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Consolidated financial statements

of the Bank Gospodarstwa Krajowego Group

prepared in accordance with IFRS

for the financial year from

1 January to 31 December 2020

The above consolidated financial statements of the Bank Gospodarstwa Krajowego Group

is a translation from the original Polish version. In case of any discrepancies

between the Polish and English version, the Polish version shall prevail.

Warsaw, 15 April 2021

Selected financial data on consolidated financial statements

The selected financial data specified below constitutes additional information to the consolidated financial statements of the BGK Group for 2020.

	in PLN thousand		in EUR thousand
	For the period from 1 Jan 2020 to 31 Dec 2020	For the period from 1 Jan 2019 to 31 Dec 2019	For the period from 1 Jan 2020 to 31 Dec 2020	For the period from 1 Jan 2019 to 31 Dec 2019
Net interest income	951,150	953,412	212,585	221,631
Net fee and commission income	248,031	218,597	55,436	50,815
Operating result	471,952	727,819	105,483	169,189
Profit before tax	446,984	459,197	99,903	106,745
Net profit	366,570	390,207	81,930	90,708
Net profit attributable to the owner of the parent entity	367,297	390,132	82,092	90,690
Net comprehensive income	324,321	284,562	72,487	66,150
Cash flows from operating activities	11,281,311	4,099,512	2,521,414	952,976
Cash flows from investing activities	-931,117	-265,530	-208,108	-61,725
Cash flows from financing activities	-2,510,314	1,192,487	-561,064	277,207
Net cash flows	7,839,880	5,026,469	1,752,242	1,168,457

	in PLN thousand		in EUR thousand
	As at 31 Dec 2020	As at 31 Dec 2019	As at 31 Dec 2020	As at 31 Dec 2019
Balance sheet total	160,325,539	100,521,240	34,741,601	23,604,847
Total equity	23,923,971	18,653,917	5,184,184	4,380,396
Equity attributable to the parent entity	23,900,269	18,639,365	5,179,048	4,376,979
Total capital ratio excluding flow funds	33.06%	28.71%	33.06%	28.71%
Total capital ratio including flow funds	33.04%	27.54%	33.04%	27.54%
Basic funds (Tier 1 capital)	23,460,630	17,869,910	5,083,780	4,196,292
Supplementary funds (Tier 2 capital)	0	0	0	0
Selected financial data on the consolidated financial statements was translated to EUR in line with the following rates:
			31 Dec 2020	31 Dec 2019
§ items from the statement of profit or loss, statement of comprehensive income, and statement of cash flows at the mid-exchange rate quoted by the National Bank of Poland (NBP) calculated as an arithmetic mean of the exchange rates applicable on the last day of each month in a given period			4.4742	4.3018
§ items from the statement of financial position at the mid-exchange rate quoted by the NBP for the last day of the period			4.6148	4.2585

Table of contents

Selected financial data on consolidated financial statements. 2

Consolidated statement of profit or loss. 4

Consolidated statement of comprehensive income. 4

Consolidated statement of financial position.. 5

Consolidated statement of changes in equity. 6

Consolidated statement of cash flows. 8

Notes to the consolidated financial statements. 9

1. General information. 9

2. Accounting policies. 18

3. Operating segments. 39

Notes to the consolidated statement of profit or loss and other comprehensive income. 43

4. Interest income and expense. 43

5. Fee and commission income and expense. 43

6. Net gains (losses) on financial instruments at fair value through profit or loss and foreign exchange gains (losses) 44

7. Net gains (losses) on investments in financial assets. 44

8. Net gains (losses) on modifications. 44

9. Other operating income and expenses. 45

10. General administrative expenses. 45

11. Net impairment losses and provisions. 45

12. Income tax. 46

13. Earnings per share. 48

14. Contribution to the State Budget 48

Notes to the consolidated statement of financial position.. 49

15. Cash and balances with the Central Bank. 49

16. Amounts due from banks. 49

17. Derivative financial instruments. 50

18. Securities. 50

19. Receivables and liabilities under reverse repurchase/repurchase agreements. 54

20. Loans and advances to customers. 54

21. Investments in associates. 56

22. Intangible assets. 59

23. Property, plant and equipment 61

24. Right-of-use assets. 62

25. Investment property. 64

26. Other assets. 65

27. Amounts due to banks. 65

28. Liabilities to customers. 66

29. Debt securities issued. 66

30. Lease liabilities. 66

31. Other liabilities. 67

32. Provisions. 67

33. Equity. 70

Other notes. 72

34. Contingent liabilities and off-balance-sheet liabilities granted and received. 72

35. Additional information to the consolidated statement of cash flows. 73

36. Transactions with the State Treasury and State Treasuryrelated entities. 75

38. Remuneration of the top executives of the Group entities. 79

39. Principles of variable remuneration for top executives of the Group. 79

40. Changes in Group entities. 81

41. Fair value of financial assets and financial liabilities. 81

42. Custody business. 86

Risk management objectives and principles. 87

43. Risk management at the Group. 87

44. Credit risk management 89

45. Liquidity risk management 107

46. Market risk management 110

47. Operational risk management 115

48. Other risks. 116

49. Capital adequacy. 120

Other supplementary information.. 125

50. Information on the entity authorised to audit the financial statements. 125

51. Proposed profit distribution of the parent entity. 125

52. Assets pledged as collateral for the payment of liabilities. 125

53. Impact of the COVID-19 pandemic on the BGK Group’s operations. 126

54. Major events subsequent to the reporting date. 129

Consolidated statement of profit or loss

Continuing operations	Note	2020	2019
Interest income	4	1,508,329	2,212,331
Interest income calculated with the use of the effective interest rate method		1,382,181	2,034,993
Income of similar nature to interest income on instruments at fair value through profit or loss		126,148	177,338
Interest expense	4	-557,179	-1,258,919
Net interest income		951,150	953,412
Fee and commission income	5	260,596	231,479
Fee and commission expense	5	-12,565	-12,882
Net fee and commission income		248,031	218,597
Net gains (losses) on financial instruments at fair value through profit or loss and foreign exchange gains (losses)	6	115,270	119,690
Net gains (losses) on investments in financial assets	7	141,652	85,697
Net gains (losses) on modifications	8	3,522	-9,171
Other operating income	9	138,858	235,770
Other operating expenses	9	-117,482	-43,945
General administrative expenses	10	-624,147	-600,816
Net impairment losses and provisions	11	-384,902	-231,415
Operating result		471,952	727,819
Share of profit or loss of associates	21	-24,968	-268,622
Profit before tax		446,984	459,197
Income tax	12	-80,414	-68,990
Net profit		366,570	390,207
Net profit attributable to the owner of the parent entity		367,297	390,132
Net profit/loss attributable to non-controlling interests	33.1	-727	75

Consolidated statement of comprehensive income

	Note	2020	2019
Net profit		366,570	390,207
Other comprehensive income		-42,249	-105,645
Items that may be reclassified subsequently to profit or loss		88,732	8,557
Revaluation of financial assets at fair value through other comprehensive income, gross		94,171	10,425
Deferred tax on financial assets at fair value through other comprehensive income	12	-17,899	-1,994
Share in other comprehensive income of associates, gross		1,916	0
Deferred tax on share in other comprehensive income of associates	12	-364	0
Foreign exchange gains or losses on translating subordinates		13,373	126
Deferred tax on foreign exchange gains or losses on translating subordinates	12	-2,465	0
Items that cannot be reclassified subsequently to profit or loss		-130,981	-114,202
Revaluation and gain or loss on sale of equity instruments designated as at fair value through other comprehensive income, gross		-159,426	-137,861
Deferred tax on revaluation and gain or loss on sale of equity instruments designated as at fair value through other comprehensive income	12	30,630	26,159
Property, plant and equipment and investment property, gross		-1,476	-67
Deferred tax on property, plant and equipment and investment property	12	280	13
Gains and losses due to measurement of defined benefit plans, gross		-1,221	-3,020
Deferred tax on measurement of defined benefit plans	12	232	574
Total net comprehensive income		324,321	284,562
Net comprehensive income attributable to the owner of the parent entity		325,048	284,487
Net comprehensive income/expense attributable to non-controlling interests	33.1	-727	75

Data for 2019 was restated. The changes in rules of presentation of financial data (comparative data) are presented in Note 1.5.

