Governance

Our strategy

Our ambitions regarding the way we do business are set out in the Group’s strategy for 2024–2026, in particular in its ‘Total Responsibility’ pillar.

What we do

  • We fulfil our commitments to all stakeholders and communicate our plans and actions transparently.
  • Our compliance with regulatory requirements ensures safety and stability, thereby strengthening customer trust.
  • We engage in dialogue with regulators and industry organisations on new legislative directions that support sustainable transformation.

How we do it

  • We build trust among customers, employees, investors and regulators as a safe and reliable bank.
  • We develop our proactive approach to managing regulatory initiatives.
  • We strengthen our risk management culture by ensuring the effectiveness of our control system.
  • We communicate our actions, plans and aspirations in the ESG area.
  • We focus on sustainable profitability, which enables us to fund non-business activities.
  • We integrate the ESG data reporting process and support the adaptation of systems and processes to collecting ESG data.

Our policies

Policy Description of content / policy area
General Code of Conduct It sets out the ethical standards and rules of conduct that all Group employees should follow in their work. By setting a good example through our daily behaviour, we build an honest and ethical Group. The Code is our guide, which we need to follow as we strive for the growth and transformation of our business and society as a whole.
Respect and Dignity Policy This policy sets out the principles for preventing bullying, harassment and discrimination, and for promoting integrity, in order to ensure a safe and dignified working environment for all employees and other stakeholders.
Corporate Culture Policy This policy defines the organisational culture within our Capital Group. It sets out the values, behaviours, principles and standards of conduct that shape the way the Capital Group and its employees operate.
Conflict of Interest Policy It describes the process of identifying and managing conflicts of interest, particularly with regard to compliance with legal requirements.
Anti-Bribery and Anti-Corruption Policy (ABC Policy) This document is a key element of the anti-corruption standard across our entire Group. It sets out the minimum requirements for mitigating the risk of bribery and corruption associated with the activities of employees, third parties and in our interactions with clients. The policy refers to applicable regulations and confirms that the bank and the Group companies do not tolerate any breaches relating to bribery and corruption.
Whistleblowing Policy and Internal Reporting Procedure (Protection of Whistleblowers) These documents set out the principles and procedures for safe reporting of breaches of law, regulations or ethical standards within the organisation and ensure protection against retaliatory measures. The regulations define the procedure for reporting such information to appropriate bank units.
Supplier and Outsourcing Policy The policy sets out standards for supplier management, rules for entering into contracts with suppliers, guidelines for the ongoing monitoring of services, and periodic assessments of both suppliers and the services they provide. The policy also sets out the rules for the use of outsourcing. The rules lid down in the policy apply to all employees and organisational units that establish and maintain business relationships with suppliers.
Information Policy This document sets out communication principles to ensure equal access to transparent, precise, reliable and up-to-date information for all our stakeholders.
Procurement Policy This document sets out uniform standards of operation within the framework of procurement processes by introducing applicable regulations and procedures in this area.
ESG Code for Suppliers The Code is a set of minimum standards that we expect all our suppliers to adhere to. The standards defined in the document are based on legislation, international conventions, market standards and our internal policies.

Our objectives

Our key priority is to ensure compliance with the applicable laws and with standards of integrity and business ethics. We operate in the highly regulated banking sector and focus on maintaining full regulatory compliance and preventing breaches, which – given the control mechanisms in place – occur essentially on an incidental basis.

Our activities

We are implementing a range of initiatives that stem from our policies and are ongoing, meaning they will be continued and developed in the coming years.

The corporate behaviour model is an important element of our culture. A clearly defined and consistent system supports employees in effective communication, collaboration and the successful completion of tasks across the organisation. This strengthens an environment based on trust, responsibility and mutual respect. It also contributes to building a bank that is friendly and open to everyone.

The bank and its subsidiaries operate a whistleblowing system that enables internal and external stakeholders to report breaches and irregularities via designated communication channels.

We have introduced a comprehensive system for assessing suppliers’ ESG risks. It is a step towards the fuller integration of environmental, social and corporate governance criteria into the management of our relations with suppliers. Since 2025, the “ESG Code for Suppliers of Erste Bank Polska” has been in force, in which we set out our expectations of contractors regarding minimum standards in the areas of environmental protection, social responsibility and corporate governance.

When assessing suppliers before entering into cooperation with them, the bank verifies, among other things:

  • whether they diversify their sources of revenue and do not become dependent on the bank,
  • whether they hold relevant certifications, e.g. regarding environmental protection and labour relations,
  • whether they apply ESG principles, have codes of ethics, implement anti-corruption procedures and programmes, and publish reports,
  • whether they take an ethical approach to finances and pay employee contributions, taxes and liabilities to contractors.

