Scope of Taxonomy disclosure

Regulation (EU) 2020/852 of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment (EU Taxonomy) lays down a unified classification system for sustainable activities designed to increase the transparency and comparability across the market and support investors in taking investment decisions. This Regulation – along with supplementing Commission Delegated Regulation (EU) 2021/2178 (as amended) specifying the content, methodology and presentation of information concerning environmentally sustainable activities – imposed additional reporting obligations on undertakings required to provide non-financial disclosures in accordance with the Non-Financial Reporting Directive (undertakings subject to NFRD). In the case of Santander Bank Polska S.A. and other credit institutions, the foregoing legislation became fully effective in 2024 (except for two forms applicable as of 2026) following the two-year transition period from 1 January 2022 to 31 December 2023, during which the disclosures were limited and focused on the eligibility of activities. In view of the above and in accordance with the interpretation of Commission Delegated Regulation (EU) 2021/2178 on Taxonomy disclosures presented in Commission Notice (C/2023/305), Santander Bank Polska Group is not required to disclose the comparative key performance indicators for 2022 in its Taxonomy reporting for 2023.

The Taxonomy covers six environmental objectives: climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution prevention, and the protection and restoration of marine and terrestrial ecosystems.

As part of GAR reporting for 2023, Santander Bank Polska Group conducted a complete Taxonomy analysis (at the level of a single transaction) with regard to two climate objectives defined in Commission Delegated Regulation (EU) 2021/2139: climate change mitigation and climate change adaptation. The results are presented in the tables included in section: “Templates presenting GAR calculation”.

Activities indicated as contributing substantially to other four climate objectives, as specified in Commission Delegated Regulation (EU) 2023/2486, have been assessed only in terms of Taxonomy eligibility based on customers’ business codes in the NACE system. They are presented at an aggregate level in the table below “Eligibility of exposures with regard to four environmental objectives”.

The transactions identified are related to the circular economy objective. The transactions are presented according to the NACE sector classification up to level 2.

Transakcje
NACE	Eligible exposures with regard to four environmental objectives defined in Commission Delegated Regulation (EU) 2023/2486
B.07 Mining of metal ores	1,303,082.30
C.11 Manufacture of beverages	4,799.30
C 17 Manufacture of paper and paper products	320.20
C.19 Manufacture of coke and refined petroleum products	223,027.20
C.20 Manufacture of chemicals and chemical products	464,696.60
C.22 Manufacture of rubber and plastic products	1,934.80
C.27 Manufacture of electrical equipment	101.40
C.28 Manufacture of machinery and equipment n.e.c.	56,204.30
C.30 Manufacture of other transport equipment	18.50
D.35 Electricity, gas, steam and air conditioning supply	270,818.30
F.41 Building construction	46,118.80
F.42 Civil engineering	681.00
G.45 Wholesale and retail trade and repair of motor vehicles and motorcycles	257,592.00
G.46 Wholesale trade, except of motor vehicles and motorcycles	644,853.20
G.47 Retail trade, except of motor vehicles and motorcycles	858,830.10
J.58 Publishing activities	29,184.50
J.61 Telecommunications	283,990.40
J.62 Computer programming, consultancy and related activities	0.30
J.63 Information service activities	87,720.80
K.66 Activities auxiliary to financial services and insurance activities	189.70
L.68 Real estate activities	61,384.90
M.70 Activities of head offices; management consultancy activities	270,907.80
N.77 Rental and leasing activities	10,927.10
N.79 Travel agency, tour operator and other reservation service and related activities	0.20
N.82 Office administrative, office support and other business support activities	192,169.40
R.93 Sports activities and amusement and recreation activities	46,139.70
SUM	5,115,692.40

Pursuant to Commission Delegated Regulation (EU) 2022/1214 amending Delegated Regulation (EU) 2021/2139 as regards economic activities in certain energy sectors and Delegated Regulation (EU) 2021/2178 as regards specific public disclosures for those economic activities, the Group provides the following information on exposure to the financing of nuclear and fossil gas related activities.

Działalność związana z energią jądrową
Nuclear energy related activities
1	The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.	NO
2	The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.	NO
3	The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.	NO
Fossil gas related activities
4	The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.	NO
5	The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.	NO
6	The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.	NO

Key performance indicators for Taxonomy purposes

The key performance indicator for sustainable activities of credit institutions is the green asset ratio (GAR), which shows investments and exposures related to Taxonomy-aligned sustainable activities with regard to the environmental objectives as a proportion of the assets included in the GAR calculation.

The GAR numerator considers loans and advances, debt securities and equity instruments in the banking book in respect of undertakings subject to NFRD, loans secured by residential properties, building renovation loans and car loans for households, and loans for local governments. Assets included in the GAR denominator (covered assets) are total gross assets excluding exposures to central governments, exposures to central banks and the trading book. Below are the key performance indicators (KPIs) of Santander Bank Polska Group calculated with regard to two climate objectives by the ratio (turnover or CapEx) used to calculate the Taxonomy eligibility and Taxonomy alignment of general purpose exposures to customers subject to the NFRD. The GAR based on flow and KPIs for off-balance sheet exposures (financial guarantees and assets under management) are included as well. The KPIs are presented using the table contained in Annex VI to Commission Delegated Regulation (EU) 2023/2485 amending Delegated Regulation (EU) 2021/2139.

Summary of KPIs

Podsumowanie kluczowych wskaźników wyników
	Total environmentally sustainable assets (PLN k)	Total environment- ally sustainable assets (TURNOVER)	Total environment- ally sustainable assets (CAPEX)	KPI (TURNOVER)	KPI (CAPEX)	% coverage (over total assets)	% of assets excluded from the numerator of the GAR	% of assets excluded from the denominator of the GAR
Main KPI Green asset ratio (GAR) stock	Green asset ratio (GAR) stock	826,727.40	1,127,250.30	0.40%	0.50%	77.90%	7.10%	22.10%
	Financial guarantees	0.00	0.00	0.00%	0.00%	nie dotyczy	nie dotyczy	nie dotyczy
	Assets under management	128,785.40	128,785.40	9.60%	9.60%	nie dotyczy	nie dotyczy	nie dotyczy
	Total environmentally sustainable assets (PLN k)	Total environmentally sustainable assets (TURNOVER)	Total environmentally sustainable assets	KPI (TURNOVER)	KPI (CAPEX)	% coverage (over total assets)	% of assets excluded from the numerator of the GAR	% of assets excluded from the denominator of the GAR
Additional KPIs Green asset ratio (GAR) flow	Green asset ratio (GAR) flow	256,134.80	225,849.50	0.50%	0.60%	80.30%	0.90%	19.70%
	Financial guarantees	0.00	0.00	0.000%	0.00%	nie dotyczy	nie dotyczy	nie dotyczy
	Assets under management	120,210	120,210	19.20%	19.20%	nie dotyczy	nie dotyczy	nie dotyczy