Ethics

This document expresses what we are striving towards, to be a respected European Bank with global reach, and what should be remembered by every employee of the BNP Paribas Group. Together we focus on building the Bank on the foundations of professionalism and integrity. In order to achieve this, our employees – in accordance with the provisions of the Code of Conduct – must comply with laws and regulations relating in particular to: protecting the interests of Clients, preventing money laundering and terrorist financing, counteracting corruption, avoiding and managing conflicts of interest, preventing market abuse, preventing all forms of discrimination, protecting the environment and counteracting climate change, and acting responsibly in public life.

Important documents regulating ethical issues at BNP Paribas Bank include:

• Regulations on conflict of interest management at BNP Paribas Bank Polska S.A.,
• Policy on reporting violations of law as well as procedures and ethical standards applicable at BNP Paribas Bank Polska S.A., including anonymous reporting (Whistleblowing),
• Rules of accepting and giving presents by Employees of BNP Paribas Bank Polska S.A.,

• Regulations for the protection of the flow of confidential information at BNP Paribas Bank Polska S.A.,
• Regulations for investing by related persons and executing transactions by managers.

Every employee receives mandatory training in the principles of the Code of Conduct. Training helps employees to familiarise themselves with the document and to understand the priorities discussed in the Code of Conduct. The employees' awareness of the binding attitudes is also systematically increased through ongoing internal communication.

BNP Paribas Bank Polska S.A. actively engages in industry initiatives for business ethics. For more information on this topic, please refer to Economic responsibility chapter.

The detailed rules of conduct that all Bank employees are expected to understand and comply with are in the following regulations accompanying the Code of Conduct:

• Regulations on Conflict of Interest,
• Policy on reporting violations of law as well as procedures and ethical standards applicable at BNP Paribas Bank Polska S.A., including anonymous reporting (Whistleblowing),

• Anti-Corruption Policy,
• Anti-Fraud Policy.

The system launched at the Bank is an expression of concern for employees and monitoring of compliance with the law. It defines communication channels, dedicated tools through which potential violations can be reported to members of the Management Board and other employees. It has been communicated to all employees.

The Bank is particularly concerned about the anonymity of reports and to this end provides:

• absolute protection of the identity of the reporting person and the reported person; their details may not be disclosed to third parties unless there is a legal obligation to do so;

• treating reports with the utmost seriousness, fairness and discretion;

• verification of the reports by authorised personnel so that concerns can be resolved fairly and impartially.

In addition to the standard communication channels, direct communication with the dedicated Compliance unit (Group Financial Security US) can be used for incident reports regarding sanctions and embargoes.