Processes for engaging with affected communities about impacts (S3‑2)

Communities that we affect through customers have limited options to contact us, like filing complaints, which is a result of banking secrecy, because banking law prohibits us to share information about our customers. As a general rule, communities are thus not aware of the business relationship between us and our customers who exert influence over these communities. When it comes to working with affected communities, we therefore focus on the requirements we set for our clients.

In the case of investment projects financed by the Bank, we oblige clients to consult with the local community and to share appropriate documentation available to the community in the local language and in a culturally appropriate way, revealing any potential adverse impacts of the project on the environment and community. Our clients consult with stakeholders and then incorporate the results of these consultations into their operations. The process takes place at an early stage of the project, before construction begins. For projects with a high potential risk of negative environmental or social impacts, we require the client to hire an independent, qualified consultant. Their task is to evaluate the public consultation process in terms of legal requirements, to ensure taking the results into account in the client’s further operations.

When we manage reputational risk, we monitor whether our clients’ actions are controversial, including community protests. Where this is the case, we check whether the client has fulfilled its public consultation obligations, whether it is implementing a policy or plan for communicating with stakeholders, and whether it is participating in meetings with local communities.

When defining the objectives of the Group’s social agenda, we address the needs of the community. We analyse them on the basis of publicly available analyses of social challenges and needs in Poland. We also carry out surveys commissioned by the Bank when we design specific social initiatives. We work with NGOs to determine both the directions of action and the optimal way to spend the funds. The objectives of activities related to employee volunteering are defined in cooperation with employees.

In 2024, we conducted opinion surveys on:

The implementation of processes is supervised by the managers of these units, who are either a department heads director or a member of the Management Board.