Notes to the consolidated financial statements on the pages to follow form their integral part.

Consolidated statement of financial position

	Note	31 Dec 2020	31 Dec 2019
Assets
Cash and balances with the Central Bank	15	32,262,257	22,729,376
Amounts due from banks	16	5,606,383	6,938,693
Derivative financial instruments	17	997,397	574,907
Securities		76,902,180	28,311,229
- held for trading		19,675	1,666
- not held for trading measured at fair value through profit or loss	18	880,771	821,198
- measured at fair value through other comprehensive income		55,769,263	20,090,431
- measured at amortised cost		20,232,471	7,397,934
Reverse repurchase agreements	19	4,207,234	5,301,537
Loans and advances to customers		33,451,675	30,912,329
- measured at amortised cost	20	33,349,409	30,787,459
- obligatorily measured at fair value through profit or loss		102,266	124,870
Investments in associates	21	4,378,771	3,652,833
Intangible assets	22	69,424	54,982
Property, plant and equipment	23	129,763	132,360
Right-of-use assets	24	104,779	45,843
Investment property	25	1,711,266	1,501,811
Current tax receivables		513	0
Deferred tax assets	12	325,237	247,376
Other assets	26	178,660	117,964
Total assets		160,325,539	100,521,240
Liabilities and equity
Liabilities
Amounts due to banks	27	3,907,897	4,119,646
Derivative financial instruments	17	1,324,800	611,330
Liabilities to customers	28	116,138,086	59,701,374
Repurchase agreements	19	5,817,989	9,113,388
Debt securities issued	29	4,859,446	7,251,523
Lease liabilities	30	113,162	43,099
Other liabilities	31	3,641,696	478,983
Current tax liabilities		47,088	80,208
Deferred tax liabilities	12	31,342	25,982
Provisions	32	520,062	441,790
Total liabilities		136,401,568	81,867,323
Equity
Statutory capital		21,692,215	16,646,945
Supplementary capital	33	1,569,548	1,134,443
Revaluation reserve		104,457	146,706
Other capital reserves		232,330	232,330
Retained earnings (accumulated loss)		-65,578	88,809
Net profit (loss) for the current year		367,297	390,132
Equity attributable to the owner of the parent entity		23,900,269	18,639,365
Non-controlling interests	33.1	23,702	14,552
Total equity	33	23,923,971	18,653,917
Total liabilities and equity		160,325,539	100,521,240

Data for 2019 was restated. The changes in rules of presentation of financial data (comparative data) are presented in Note 1.5.

Notes to the consolidated financial statements on the pages to follow form their integral part.

Consolidated statement of changes in equity

Equity attributable to the parent entity
	Revaluation reserve	Other capital reserves

Changes from 1 January to 31 December 2020	Note	Statutory capital	Supplementary capital	Financial assets at fair value through other comprehensive income	Actuarial gains and losses	Investment property revaluation reserve	Share in other comprehensive income of associates	Foreign exchange gains or losses on translating subordinates	Reserve capital	General banking risk reserve	Retained earnings	Total	Non-controlling interests	Total equity
1 January 2020		16,646,945	1,134,443	150,370	-5,218	1,526	0	28	76,830	155,500	478,941	18,639,365	14,552	18,653,917
Total comprehensive income, including:		0	0	-52,524	-989	-1,196	1,552	10,908	0	0	367,297	325,048	-727	324,321
net profit for the current year		0	0	0	0	0	0	0	0	0	367,297	367,297	-727	366,570
other comprehensive income for the period		0	0	-52,524	-989	-1,196	1,552	10,908	0	0	0	-42,249	0	-42,249
Allocation of investment property revaluation surplus to retained earnings		0	0	0	0	0	0	0	0	0	1,772	1,772	0	1,772
Retained earnings distribution, including:		110,770	435,105	0	0	0	0	0	0	0	-546,290	-415	0	-415
allocation to capital		110,770	439,980	0	0	0	0	0	0	0	-550,750	0	0	0
appropriation of profit to the Inland Waterways Fund (IWF)		0	0	0	0	0	0	0	0	0	-415	-415	0	-415
coverage of loss brought forward at the Group entities		0	-4,875	0	0	0	0	0	0	0	4,875	0	0	0
Statutory capital increase	33	4,934,500	0	0	0	0	0	0	0	0	0	4,934,500	0	4,934,500
Change in non-controlling interests		0	0	0	0	0	0	0	0	0	-1	-1	9,877	9,876
31 December 2020		21,692,215	1,569,548	97,846	-6,207	330	1,552	10,936	76,830	155,500	301,719	23,900,269	23,702	23,923,971

Notes to the consolidated financial statements on the pages to follow form their integral part.

Equity attributable to the parent entity
	Revaluation reserve	Other capital reserves

Changes from 1 January to 31 December 2019	Note	Statutory capital	Supplementary capital	Financial assets at fair value through other comprehensive income	Actuarial gains and losses	Investment property revaluation reserve	Foreign exchange gains or losses on translating subordinates	Reserve capital	General banking risk reserve	Retained earnings	Total	Non-controlling interests	Total equity
1 January 2019		17,102,410	1,053,260	253,641	-2,772	1,580	-98	76,830	155,500	579,964	19,220,315	13,360	19,233,675
Total comprehensive income, including:		0	0	-103,271	-2,446	-54	126	0	0	390,132	284,487	75	284,562
net profit for the current year		0	0	0	0	0	0	0	0	390,132	390,132	75	390,207
other comprehensive income for the period		0	0	-103,271	-2,446	-54	126	0	0	0	-105,645	0	-105,645
Allocation of investment property revaluation surplus to retained earnings		0	0	0	0	0	0	0	0	67	67	0	67
Retained earnings distribution, including:		44,535	81,183	0	0	0	0	0	0	-126,158	-440	0	-440
allocation to capital		44,535	98,143	0	0	0	0	0	0	-142,678	0	0	0
appropriation of profit to the Inland Waterways Fund (IWF)		0	0	0	0	0	0	0	0	-433	-433	0	-433
income tax		0	0	0	0	0	0	0	0	-7	-7	0	-7
coverage of loss brought forward at the Group entities		0	-16,960	0	0	0	0	0	0	16,960	0	0	0
Reduction of the statutory capital – establishment of the Polish Science Fund	33	-500,000	0	0	0	0	0	0	0	0	-500,000	0	-500,000
Distribution of profit to the State Budget	14	0	0	0	0	0	0	0	0	-364,745	-364,745	0	-364,745
Change in non-controlling interests		0	0	0	0	0	0	0	0	-317	-317	1,117	800
Other changes		0	0	0	0	0	0	0	0	-2	-2	0	-2
31 December 2019		16,646,945	1,134,443	150,370	-5,218	1,526	28	76,830	155,500	478,941	18,639,365	14,552	18,653,917

Notes to the consolidated financial statements on the pages to follow form their integral part.

