Declaration of the ING Bank Śląski S.A. Group on Respect for Human Rights

Everyone has the right to be treated with dignity and equality and to have their fundamental rights protected. Governments have a duty to ensure that human rights are respected and enforced, yet, in line with international standards, business also has a significant role to play in this regard. At ING Bank Śląski S.A. Group, we regard respect for human rights as a fundamental, universal principle that is reflected in various aspects of our activities. Respect for people and their rights stems, among other things, from our values and behaviours, as defined in the Orange Code. As a bank and a large organisation, we feel a sense of responsibility for our relationships with employees, clients, social and business partners or vendors.

We are committed to respecting all human rights that are internationally recognised and applicable to our activities, in particular the principles and rights set out in the International Bill of Human Rights and the fundamental conventions identified in the ILO Declaration on Fundamental Principles and Rights at Work. The human rights norms and standards that guide our business activities and relationships with clients, employees, vendors and other stakeholder groups include the regulations indicated in Article 18 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (EU Taxonomy), namely:

• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct,
• UN Guiding Principles on Business and Human Rights.

At the Bank we apply the Principles of Corporate Governance for Supervised Institutions of the Polish Financial Supervision Authority of 22 July 2014. As a public trust institution, we act in accordance with the Bank‘s Anti-Bribery and Corruption Policy, in an honest and ethical manner, applying zero tolerance towards behaviour that violates ING Values and the Orange Code principles in all relationships and business dealings.

In the ING Bank Śląski S.A. Group we process personal data in accordance with the applicable data protection laws and regulations and we make every effort to ensure the security and protection of personal data during processing. Our business decisions are guided by a client focus, but our aim is to make decisions so as to balance the interests of all stakeholders, operating within international standards and best practice.

We are a member of the United Nations Global Compact, which carries out activities, among others, in the area of human rights. The directions of our commitment to sustainability are set by our strategy.

At ING, we understand that our activities have an impact on many stakeholder groups. To best understand the scale of our impact on human rights in the value chain, we conduct work to identify the most relevant areas of our impact. The drafting of this Declaration was preceded by activities carried out in cooperation with external experts in the area of human rights. We will continue to develop the human rights due diligence process (HRDD). As a first step, we carry out activities aimed at identifying and preventing or minimising the materialisation of salient human rights issues.

An analysis of the impact on human rights is an ongoing process. We will continue to monitor our impact on human rights and regularly review (at least annually) and update this Declaration as necessary. We will continue to work on identifying the risks and their possible – existing or potential – adverse impact on human rights, with which we may be involved either through our own activities or as a result of business relationships. At an international level, the ING Group regularly publishes reports on its impact on human rights. ING Bank Śląski was among the banks under consideration. Links to the reports in English are available here: Human rights | ING.

Below, we describe the actions taken regarding respect for human rights at different stages of our value chain.

Our organisational culture is based on clearly defined ethical principles, which we expect everyone working at ING to adhere to. In determining them, we followed the requirements specified by the Polish Financial Supervision Authority, the European Banking Authority, the Banking Code of Ethics, and the ING Group’s Global Code of Conduct. The human rights that we consider fundamental and universal for our employees include, in particular, the right to equal treatment and the enjoyment of fair and favourable working conditions, the right to health, the right to safe and healthy working conditions, the right to freedom of association, the right to collective bargaining and freedom from discrimination on the grounds of race, colour, gender, religion, political views and national and social origin. ING is in favour of eliminating all forms of forced and child labour both in its operations and in its value chain.

We provide a healthy and safe workplace where mutual respect is key and discrimination is not tolerated. We appreciate our employees and strive to be a good employer. We promote the personal and professional development of our employees by providing core and fringe benefits and development opportunities. We take numerous measures to promote diversity and equal opportunities. We are a signatory to the Diversity Charter. We are guided by the principles set out by ING’s Diversity Manifesto, which we adopted in 2016. We promote and foster diversity at all levels of the organisation. We strive to minimise the wage gap between men and women. We publish information on the level of the wage gap in our annual reports. We work closely with social partners in the form of the Staff Council and trade unions.

We make sure that our products and services are accessible to all clients. The financial health of our clients and social inclusion are very important to us. We protect our client data, provide accurate information about our products and adhere to best practice in marketing communications.

We educate, support and sensitise our staff to client groups at risk of exclusion, including people with disabilities and individual needs. Since 2015, we have continued to maintain the “MIGAM” sign language interpreter access service in all our branches and on the bank’s helpline. We are also adapting the Moje ING system for use by visually impaired people in accordance with Web Content Accessibility Guidelines 2.1 (WCAG 2.1). We support the remote contact of our clients through a helpline that operates 24/7, a modern chat, contact forms and social media.

ING Bank Śląski has a process for the implementation, modification, review and disposal of client products, the so-called PARP, or the Product Approval and Review Process. It serves to provide an appropriate oversight and risk management framework for the development of new products and the modification of the existing ones. According to the PARP Policy, each product should ensure that the interests, objectives and characteristics of clients have been taken into account to avoid potential client harm and to minimise conflicts of interest.