Clear anti-corruption processes are in place at the bank and its subsidiaries. Investigation committees are appointed to examine cases involving corruption or bribery, and their composition ensures the objectivity and transparency of the proceedings. Members of such committees are selected in each case in a manner that eliminates potential conflicts of interest, allowing for a thorough and impartial analysis of reported cases. The committee’s work is conducted in accordance with the guidelines set out in the “Anti-Bribery and Anti-Corruption Policy (ABC Policy)” and other internal regulations. In this way we make sure that every report concerning corruption or bribery is handled fairly, with respect for the principles of confidentiality and professionalism, and that the recommended corrective measures are implemented in accordance with established standards.

We also conduct regular training on anti-bribery and anti-corruption, which is mandatory for all Group employees (including members of the Management Board and Supervisory Board).

We present the bank’s current ESG ratings, which help investors better understand how we manage risks and build long-term stability and value.

ESG Risk Assessment
Morningstar Sustainalytics:

Low risk

(July 2025)

 MSCI’s
ESG Rating:

AAA

(March 2026)

 

Responsible Business Forum (FOB)

FOB is the longest-running (since 2000) and largest non-governmental organisation in Poland dedicated to the concept of sustainable development in a comprehensive manner. The Forum is an expert organisation, an initiator and partner of key ESG initiatives in Poland. One of FOB’s flagship initiatives is the Partnership Programme, bringing together nearly 100 companies, industry leaders who, through collaboration with a group of experts, enhance their ESG capabilities and undertake joint actions to support sustainable business transformation.

International cooperation plays a significant role in FOB’s activities. Since 2002, the organisation has been a national partner of CSR Europe; since 2009, it has collaborated with the World Business Council for Sustainable Development (WBCSD); and since 2025, it has been a member of the prestigious ‘Friends of EFRAG’ group. FOB organises the Chapter Zero Poland programme, the Polish branch of the Chapter Zero Alliance, established by the World Economic Forum.

FOB coordinates the Diversity Charter in Poland, an international initiative under the patronage of the European Commission. The bank is a member of the Partnership Programme and a signatory to the Diversity Charter

Sustainable Investment Forum Poland

POLSIF’s mission is to develop and promote the Polish and European sustainable investment and finance markets by establishing and disseminating best practices. The association creates an industry platform for cooperation between investors and financial market entities, both domestic and international. It supports the growth and transformation of the Polish and European economies, particularly the financial market. It promotes knowledge and conducts research and analysis in the field of sustainable finance and ESG. It helps to understand legal regulations and coordinate them with national and European public administration.

Scope of activities:

  • Creating a platform for the exchange of knowledge and experience
  • Developing standards and best practices
  • Preparing analyses and reports
  • Conducting educational activities
  • Representing the industry
  • Initiating international cooperation

Together for the Environment

This partnership for the implementation of the environmental Sustainable Development Goals has been established by the UNEP/GRID Centre in response to the need to create a climate-friendly environment in Poland and the best possible conditions for the implementation of the Sustainable Development Goals, particularly those relating to environmental issues. Its aim is to pursue sustainable development through multi-stakeholder cooperation – across sectors and industries – based on the principle of environmental responsibility. The partnership brings together companies, business associations and chambers of commerce, scientific institutions, public administration bodies, non-governmental organisations and individuals. It serves as a platform for the exchange of ideas, experiences and best practices, as well as for broad cooperation towards the achievement of the SDGs.

Business Accessibility Forum (BAF)

The Business Accessibility Forum is a platform bringing together organisations focused on increasing the accessibility of goods and services for all internet users. BAF’s mission is to create a space dedicated to Polish business for mutual learning about accessibility, so as to better fulfil the UN Convention’s message that accessibility is a human right to barrier-free access. The bank is a Founding Member of the Forum.

UN Global Compact Network Poland

It serves as the national office and local contact and information point for Polish members of the United Nations Global Compact. The organisation also acts as a local hub for Polish UNGC members and runs local programmes and activities.

The mission of the United Nations Global Compact is to mobilise a global movement of sustainable businesses and stakeholders to create the safe, just and people-centred world we all aspire to. The bank is a member of two programmes:

  • Business & Human Rights Programme which supports companies in implementing the UN Guiding Principles on Business and Human Rights and applying them in practice
  • Climate Positive Programme which provides practical solutions tailored to the Polish reality. It supports companies in achieving climate neutrality, meeting new non-financial reporting requirements and maintaining a competitive edge.

Partnership for the Sustainable Development Goals (SDGs)

Since 2017, we have been a member of the Partnership for the Sustainable Development Goals (SDGs). This partnership between the Ministry of Entrepreneurship and Technology and representatives of the business sector aims to create synergies in the actions undertaken in Poland to implement the recommendations of the 2030 Agenda and achieve the Sustainable Development Goals set out therein.

More information about what we do

 

News

Selected results for 2025

  • 143
    Total number of reports submitted via whistleblowing channels
  • 10.15days
    Average invoice payment time
  • 99.40%
    Employees who had completed anti-corruption training by the end of the year

For more information, see our 2025 Sustainability Statement.

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