Consolidated statement of cash flows

Consolidated statement of cash flows	Note	2020	2019
A. Cash flows from operating activities
Net profit/loss		366,570	390,207
Total adjustments:		10,914,741	3,709,305
Income tax recognised in profit or loss	12	80,414	68,990
Depreciation and amortisation	10	48,790	35,285
Profit/loss on investing activities		37,146	207,640
Interest and dividends	35	124,814	163,507
Foreign exchange gain/loss		39,435	-4,128
Change in amounts due from banks		-360,691	392,264
Change in assets under derivative financial instruments		-422,490	403,955
Change in securities		-43,731,141	-4,954,156
- held for trading		-18,009	-1,048
- not held for trading measured at fair value through profit or loss		-66,857	-81,057
- measured at fair value through other comprehensive income		-30,811,738	-4,355,887
- measured at amortised cost		-12,834,537	-516,164
Change in reverse repurchase agreements	35	1,094,303	-1,426,877
Change in loans and advances to customers		-2,539,345	-4,973,548
- measured at amortised cost		-2,561,949	-4,994,766
- obligatorily measured at fair value through profit or loss		22,604	21,218
Change in other assets		-96,017	-59,796
Change in amounts due to banks		-273,762	-60,258
Change in liabilities under derivative financial instruments		713,470	-965,665
Change in liabilities to customers		56,436,712	12,064,076
Change in repurchase agreements		-3,295,399	3,899,337
Change in provisions		77,050	40,569
Change in accumulated loss allowance for non-financial assets and other loss allowances		-6,454	2,765
Change in other liabilities		3,162,298	-1,023,272
Income tax paid		-176,135	-103,411
Other adjustments	35	1,743	2,028
Net cash from operating activities		11,281,311	4,099,512
B. Cash flows from investing activities
Inflows		130,241	42,743
Sale of property, plant and equipment		2	2,207
Sale of investment property		266	2,938
Sale of shares in associates		120,384	640
Sale of investments in financial assets		9,544	0
Dividends received	35	45	36,958
Outflows		1,061,358	308,273
Purchase of property, plant and equipment	23	20,050	10,303
Purchase of intangible assets	22	25,208	18,111
Purchase of investment property		160,407	237,616
Purchase of shares in associates	21	855,693	42,243
Net cash from investing activities		-931,117	-265,530
C. Cash flows from financing activities
Inflows		460,002	4,566,178
Net proceeds on share issued		2	523
Long-term loans received		460,000	715,655
Debt securities issued		0	3,850,000
Outflows		2,970,316	3,373,691
Repayment of long-term loans		432,375	411,449
Redemption of debt securities issued		2,358,600	2,392,000
Repayment of interest		159,139	192,571
Repayment of lease liabilities		20,202	12,775
Change in ownership structure		0	151
Other financial expenditure		0	364,745
Net cash from financing activities		-2,510,314	1,192,487
D. Total net cash flows		7,839,880	5,026,469
E. Cash and cash equivalents at the beginning of the period		29,131,114	24,104,645
F. Cash and cash equivalents at the end of the period	35	36,970,994	29,131,114

Data for 2019 was restated. The changes in rules of presentation of financial data (comparative data) are presented in Note 1.5.

Notes to the consolidated financial statements on the pages to follow form their integral part.

Notes to the consolidated financial statements

1. General information

Bank Gospodarstwa Krajowego (the “parent entity”, the “Bank”, “BGK”) is the parent of the Bank Gospodarstwa Krajowego Group (the “Group”, the “BGK Group”). The Bank’s name has not changed since the end of the previous reporting period. The Bank does not have a parent entity. The Bank does not have any ultimate parent entity.

Bank Gospodarstwa Krajowego is a state-owned bank as defined by the Banking Law of 29 August 1997 (Journal of Laws of 2020, item 1896) (“Banking Law”), the Act on Bank Gospodarstwa Krajowego of 14 March 2003 (Journal of Laws of 2020, item 1198), along with the Articles of Association adopted by the Regulation of the Minister of Development on the adoption of the Articles of Association of Bank Gospodarstwa Krajowego of 16 September 2016 (Journal of Laws of 2016, item 1527) and the Regulation of the Minister of Development, Labour and Technology of 31 December 2020 amending the Regulation on the adoption of the Articles of Association of Bank Gospodarstwa Krajowego (Journal of Laws of 2021, item 128). The Bank operates within the territory of the Republic of Poland. Its Head Office is located at Al. Jerozolimskie 7, 00-955 Warsaw, Poland (Bank’s temporary office is located in the Varso 2 Building at ul. Chmielna 7, 00-801 Warsaw). The Bank’s REGON statistical number is 000017319 and NIP tax identification number is 525-00-12-372. Apart from the Head Office, BGK operates 16 Regions located in all province capitals and representative offices based in Brussels, Frankfurt, London and Amsterdam. The Bank is the parent of the Bank Gospodarstwa Krajowego Group and a significant investor for associates held by the Bank and its subsidiaries.

Under Art. 4 of the Act on Bank Gospodarstwa Krajowego, the key objectives of BGK’s activities include supporting the economic policy of the Council of Ministers, social and economic government programmes, including surety and guarantee programmes, as well as local government and regional development programmes, in particular:

§ projects financed with EU funds and international financial institutions,

§ infrastructure projects,

§ projects related to the development of micro, small and medium-sized enterprise sector,

- including those financed with public funds.

Tasks fulfilled by the Bank under Articles 5 and 6 of the Act on Bank Gospodarstwa Krajowego include, in particular:

§ performance of activities specified in the Banking Law,

§ administration of funds created by, entrusted with or transferred to BGK under separate legislation,

§ export transaction handling with the use of export support instruments, in addition to supporting exports of Polish goods and services under separate legislation or government programmes,

§ offering, whether directly or indirectly, guarantee and/or surety services under government surety and guarantee programmes or on behalf of and for the account of the State Treasury in accordance with the Act on Sureties and Guarantees Granted by the State Treasury and Certain Legal Persons, dated 8 May 1997, in particular to the small and medium-sized enterprise sector,

§ supporting the development of residential construction, in particular development of residential property for rent, under separate legislation or government programmes,

§ providing bank account services to the State budget,

§ providing bank account services to the local government budget administration,

§ providing bank account services to the accounts of state or local government legal persons established under separate legislation to carry out public functions,

§ other functions carried out with the use of public funds, as specified in agreements entered into with public administration bodies.

Bank Gospodarstwa Krajowego has consistently pursued its mission to support social and economic growth of Poland and support the public finance sector in the performance of its tasks. The mission has been pursued since the Bank’s establishment in 1924.

The adopted strategy for 2017–2020 provides for the Bank’s active role as a partner in supporting growth and cooperation both in the financial market and as part of implementation of social and economic programmes. BGK’s strategy addresses the challenges faced by the Polish economy and reflects the Strategy for Responsible Development.

The four basic pillars of the Bank’s operations are: financing development and investments, European programmes, public finance, and operational excellence.

The Bank’s overriding objective is to support economic growth in areas where a gap occurred and the market does not operate effectively and to support sectors which are key to the implementation of the objectives of the economic policy. In addition, the Bank operates numerous programmes commissioned by governmental authorities and related to distribution of EU funds.

The key values defining the Bank’s organisational culture are: professionalism, partnership cooperation and commitment. Assimilation of these values is facilitated by cultural transformation. The effectiveness of the process is confirmed by, among other things, positive results of employee opinion survey carried out in 2020. The key element of the transformation has always been the pursuit of operational excellence in terms of delivering value to both external customers and the Bank’s employees. Projects and internal efforts undertaken are focused on four key areas: business model, IT, HR and communications. Another important area of the Bank’s activities is strengthening of its position on the international market. To date, representative offices were opened in Brussels, Frankfurt, London and Amsterdam. The Bank intends to open further offices across the world in the near future.

The new Strategy for 2021–2024 draws on the effects of the Bank’s existing development projects and strengthens BGK’s role as a key institution for Poland’s sustainable social and economic development.

1.1. Composition of the Supervisory Board and the Management Board of the parent entity

Composition of the Bank’s Supervisory Board

Compared to 31 December 2019, the composition of the Bank’s Supervisory Board changed.

The President of the Council of Ministers appointed Honorata Krysiewicz as Member of the Supervisory Board as of 30 July 2020.

On 31 August 2020, the term of office of the existing Supervisory Board expired. After the end of the term of office, members of the Supervisory Board continued to perform their duties until the appointment of the new Supervisory Board.

The President of the Council of Ministers appointed the Supervisory Board of the new 10th term of office as of 6 October 2020 composed as follows:

§ Paweł Borys – Chairman of the Supervisory Board,

§ Beata Gorajek – Member of the Supervisory Board,

§ Zbigniew Krysiak – Member of the Supervisory Board,

§ Honorata Krysiewicz – Member of the Supervisory Board,

§ Jerzy Szmit – Member of the Supervisory Board,

§ Łukasz Śmigasiewicz – Member of the Supervisory Board,

§ Magdalena Tarczewska-Szymańska – Member of the Supervisory Board,

§ Robert Nowicki – Member of the Supervisory Board,

§ Marek Niedużak – Member of the Supervisory Board,

The Supervisory Board in the new composition was installed in office on 29 October 2020.

In addition, the President of the Council of Ministers appointed the following new members of the Supervisory Board:

§ as of 2 November 2020 – Adam Rudzewicz,

§ as of 16 November 2020 – Jacek Hecht,

§ as of 24 November 2020 – Grzegorz Dostatni.