In our communication activities, we take care to ensure that the content is reliable, that the message is clear and understandable, that the language is simple and that comprehensive information about products or services is provided. We know that children are a special audience for our communications and services. To emphasise the compliance with and the importance attached to their rights, ING Bank Śląski and the ING for Children Foundation signed the Charter on Children’s Rights in Business.

We work with our vendors in accordance with business ethics and market best practice. At the same time, we carefully verify vendors, including in terms of social and environmental risks. The qualification of vendors to work with ING and their subsequent cyclical screening is an important element of vendor relationship management. This process mitigates the risk of working with vendors involved in undesirable activities, including in terms of human rights impact. An important aspect of starting a relationship with a vendor is an attitude that ensures compliance with the ING Bank Śląski S.A. Code of Conduct for Vendors. Each of our vendors pledges to comply with the standards contained in the Code. Vendors thus commit to respecting basic standards, including respect for human rights (e.g. prohibition of forced labour, child labour, discrimination). It is important for us to be able to document compliance with those standards. To this end, the Bank may approach vendors, requesting relevant supporting documents, or carry out inspections.

Environmental and social risks are an important factor in making decisions to establish relationships with clients and prospective clients, as well as in taking decisions to finance corporate clients. Our environmental, social and corporate governance risk regulations (“ESG Manual”) help us in the process.

The environmental and social risk assessment covers the client and the transaction. We make our assessment to the best of our knowledge. At the client level, we assess whether the business is conducted with respect for human rights, environmental principles and is not covered by exclusionary policies. At the transaction level, we assess whether it complies with the requirements of the detailed policies. Sector exclusion policy applies to corporate clients to whom credit and other banking products/services are offered. We do not establish relationships with clients whose core business is covered by ING Bank Śląski’s exclusion policy. Past relationships with this type of clients have been terminated or an exit path is agreed.

As part of our social risk management, we have a well-established exclusion policy. The areas affected by the full ban on funding are as follows:

• activities that have an adverse impact on the respect for and fulfilment of human rights, including in situations of forced labour, child labour, inadequate working conditions, use of violence,
• activities posing a risk to the health of workers and local communities, including contact with harmful chemical materials, transmission of animal diseases to humans, non-compliance with labour laws,
• production of and trade in controversial weapons (including: anti-personnel mines, cluster munitions, phosphorus bombs, depleted uranium munitions, nuclear, chemical, biological weapons),
• cultivation, processing, production and sale of tobacco and tobacco products and e-cigarettes (excluding companies trading in these products as long as this is not their core business),
• asbestos-related activities, fur farming.

In addition to mitigating the materialisation of key risks in the area of human rights, we want to actively engage with and fund projects that have a positive social impact. We are developing a sustainable finance offering aimed at all our client groups, educating our employees and setting targets for a positive impact on sustainability issues. We understand that a better environment means a better future for successive generations. After 2025, we will not finance clients whose business is directly dependent on thermal coal to the extent of more than 5 percent. Information on the direction of our efforts to reduce greenhouse gas emissions can be found here.

If a breach or risk of a human rights violation is identified, internal and external stakeholders can get in touch with us through whistleblowing channels. External stakeholders can report irregularities via the external reporting channel – more information about this channel can be found here.

Our whistleblower policy enables employees to safely and confidentially report any concerns should they arise. Each employee may report irregularities related to material breaches of labour standards, internal regulations, as well as ethical standards in the Bank’s business practices. This can be done through channels such as:

• whistle-blowing (electronic form on the Intranet site or submission by post),
• e-mail notification to the Mobbing-Discrimination mailbox,
• contact with the company’s trade union organisation, the Staff Council representatives or HR Business Partners.

The aforementioned channels are reviewed periodically to ensure that they are operated effectively, and improvements are made according to identified needs. The use of the above-mentioned channels does not exclude the use of other mechanisms generally available, including the judicial path.

We want to be an active moderator of the ecosystem and inspire discussion around the broader issues of corporate responsibility and sustainability, including respect for human rights. For years, we have been involved in initiatives for the benefit of various communities, and we also carry out a number of activities within the ING for Children Foundation and the ING Polish Art Foundation. We are not indifferent to difficult situations with a high social impact.

We are an active member of numerous trade associations and organisations. This allows us to share knowledge, identify what is important to us, co-create and participate in many relevant projects. We also organise round tables to foster the exchange of knowledge among representatives of different sectors on sustainability measures. Since 2022, we have been running the ING Grant Programme, targeting start-ups and young researchers. We hold two editions of the programme every year, with each edition allocating PLN 1 million for the best solutions to support sustainable development. In the fourth edition, completed in December 2023, we focused on social issues – looking for solutions to help ensure healthy living at any age. More about our ESG activities can be found here.

We want not only to avoid adverse impacts, but to make a real positive difference to the lives of all our stakeholders. We know that today’s decisions and actions determine what the world of tomorrow will look like and what reality the next generation will find – because the future is our shared responsibility.

This Declaration was developed by a working group representing various ING units. The Declaration was adopted by the President of the Management Board of ING Bank Śląski S.A. on 27 December 2023.

ING Bank Śląski S.A.