Supporting diversity and counteracting discrimination

[GRI 103-1], [GRI 103-2], [GRI 103-3] In accordance with the „Human Resources Policy” in force in the Bank Millennium Group the use of any discriminatory practices with features of mobbing or harassment in relation to employees is prohibited. The Bank Millennium Group operates while respecting human dignity, it adheres to the law on equal treatment regardless of age, gender, ethnic or national origin, religion, creed, family status, sexual orientation, health condition, convictions, trade union membership and other premises that could trigger discrimination. The Bank has “Diversity Policy” and is a signatory to the Diversity Charter, which is a pledge signed by organizations that choose to prohibit discrimination in the workplace and work to create and promote diversity.

Issues of respecting diversity in the Bank’s Group are also governed by the “Code of Ethics”, the “Work Rules and Regulations” and regulations pertaining to recruitment. The result of implementing these policies is a series of measures. All employees go through mandatory training on ethical issues. In addition, the management is trained on combating mobbing and discrimination in employment. The Bank has anti-mobbing and anti-discriminatory procedures. Employees may report abuse anonymously to the stated email address.

• During employee recruitment, criteria putting one in jeopardy of discriminatory behaviour are not applied. These rules also apply to the termination of employment, terms of employment, promotions and access to training to raise professional qualification. Candidates are selected based on objective criteria, such as in particular: education, professional experience, general and specific competences, proficiency in foreign languages and the overall match with the profile.
• The Bank analyzes on an ongoing basis the compensation structure and equality of earnings and jobs by gender, age and nationality. Interviews are held from time to time with persons leaving the Bank to grasp the reasons for them to leave.
• Extensive communication and support are addressed to employees who are parents. The Bank advises them of their parental rights. People with small children may take advantage of forms of recreation co-financed by the Bank under the Yes to Parenting program.
• Benefits such as medical care, group insurance, co-financing for sport and recreation are offered to all employees, also part-time employees.
• The Bank encourages employees to take their holiday leaves.

• The Bank lends a helping hand to people in a challenging financial and health-related situation through the existing social assistance system predicated on the Company Social Benefits Fund.
• People with disabilities may take advantage of office infrastructure that is aligned to their capabilities.

• The Bank runs management training whose aim is to strengthen appropriate attitudes, including also to overcome stereotypes and promote openness to employees’ various convictions and mould their own responsibility and that of their reports.
• Employees may freely express their views on an internal internet forums.

The HR Department keeps a register in which all employee claims are recorded. They are reported to the Process and Operational Risk Committee. A notification is examined using a procedure, which involves, among others: collecting documentation to review the claim, conducting a survey among employees, making a decision to accept or reject the claim and issuing a response to the employee.

[GRI 406-1] Two notifications pertaining to actions involving mobbing were recorded in 2021. In each case, anti-mobbing surveys were carried out and conversations held with managers of teams and units. In neither of these cases was bullying confirmed, but nevertheless the managers were instructed on the absolute necessity to ensure that the relationships between team members comply with the rules of social coexistence.

The coronavirus pandemic has not blocked a grass-roots initiative 3xM(ille) – implemented for women, at work and after work. In 2021, activities were developed through creating a culture of diversity and innovation and conducting an effective and engaging communication.

The cooperation with Vital Voices Poland in the project for young women aged 16-19 #I am a Leader has been successfully finalized in the form of external mentoring of female leaders from the organization and the implementation of a social project with the mentee.

In addition, several important concepts were implemented, including the launch of a social breast cancer prevention campaign, „3xM(ille)j bez raka” („3xM(ille)j without cancer”).

In accordance with the Human Resource Policy in force in Bank Millennium, the Bank incorporates information in the compensation policy concerning the market levels of compensation for similar positions. Employee compensation is periodically checked on the basis of the Bank’s current strategy, market data, job performance assessments and employee career stages. The Bank strives to devise bonus schemes in which the incentive is linked to the nature of the work in a given unit – by formulating reasonable and fair ratios describing job performance and the appropriate incentive systems for a given unit in the Bank.

[GRI 405-2] Ratio of women’s base compensation to men’s*

[GRI 405-2] Ratio of women’s overall compensation to men’s*

The difference in the average salary of men and women does not include the differences in geographic location, scope of duties and headcount structure of men and women in various positions in different areas of the Bank. It should be emphasized that the last factor in particular is of major significance for the shaping of the average employee compensation. Most women are hired in the sales network, while men work chiefly in high technology areas, where the market, due to a shortage of specialists, dictates significantly higher levels of remuneration. The Bank reviews in detail all factors that may contribute to the differences in employee compensation between men and women.