As at 31 December 2020, the composition of the Bank’s Supervisory Board was as follows:

§ Paweł Borys – Chairman of the Supervisory Board,

§ Beata Gorajek – Deputy Chairwoman of the Supervisory Board,

§ Marek Niedużak – Secretary of the Supervisory Board,

§ Zbigniew Krysiak – Member of the Supervisory Board,

§ Honorata Krysiewicz – Member of the Supervisory Board,

§ Robert Nowicki – Member of the Supervisory Board,

§ Magdalena Tarczewska-Szymańska – Member of the Supervisory Board,

§ Jerzy Szmit – Member of the Supervisory Board,

§ Łukasz Śmigasiewicz – Member of the Supervisory Board,

§ Adam Rudzewicz – Member of the Supervisory Board,

§ Jacek Hecht – Member of the Supervisory Board,

§ Grzegorz Dostatni – Member of the Supervisory Board.

Composition of the Bank’s Supervisory Board did not change from 31 December 2020 until the date on which these financial statements were signed.

1.2. Composition of the Bank Gospodarstwa Krajowego Group

As at 31 December 2020, the composition of the Bank Gospodarstwa Krajowego Group was as follows: Bank Gospodarstwa Krajowego (the parent entity) and the following direct or indirect subsidiaries:

Fundusz Sektora Mieszkań na Wynajem FIZ AN (Dwelling for Rent Sector Closed-End Private Equity Investment Fund) – its operations consist in investing proceeds from non-public offering of investment certificates. The Fund seeks to achieve its investment objective mainly by purchasing and subscribing for shares in SPVs and debt securities issued by SPVs.

Fundusz Ekspansji Zagranicznej FIZ AN (Foreign Expansion Closed-End Private Equity Investment Fund) – its operations consist in investing proceeds from non-public offering of investment certificates. The Fund seeks to achieve its investment objective mainly by purchasing and subscribing for shares. It supports foreign expansion by investing in foreign operations of Polish companies.

Fundusz Sektora Mieszkań dla Rozwoju FIZ AN (Dwelling for Development Sector Closed-End Private Equity Investment Fund) – its operations consist in co-financing investments in building real estate carried out by municipalities and communes or companies under their management. The Fund invests in projects consisting in constructing or purchasing buildings that lie in significant interests of a municipality or commune, along with reconstructing and adjusting them to its needs, as well as in real estate projects carried out as part of urban areas regeneration projects.

Special Purpose Vehicles – the entities whose scope of business include implementation, on own account, of construction projects involving the construction of buildings, purchase and sale of real estate, including multi-family residential buildings, as well as lease of apartments located in its multi-family residential buildings on own account, in addition to real estate services.

1.3. Subsidiaries

Composition of the BGK Group is presented below:

Composition of the BGK Group
Entity name	Registered office	Scope of business	Direct/indirect interest held by the parent entity in the entity’s capital (%)
Entity name	Registered office	Scope of business	31 Dec 2020	31 Dec 2019
Investments of Bank Gospodarstwa Krajowego
Fundusz Ekspansji Zagranicznej FIZ AN*	Warsaw	investment of proceeds from fund participants	100%	100%
Fundusz Sektora Mieszkań dla Rozwoju FIZ AN*	Warsaw	investment of proceeds from fund participants	99.99988%	100%
Fundusz Sektora Mieszkań na Wynajem FIZ AN*	Warsaw	investment of proceeds from fund participants	99.99998%	100%
Special Purpose Vehicles of Fundusz Sektora Mieszkań na Wynajem FIZ AN
FSMnW Poznań Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Kraków Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Trójmiasto Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Warszawa 1 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Wrocław Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Katowice Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Inwestycje Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Warszawa 2 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Warszawa 4 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
FSMnW Warszawa 3 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MP Inwestycje Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
Special Purpose Vehicles of Fundusz Sektora Mieszkań dla Rozwoju FIZ AN
MP Inwestycje 2 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Katowice Sp. z o.o.	Warsaw	rental and management of own or rented property	91.38%	90.59%
Projekt Municypalny Jarocin 1 Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	92.03%	92.99%
Projekt Municypalny Kępice 1 Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	86.96%	86.96%
Projekt Municypalny Kępno 1 Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	89.85%	89.85%
Projekt Municypalny Sulęcin 1 Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
Spółka Operacyjna Projektów Municypalnych Sp. z o.o.	Warsaw	Activities of head offices and holdings, excluding financial holdings	100%	100%
MP Biała Podlaska Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Inwestycje 8 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Mińsk Mazowiecki Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Radom Sp. z o.o.	Warsaw	rental and management of own or rented property	91.86%	51.76%
MDR Inwestycje 6 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Inwestycje 7 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Inwestycje 13 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Inwestycje 12 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Szczecin Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Warszawa Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Września Sp. z o.o.**	Warsaw	rental and management of own or rented property	100%	100%
MDR Katowice 2 Sp. z o.o.	Warsaw	rental and management of own or rented property	51.22%	100%

MDR Lublin Krochmalna Sp. z o.o.***	Warsaw	rental and management of own or rented property	100%	100%
MDR Inwestycje 16 Sp. z o.o.	Warsaw	rental and management of own or rented property	sale	100%
MDR Inwestycje 5 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Inwestycje 14 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Łowicz Sp. z o.o.	Warsaw	rental and management of own or rented property	86.77%	100%
Projekt Municypalny Zgorzelec 1 Sp. z o.o.	Warsaw	rental and management of own or rented property	99.92%	99.89%
MDR Toruń Sp. z o.o.	Warsaw	rental and management of own or rented property	54.74%	54.74%
MDR Świdnik Sp. z o.o.	Warsaw	rental and management of own or rented property	83.18%	100%
MDR Dębica Sp. z o.o.	Warsaw	rental and management of own or rented property	86.85%	100%
MDR Skawina Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Zamość Sp. z o.o.	Warsaw	rental and management of own or rented property	72.99%	100%
Projekt Municypalny Nidzica 1 Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	75.00%	75.00%
MP Inwestycje 3 Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MP Wałbrzych Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Przemyśl Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Mielec Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Wrocław Białowieska Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Warszawa Ordona Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Szczecin Starkiewicza Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Zakliczyn Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Katowice Asnyka Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Gdańsk Kochanowskiego Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Poznań Wolne Tory Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Wrocław Hermanowska Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Oława Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Witnica Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Sianów Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Wieluń Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Wrocław Zatorska-Odolanowska Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Jedlina-Zdrój Sp. z o.o.	Warsaw	rental and management of own or rented property	100%	100%
MDR Nakło nad Notecią Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	99.95%	100%
MDR Nowy Targ Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Warszawa Ratuszowa Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	100%
MDR Sochaczew Sp. z o.o.	Warsaw	implementing construction projects related to erecting buildings	100%	-
PFR Mieszkania S.A.	Warsaw	rental and management of own or rented property	100%	-
* “Direct/indirect interest held by the parent entity in the entity’s capital” presents the share in the Fund’s investment certificates. As at 31 December 2020, another investor held one certificate in each Fundusz Sektora Mieszkań dla Rozwoju FIZ AN and Fundusz Sektora Mieszkań na Wynajem FIZ AN, representing 0.0002% of their share capital.
** In 2020, MDR Inwestycje 10 Sp. z o.o. changed its name to MDR Września Sp. z o.o.
*** On 25 January 2021, MDR Inwestycje 15 Sp. z o.o. changed its name to MDR Lublin Krochmalna Sp. z o.o.

