes are reviewed for inclusiveness.

The PZU Group maintains up-to-date documentation concerning recruitment, training, and promotion, ensuring a transparent overview of employees’ development and promotion opportunities.

The PZU Group has the Human Rights Policy in the PZU Group, aimed at effectively protecting human rights and creating an organization that supports diversity. The document covers principles of equal treatment and antidiscrimination measures in relations with employees, clients, suppliers and other stakeholders. The policy mandates the provision of fair wages, ergonomic working conditions, privacy protection and freedom of expression. It also includes support for employee health and well-being.

The Human Rights Policy in the PZU Group is addressed to all interested parties including employees, job candidates, customers, suppliers and business partners of the PZU Group. In its content, the PZU Group refers to the principles of equal treatment and respect for human rights in accordance with international standards and labor law regulations. The document has been published on the PZU Group’s website, ensuring access for all interested parties.

The Human Rights Policy in the PZU Group aims to ensure the effective protection of human rights and to create an organization that supports diversity. The PZU Group is committed to respecting human rights in its business operations, particularly in employee relations.

Main principles:

• respecting the right of candidates to equal treatment and non-discrimination during recruitment;
• ensuring employees’ right to fair and equal remuneration;
• providing safe and ergonomic working conditions;
• respecting employees’ right to association;
• protecting the right to privacy, as well as freedom of speech and expression;
• creating conditions that enable work-life balance;
• supporting employees in health protection and workplace well-being;
• preventing discrimination and mobbing in accordance with labor law and internal regulations;
• striving to ensure compliance with human rights by employees, suppliers and business partners.

The Human Rights Policy in the PZU Group applies to all entities within the PZU Group, except for Alior Group and Pekao Group, which have their own human rights policies. For the Pekao Group, the key regulation regarding human rights is the Pekao Group Code of Conduct, which, in addition to human rights, also addresses organizational culture and the value system. For Alior Bank Group, the key regulation governing human rights is Alior Bank Human rights policy.

Implementation mechanisms

The Human Rights Policy is implemented through the Procedure for Addressing Human Rights Violations in the PZU Group. The procedure defines the principles and methods of action to prevent human rights violations within PZU and its subsidiaries.

The Human Rights Policy of the PZU Group explicitly refers to the prohibition of human trafficking, forced labor, and child labor. The PZU Group applies a zerotolerance principle toward such practices, and the risk of their occurrence is considered minimal.

The PZU Group maintains a zero-tolerance policy toward any actions or behaviors that violate human rights. If a violation is identified, any stakeholder who believes that their rights or the rights of others have been violated by PZU or its subsidiaries has the right to report the case to the Client Ombudsman. Reports can be submitted electronically to rzecznikklienta@pzu.pl or in writing to the PZU headquarters address.

Both the Human Rights Policy and the procedures of the PZU Group relating to human rights in respect of its own workforce also apply to complaints or incidents involving human rights violations reported by persons who are not employees of the PZU Group.

Entities covered: All PZU Group entities except Pekao and Alior Bank Groups, which have their own internal procedures in this area.