1.4. Associates

BGK Group has the following associates:

Associates
Entity name	Registered office	Scope of business	Interest held by the parent entity in the entity’s capital
Entity name	Registered office	Scope of business	31 Dec 2020	31 Dec 2019
Investments of Bank Gospodarstwa Krajowego
Fundusz Inwestycji Infrastrukturalnych Kapitałowy Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych	Warsaw	investment of proceeds from fund participants	86.45%	86.45%
Fundusz Inwestycji Polskich Przedsiębiorstw Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych	Warsaw	investment of proceeds from fund participants	86.40%	86.40%
Fundusz Inwestycji Samorządowych Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych	Warsaw	investment of proceeds from fund participants	50.00%	50.00%
Fundusz Inwestycji Infrastrukturalnych Dłużny Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych	Warsaw	investment of proceeds from fund participants	liquidated	5.89% (86.45%)*
Three Seas Initiative Investment Fund S.A. SICAV-RAIF	Luxembourg	investment activity	89.29%	96.15%
Korporacja Ubezpieczeń i Kredytów Eksportowych S.A.	Warsaw	insurance activities	48.45%	36.69%
Krajowa Grupa Poręczeniowa Sp. z o.o.	Warsaw	surety activities	39.29%	39.29%
Świętokrzyski Fundusz Poręczeniowy Sp. z o.o.	Kielce	surety activities	49.99%	49.99%
Kujawsko-Pomorski Fundusz Poręczeń Kredytowych Sp. z o.o.	Toruń	surety activities	49.38%	49.38%
Opolski Regionalny Fundusz Poręczeń Kredytowych Sp. z o.o.	Opole	surety activities	48.27%	48.27%
Fundusz Pomerania Sp. z o.o.	Szczecin	surety activities	41.15%	41.15%
Samorządowy Fundusz Poręczeń Kredytowych Sp. z o.o. of Gostyń	Gostyń	surety activities	37.51%	41.01%
Śląski Regionalny Fundusz Poręczeniowy Sp. z o.o.	Katowice	surety activities	46.08%	46.08%
Poznański Fundusz Poręczeń Kredytowych Sp. z o.o.	Poznań	surety activities	44.44%	44.44%
Dolnośląski Fundusz Gospodarczy Sp. z o.o.	Wrocław	surety activities	42.62%	42.62%
Małopolski Regionalny Fundusz Poręczeniowy Sp. z o.o.	Kraków	surety activities	36.87%	36.87%
Warmińsko-Mazurski Fundusz Poręczenia Kredytowe Sp. z o.o.	Działdowo	surety activities	36.19%	36.19%
Małopolski Fundusz Poręczeń Kredytowych Sp. z o.o. w likwidacji (in liquidation)	Nowy Sącz	surety activities	32.86%	32.86%
Bydgoski Fundusz Poręczeń Kredytowych Sp. z o.o.	Bydgoszcz	surety activities	31.09%	31.09%
Fundusz Rozwoju i Promocji Województwa Wielkopolskiego S.A.	Poznań	surety activities	sale	22.47%
Investments of Fundusz Ekspansji Zagranicznej FIZ AN
Esotiq Germany GMBH	Stuttgart	Retail sale of textile goods	48.78%	48.78%
UAB EMP Recycling	Galines (Lithuania)	Acquisition, processing, and sale of recyclable waste	49.00%	49.00%
ASM Germany GmbH	Nuremberg	Sales support services	49.90%	49.90%
Elemental USA Inc.	Wilmington, Delaware (USA)	Recycling of automotive catalysts	49%	49%
Recat GmbH	Sulzfeld, Germany	Recycling of automotive catalysts	32.20%	32.20%
G+M GmbH	Marktzeuln, Germany	Manufacture of precast concrete products	24.00%	-
* target interest

BGK is the initiator and co-founder of Three Seas Initiative Investment Fund S.A. SICAV-RAIF (the Three Seas Initiative Investment Fund, ‘Fundusz Trójmorza’). It is an alternative investment fund established to implement commercial infrastructure projects which are significant growth drivers for economies of countries located in the Three Seas Region (Central and Eastern Europe between the Baltic Sea, the Black Sea and the Adriatic). The Bank’s role is to perform the arrangements regarding the Fund’s strategy and structure established with partners from development institutions of the Three Seas Initiative member states, thus it does not have control over the Fund within the meaning of IFRS. The Fund is open to institutions representing other Three Seas Initiative member states – after joining the Fund each of them will hold shares conferring equivalent ownership rights to the shares held by the Bank. In addition, the Three Seas Initiative Investment Fund is in the process of raising funds and holds talks with private investors and international financial institutions on their potential participation in the Fund as shareholders.

Fundusz Inwestycji Infrastrukturalnych Kapitałowy Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych (‘The Infrastructure Investment Equity Closed-End Private Equity Investment Fund’) and Fundusz Inwestycji Polskich Przedsiębiorstw Fundusz Inwestycyjny Zamknięty Aktywów Niepublicznych (‘The Polish Enterprise Investments Closed-End Private Equity Investment Fund’) , whose certificate holders are Bank Gospodarstwa Krajowego and Polski Fundusz Rozwoju S.A. (Polish Development Fund, PFR) are classified as associates. Despite holding a significant interest in the Funds, the Bank only has significant influence over the Funds due to:

§ commissioning to PFR by PFR TFI S.A. of management and investment activities with respect to part of the Funds’ investment portfolio as part of the investment strategy, and

§ participation of only one representative of the Bank in the work of investment committee composed of five members (share of 20%), whose positive opinion is required for making investments by the Funds.

1.5. Change in presentation of financial data (comparative data)

In the full-year consolidated financial statements for the period from 1 January 2020 to 31 December 2020, relative to the full-year consolidated financial statements for the period from 1 January 2019 to 31 December 2019, the Group restated items of the consolidated statement of comprehensive income, consolidated statement of financial position and consolidated statement of cash flows. In particular, the changes consist in a different grouping of financial assets and financial liabilities resulting from derivative financial instruments and securities, with no impact on their valuation or classification.

In the parent entity’s opinion, the presentation changes are organisational in nature and result in better presentation of the types of the Group’s financial instruments. The introduction of the changes resulted in the need to ensure comparability with the current period of comparable data disclosed in these consolidated financial statements.

Below are presented the individual items of the consolidated statement of comprehensive income, consolidated statement of financial position and consolidated statement of cash flows at amounts disclosed in the full-year consolidated financial statements for the period from 1 January 2019 to 31 December 2019 and after restatement.

Consolidated statement of comprehensive income	2019	restatement	31 Dec 2019 restated
Net profit	390,207		390,207
Other comprehensive income	-105,645		-105,645
Items that may be reclassified subsequently to profit or loss	8,557		8,557
Revaluation of financial assets at fair value through other comprehensive income, gross	0	10,425	10,425
Revaluation of financial assets at fair value through other comprehensive income, including:	8,431	-8,431	0
Deferred tax on financial assets at fair value through other comprehensive income	-1,994		-1,994
Foreign exchange gains or losses on translating subordinates, gross	0	126	126
Foreign exchange gains or losses on translating subordinates	126	-126	0
Items that cannot be reclassified subsequently to profit or loss	-114,202		-114,202
Revaluation and gain or loss on sale of equity instruments designated as at fair value through other comprehensive income, gross		-137,861	-137,861
Revaluation of equity instruments designated as at fair value through other comprehensive income, including:	-111,702	111,702	0
Deferred tax on revaluation and gain or loss on sale of equity instruments designated as at fair value through other comprehensive income	26,159		26,159
Property, plant and equipment and investment property, gross		-67	-67
Property, plant and equipment and investment property, including:	-54	54	0
Deferred tax on property, plant and equipment and investment property	13		13
Gains and losses due to measurement of defined benefit plans, gross		-3,020	-3,020
Gains and losses due to measurement of defined benefit plans, including:	-2,446	2,446	0
Deferred tax on measurement of defined benefit plans	574		574
Total net comprehensive income	284,562		284,562
Net comprehensive income attributable to the owner of the parent entity	284,487		284,487
Net comprehensive income attributable to non-controlling interests	75		75

Consolidated statement of financial position	31 Dec 2019	restatement	31 Dec 2019 restated
Assets
Cash and balances with the Central Bank	22,729,376		22,729,376
Amounts due from banks	6,938,693		6,938,693
Financial assets held for trading	576,573	-576,573	0
Financial assets at fair value through profit or loss	821,198	-821,198	0
Financial assets at fair value through other comprehensive income	20,090,431	-20,090,431	0
Debt instruments at amortised cost	7,397,934	-7,397,934	0
Derivative financial instruments	0	574,907	574,907
Securities	0		28,311,229
- held for trading	0	1,666	1,666
- not held for trading measured at fair value through profit or loss	0	821,198	821,198
- measured at fair value through other comprehensive income	0	20,090,431	20,090,431
- measured at amortised cost	0	7,397,934	7,397,934
Reverse repurchase agreements	5,301,537		5,301,537
Loans and advances to customers	30,912,329		30,912,329
- measured at amortised cost	30,787,459		30,787,459
- obligatorily measured at fair value through profit or loss	124,870		124,870
Investments in associates	3,652,833		3,652,833
Intangible assets	54,982		54,982
Property, plant and equipment	132,360		132,360
Right-of-use assets	45,843		45,843
Investment property	1,501,811		1,501,811
Current tax receivables	0		0
Deferred tax assets	247,376		247,376
Other assets	117,964		117,964
Total assets	100,521,240		100,521,240
Liabilities and equity
Liabilities
Amounts due to banks	4,119,646		4,119,646
Financial liabilities held for trading	611,330	-611,330	0
Derivative financial instruments	0	611,330	611,330
Liabilities to customers	59,701,374		59,701,374
Repurchase agreements	9,113,388		9,113,388
Debt securities issued	7,251,523		7,251,523
Lease liabilities	43,099		43,099
Other liabilities	478,983		478,983
Current tax liabilities	80,208		80,208
Deferred tax liabilities	25,982		25,982
Provisions	441,790		441,790
Total liabilities	81,867,323		81,867,323
Equity
Statutory capital	16,646,945		16,646,945
Supplementary capital	1,134,443		1,134,443
Revaluation reserve	146,678	28	146,706
Other capital reserves	232,330		232,330
Foreign exchange gains or losses on translating subordinates	28	-28	0
Retained earnings (accumulated loss)	88,809		88,809
Net profit (loss) for the current year	390,132		390,132
Equity attributable to the owner of the parent entity	18,639,365		18,639,365
Non-controlling interests	14,552		14,552
Total equity	18,653,917		18,653,917
Total liabilities and equity	100,521,240		100,521,240

Consolidated statement of cash flows	2019	restatement	31 Dec 2019 restated
A. Cash flows from operating activities
Net profit/loss	390,207		390,207
Total adjustments:	3,709,305		3,709,305
Income tax recognised in profit or loss	68,990		68,990
Depreciation and amortisation	35,285		35,285
Profit/loss on investing activities	210,405	-2,765	207,640
Interest and dividends	163,507		163,507
Foreign exchange gain/loss	-4,128		-4,128
Change in amounts due from banks	392,264		392,264
Change in financial assets held for trading	402,907	-402,907	0
Change in assets under derivative financial instruments	0	403,955	403,955
Change in securities	0	-4,954,156	-4,954,156
- held for trading	0	-1,048	-1,048
- not held for trading measured at fair value through profit or loss	0	-81,057	-81,057
- measured at fair value through other comprehensive income	0	-4,355,887	-4,355,887
- measured at amortised cost	0	-516,164	-516,164
Change in reverse repurchase agreements	-1,426,877		-1,426,877
Change in loans and advances to customers	-4,973,548		-4,973,548
- measured at amortised cost		-4,994,766	-4,994,766
- obligatorily measured at fair value through profit or loss		21,218	21,218
Change in financial assets at fair value through profit or loss	-81,057	81,057	0
Change in financial assets at fair value through other comprehensive income	-4,355,887	4,355,887	0
Change in debt instruments at amortised cost	-516,164	516,164	0
Change in other assets and assets held for sale	-59,796		-59,796
Change in amounts due to banks	-60,258		-60,258
Change in financial liabilities held for trading	-965,665	965,665	0
Change in liabilities under derivative financial instruments	0	-965,665	-965,665
Change in liabilities to customers	12,064,076		12,064,076
Change in repurchase agreements	3,899,337		3,899,337
Change in provisions	40,569		40,569
Change in accumulated loss allowance for non-financial assets and other loss allowances	0	2,765	2,765
Change in other liabilities	-1,023,272		-1,023,272
Income tax paid	-103,411		-103,411
Other adjustments	2,028		2,028
Net cash from operating activities	4,099,512		4,099,512
B. Cash flows from investing activities
Inflows	42,743		42,743
Sale of property, plant and equipment	2,207		2,207
Sale of investment property	2,938		2,938
Sale of shares in subsidiaries and associates	640		640
Dividends received	36,958		36,958
Outflows	308,273		308,273
Purchase of property, plant and equipment	10,303		10,303
Purchase of intangible assets	18,111		18,111
Purchase of investment property	237,616		237,616
Purchase of shares in subsidiaries and associates	42,243		42,243
Net cash from investing activities	-265,530		-265,530
C. Cash flows from financing activities
Inflows	4,566,178		4,566,178
Net proceeds on share issued	523		523
Long-term loans and advances received	715,655		715,655
Debt securities issued	3,850,000		3,850,000
Outflows	3,373,691		3,373,691
Repayment of long-term loans and advances	411,449		411,449
Repayment of interest	57,644	134,927	192,571
Redemption of debt securities issued	2,392,000		2,392,000
Interest paid on debt securities issued	134,927	-134,927	0
Repayment of lease liabilities	12,775		12,775
Change in ownership structure	151		151
Other financial expenditure	364,745		364,745
Net cash from financing activities	1,192,487		1,192,487
D. Total net cash flows	5,026,469		5,026,469
E. Cash and cash equivalents at the beginning of the period	24,104,645		24,104,645
F. Cash and cash equivalents at the end of the period	29,131,114		29,131,114

2. Accounting policies

2.1. Statement of compliance

These consolidated financial statements of the Bank Gospodarstwa Krajowego Group for 2020 (the “financial statements”) have been prepared in accordance with the International Financial Reporting Standards approved by the European Union as at 31 December 2020 and the related interpretations published as Commission Regulations (IFRS), and to the extent not regulated by the aforesaid standards in accordance with the requirements of the Accounting Act of 29 September 1994 (Polish Accounting Standards , PAS) and secondary legislation thereto.

Financial data of subsidiaries and associates which do not apply the accounting principles according to IFRS was adjusted to align it to the accounting principles used by the Group.

These consolidated financial statements were approved for issue by the Management Board of Bank Gospodarstwa Krajowego on 15 April 2021.

These consolidated financial statements of the Bank Gospodarstwa Krajowego Group are published on the same date as the separate financial statements of Bank Gospodarstwa Krajowego for 2020.

2.2. Amendments to accounting standards

Amendments to the existing standards adopted for the first time in the financial statements for 2020

The following new standards, amendments to existing standards and interpretations issued by the International Accounting Standards Board (IASB) and approved for use in the EU were applied for the first time in the Group’s financial statements for 2020:

§ Amendments to IFRS 9 Financial Instruments, IAS 39 Financial Instruments: Recognition and Measurement and IFRS 7 Financial Instruments: Disclosures − Interest Rate Benchmark Reform – These amendments provide for a temporary and minor derogations from the hedge accounting requirements set out in IAS 39 and IFRS 9, which allow entities to continue to comply with the applicable requirements, provided that the existing interest rate benchmarks are not affected following the completed Interest Rate Benchmark Reform.

§ Amendments to IAS 1 Presentation of Financial Statements and IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors – The amendments clarify the definition of ‘material’ and how it should be applied.

§ Amendments to IFRS 3 Business Combinations – The amendments are implemented to improve the definition of a business. The revised definition of a business specifies that the objective (result) of a business is to provide goods and services to customers, while the existing definition focuses on results in the form of dividends, lower costs or other economic benefits for investors and other entities.

§ Amendments to IFRS 16 Leases – The amendments permit lessees not to treat rent concessions as a lease modification, if they occur as a direct consequence of COVID-19 and meet certain conditions.

§ Update of references to the conceptual framework in IFRS Standards – Due to an update of conceptual framework, the IASB updated references to the revised conceptual framework in IFRS Standards.

The above new standards, amendments to existing standards and the interpretation had no effect on the Group’s financial statements for 2020.

New standards and amendments to existing standards issued by the IASB and approved by the EU, but which have not yet become effective

The following amendments have been approved for use in the EU, but are not yet effective:

§ Amendments to IFRS 9 Financial Instruments, IAS 39 Financial Instruments: Recognition and Measurement and IFRS 7 Financial Instruments: Disclosures, IFRS 4 Insurance Contracts and IFRS 15 Revenue from Contracts with Customers − Interest Rate Benchmark Reform – Phase 2. The provisions published as part of Phase 2 of the IBOR reform relate to:

- changes in contractual cash flows – addition to IFRS 9 of a solution that permits the recognition of a modification of contractual cash flows as a result of IBOR reform by revising the effective interest rate of a contract to reflect the transition to an alternative reference rate (it will not be required to discontinue recognition or adjust the carrying amount of financial instruments); a similar solution is provided for under IFRS 16 with respect to recognition by lessees of lease modifications;

- hedge accounting – there will be no requirement to discontinue hedge accounting solely because of changes required by the reform, if the hedge meets other hedge accounting criteria; and

- disclosures – entities will be required to provide disclosures about new risks arising from the reform and how the entity manages the transition to alternative reference rates.

§ Amendments to IFRS 4 Insurance Contracts – The amendments provide for two optional solutions reducing the impact of differing effective dates of IFRS 9 Financial Instruments and IFRS 17 Insurance Contracts.

The Group estimates that the above new standards and amendments to existing standards would not have had a material effect on these consolidated financial statements if they had been applied by the Group as at 31 December 2020.

New standards and amendments to existing standards published by the IASB, but have not yet been approved for use in the EU

The EU-approved IFRS do not differ significantly from the regulations issued by the IASB, with the exception of the following new standards and amendments to standards, which have not yet been approved for use in the EU:

§ IFRS 17 Insurance Contracts and amendments to IFRS 17 – The new standard requires for measurement of insurance contracts in an amount of current fulfilment value and ensures a more uniform approach for measuring and presentation all insurance contracts. The purpose of these requirements is to achieve a coherent disclosure of insurance contracts based on uniform accounting principles. IFRS 17 replaces IFRS 4 Insurance Contracts and its interpretations on the date of adoption of the new standard. The amendments issued in 2020 are designed to:

- reduce costs by simplifying some requirements in the standard;

- make financial performance easier to explain; and

- ease transition to the new standard by deferring the effective date of the standard to 2023 and by providing additional relief to simplify the application of IFRS 17 for the first time.

§ Amendments to IFRS 3 Business Combinations – The amendments update a reference in IFRS 3 to the Conceptual Framework for Financial Reporting without changing the accounting requirements for business combinations.

§ Amendments to IAS 1 Presentation of Financial Statements – The amendments introduce a more general approach to classification of liabilities based on contractual arrangements effective as at the reporting date.

§ Amendments to IAS 16 Property, Plant and Equipment – The amendments prohibit a company from deducting from the cost of property, plant and equipment amounts received from selling items produced while the company is preparing the asset for its intended use. Instead, a company should recognise such sales proceeds and related cost in profit or loss.

§ Amendments to IAS 37 Provisions, Contingent Liabilities and Contingent Assets – The amendments specify which costs a company includes when assessing whether a contract will be loss-making.

The Group estimates that the above new standards and amendments to existing standards would not have had a material effect on these consolidated financial statements if they had been applied by the Group as at 31 December 2020.

2.3. Basis of preparation of the financial statements

These consolidated financial statements of the Bank Gospodarstwa Krajowego Group contain data for the financial year from 1 January to 31 December 2020 as well as comparative financial data for the financial year from 1 January to 31 December 2019.

These consolidated financial statements have been prepared on the assumption that the Group will continue as a going concern for at least twelve months after the reporting date. As at the date of approval of these financial statements, the Management Board of the parent entity did not identify any facts or circumstances that would pose a risk for the Group to continue as a going concern as a result of intended or forced discontinuation or material limitation of its operations. In applying the going concern assumption the impact of the COVID-19 pandemic on the general macroeconomic environment and the Group’s operations was taken into account. For disclosures related to COVID-19 see “Risk management objectives and principles” and “Other supplementary information”.

Unless otherwise stated, the financial data in the financial statements is presented in the Polish złoty, rounded to PLN 1 thousand.

These consolidated financial statements were prepared based on the following measurement principles:

§ at fair value for financial assets and liabilities measured at fair value through profit or loss, including financial assets held for trading, and for financial assets measured at fair value through other comprehensive income,

§ at amortised cost for other financial assets, including loans and advances and other financial liabilities,

§ at historical cost less impairment allowances, for associates and subsidiaries and non-financial assets and liabilities; in addition, for two entities (MP Inwestycje Sp. z o.o., FSMnW Warszawa 3 Sp. z o.o.) liquidation measurement was applied due to their intended winding up,

§ at fair value for investment property.

2.4. Estimates and assumptions

The Group makes certain estimates and assumptions that affect both the financial statements and the accompanying notes. The estimates and assumptions made for purposes of recognition of the respective amounts of assets and liabilities as well as revenue and costs are based on historical data and other factors which are available and considered appropriate under given circumstances.

The assumptions concerning the future and the available data are used for purposes of estimating the carrying amounts of assets and liabilities that cannot be measured reliably using other sources. While making such assumptions, the Group takes into account the causes and sources of uncertainty that it is able to foresee at the end of the reporting period. Actual performance may differ from estimates.

The estimates and assumptions made by the BGK Group are reviewed on a regular basis. Estimation adjustments are recognised in the period when the estimates are modified, if they pertain to that period only. If the adjustments affect both the period of the modification and future periods, they are recognised in the period of the modification and in future periods.

Allowances for expected credit losses taking account of the situation resulting from the COVID-19 pandemic

The Group applies the requirements of IFRS 9 regarding impairment for the recognition and measurement of a loss allowance for financial assets that are measured at amortised cost or at fair value through other comprehensive income. The methods for impairment tests and calculation of expected credit losses are described in Note 44 “Credit risk management”.

As regards expected credit losses, the Bank analysed the situation related to COVID-19 and took appropriate measures on an ongoing basis. In the first months of the epidemic, before the virus spilled across Europe, the Bank carried out stress test for clients from industries which were the most badly affected by the COVID-19 pandemic. The tests were performed in consultation with the clients and using the Bank’s risk assessment tools, and their results were reflected in the level of expected credit losses. As the COVID-19 pandemic grew in strength, the stress tests covered the entire portfolio by industry with gradation of how the epidemic affects different industries. Regardless of the impact on clients’ standing and BGK’s performance, the pandemic of COVID-19 had a significant impact on the entire lending process. The Bank took a number of steps to facilitate the lending process during the pandemic, which involved the simplification of rules applied to changing the existing financing terms, including deferral of repayments. Also, it introduced a simplified approval path for deferral of repayments and renewal of financing for customers affected by the epidemic, while retaining the acceptable level of risk. In the lending process the Bank has applied the guidelines of the Polish Financial Supervision Authority and the European Banking Authority regarding the classification and assessment of exposures in the light of the COVID-19 crisis.

The situation related to COVID-19, the activities referred to above (described in detail in Note 53) and the guidelines on classification of exposures to appropriate stages in accordance with IFRS 9 had a direct impact on the amount of expected credit losses. The Bank did not change the methods of IFRS 9 valuation models, but the updated parameters of the models and actual monitoring data (which is crucial due to the nature of the Bank’s loan portfolio – high concentration of the portfolio, no retail loan portfolio) reflect expectations regarding the increase in credit risk following the COVID-19 pandemic and the resulting significant uncertainty. The following changes were made, which was reflected in the amount of expected credit losses:

§ adjustment of LGD parameters (to reflect the estimated changes in recovery of collateral),

§ update of the LtPD curve to reflect current data,

§ update of macroeconomic forecast based on which expected credit losses are determined,

§ update of the assessment of the situation of individual clients as part of the monitoring process, reflected in the rating and the PD parameter.

Estimated impairment losses on investments in non-financial assets

The Bank applies the requirements of IAS 36 for assessing whether there is any indication that non-financial assets may be impaired. If an indication of an impairment is present and is considered to be permanent, the Bank estimates the

recoverable amount of such assets. Non-financial assets are impaired when their carrying amount exceeds their recoverable amount. The difference is recognised as an impairment loss.

Fair value of derivatives, unlisted debt securities and receivables

Derivatives, unlisted debt securities and receivables recognised in the statement of financial position at fair value, with no active market identified, are measured using generally accepted valuation techniques, using inputs based on observable market data and professional judgement to the maximum extent possible. The valuation techniques and input data are reviewed on a regular basis. The estimated effect of changes in the fair value measurement of financial instruments is presented in Note 41 “Fair value of financial assets and financial liabilities”.

Provisions for defined benefit plans

A sensitivity analysis of provisions for defined benefit plans is presented in Note 32 “Provisions”.

Provisions for litigation and legal risks

Provisions for litigation and legal risks are recognised based on the assessment of the probability of issuing a ruling against the Bank or unfavourable finalisation of the case.

The Bank is following the changes in the legal environment resulting from judicial decisions relating to mortgage loans indexed to foreign currencies (CHF), including the judgment of the Court of Justice of the European Union (CJEU) of 3 October 2019 in case C 260/18. Account should also be taken of the activities of the Polish Financial Supervision Authority aimed at recommending the direction and scope of potential settlements between banks and borrowers.

The Bank took into account the related legal risk and determined on relevant schedules that the cash flows from the portfolio of mortgage loans in foreign currencies may not be fully recoverable or there may occur a liability resulting in future cash outflow. Therefore, the Bank recognised provisions for individual cases and for the portfolio of foreign currency mortgage loans in connection with the related legal risk.

Based on the current practice, the Bank intends to monitor changes in the market approach and continue the existing practice, including with regard to making settlements, which is considered as the primary scenario. It is assumed that the effects of the expected judgment of the Supreme Court will not have a significant impact on the estimated amount of the Bank’s provision for the portfolio of foreign currency mortgage loans.

For details on the amount of provisions for litigation and legal risks see Note 32 “Provisions”.

Management fee income

The Bank accounts for income from fees related to programme management as part of commissioned activities as required by IFRS 15. In order to create a fee allocation key, the Bank uses an input method, where the estimation of the appropriate level of satisfaction of a performance obligation under a given management agreement requires the application of appropriate estimates throughout the programme period (fees to be received, costs to be incurred, deviation of the actual amounts of income/costs from prior forecast). The Bank updates its estimates at least each six months.

Deferred tax assets

The Group recognises deferred tax assets based on the assumption that it will generate taxable profit sufficient to realise the assets in the future. If the actual tax results were to deteriorate in the future, the above assumption might prove baseless.

2.5. Significant accounting policies

2.5.1 Presentation of the statement of financial position and the statement of profit or loss of the parent entity

Apart from own activities, the parent entity carries out commissioned activities, as part of which it operates:

§ flow funds created, entrusted or transferred to BGK under separate legislation, whose statements of financial position and statements of profit or loss (not audited by a qualified auditor) are presented as appendices to BGK’s separate financial statements (“Funds”):

- Inland Waterways Fund;

- National Road Fund;

- Railway Fund;

- Thermal Modernisation and Refurbishment Fund;

- Student Loan Fund;

- Subsidy Fund;

- Borrower Support Fund;

- National Guarantee Fund;

- Polish Science Fund;

- COVID-19 Response Fund;

- Interest Subsidy Fund;

- Liquidity Guarantee Fund;

- Tourist Refund Fund,

§ social and economic programmes, as well as programmes of local governments and regional development supported by public funds, including EU funds (“Programmes”).

For detailed information on the parent entity’s commissioned activities see the Report of the Management Board on the Activities of the BGK Group in 2020.

In the statement of financial position, the parent entity presents own activities and that part of commissioned activities which is treated as its assets and liabilities under IFRS. In the case of the Funds, these include the parent entity’s receivables from or liabilities to such Funds resulting from mutual settlements (the Fund’s cash flows are carried out through the Bank). As for the Programmes, these include in particular cash transferred to the parent entity to designated bank accounts.

The parent entity’s statement of profit or loss presents revenue and costs related to own activities and does not include revenue and costs of Funds and Programmes, except for costs incurred by the parent entity for the purpose of management of commissioned activities and revenue obtained as remuneration for such management.

Presentation changes related to the Inland Waterways Fund

The Act on Financial Support of Inland Shipowners, the Inland Waterways Fund and the Reserve Fund of 31 July 2019 (Journal of Laws of 2019, item 1901), repealing the Act on the Inland Waterways Fund and the Reserve Fund of 28 October 2002, entered into force on 9 November 2019.. Before the effective date of the act, the assets and liabilities of the Inland Waterways Fund had been recognised in the Bank’s statement of financial position, while the Fund’s revenue and costs were recognised in the Bank’s statement of profit or loss. Once the act referred to above has become effective, the parent entity does not bear the risk of lending activities of the Inland Waterways Fund, thus as at 31 December 2019 it has derecognised assets and liabilities of the Inland Waterways Fund from the statement of financial position and its revenue and costs from the statement of profit or loss. The net profit of the Inland Waterways Fund earned in 2019 until the date of the Fund’s reclassification was entirely allocated for the increase of the Inland Waterways Fund. As a result, from 2019 and for 2020 the parent entity presents financial data of the Inland Waterways Fund in a way similar to other Funds.

2.5.2 Consolidation principles

Subsidiaries

These financial statements comprise the financial statements of the parent entity and the financial statements of its subsidiaries, prepared for the year ending 31 December 2020. The accounting policies applied by the subsidiaries are in line with PAS.

Subject to adjustments made to ensure compliance with IFRS, the financial data of the consolidated subsidiaries are prepared for the same reporting period as the financial statements of the parent entity with accounting policies consistently applied to economic events and transactions of a similar nature.

Subsidiaries are consolidated in the period from the date when the parent entity assumes control of those entities, until the date when control is no longer exercised. It is assumed that the parent entity controls an investee if and only if the parent entity:

§ exercises power over the investee, and

§ is exposed, or has rights, to variable returns from its involvement with the investee, and

§ has the ability to use its power over the investee to affect the amount of its returns.

If the facts and circumstances indicate that at least one of the aforesaid three elements of control has changed, the Group has to reassess whether or not it still controls the entity. When assessing whether or not the parent entity has control over an investee if it holds less than the majority of voting rights in that investee, the parent entity considers other facts and circumstances to determine whether or not it has power over that investee, with particular focus on the contractual arrangements between the Group and other holders of voting rights, rights resulting from other contractual arrangements, voting rights held by the Group as well as potential voting rights.

In the financial statements:

§ similar items of assets, liabilities, equity, income, expenses and cash flows of the parent entity and its subsidiaries are aggregated,

§ the carrying amount of the parent entity’s investment in each subsidiary and the parent entity’s portion of equity of each subsidiary is set off (eliminated),

§ intra-group assets and liabilities, equity, income, expenses and cash flows resulting from transactions between the Group entities are eliminated in whole.

Associates

An associate is an entity over which the Group has significant influence, i.e. the power to participate in decisions about the financial and operating policy of the investee, which does not involve control or joint control of those policies.

The financial statements of associates and of the parent entity are prepared for the same reporting period.

In these financial statements, associates are accounted for using the equity method. Before calculating the share in net assets of associates, relevant adjustments are made to ensure compliance of the associates’ financial information with IFRSs applied by the parent entity.

These financial statements present the Group’s share of profit or loss of associates determined by reference to its interest in their equity, from the date when significant influence begins to be exercised to the date when it expires. If the Group’s share of loss of an associate exceeds the value of interest in that associate, the carrying amount is reduced to zero. At that point, no additional losses are recognised, except those resulting from the Group’s assumption of legal or constructive obligations or from a payment made on behalf of an associate.

2.5.3 Foreign currencies

Functional and presentation currency

The Polish złoty is the functional currency (the currency of the primary economic environment where the Group operates) of the parent entity and other entities presented in these financial statements, except for Fundusz Ekspansji Zagranicznej FIZ AN and the Three Seas Initiative Investment Fund.

EUR is the functional and presentation currency of Fundusz Ekspansji Zagranicznej FIZ AN and its investments in Esotiq Germany GmbH, UAB EMP Recycling, ASM Germany GmbH, Recat GmbH, G+M GmbH and the Three Seas Initiative Investment Fund. USD is the functional and presentation currency of Fundusz Ekspansji Zagranicznej FIZ AN’s investment in Elemental USA Inc.

Translation of financial data of the Group entities

Assets and liabilities and equity relating to the investment in Fundusz Ekspansji Zagranicznej FIZ AN, as recognised in these financial statements, were translated from the euro, i.e. the functional currency of the Fund, into the Polish złoty at the following exchange rates:

§ translation of on-balance-sheet items as at 31 December 2020 – the mid exchange rate quoted by the National Bank of Poland as at 31 December 2020, i.e. 4.6148, except for retained earnings/accumulated loss which employs an arithmetic mean of the mid-market rates as at the last day of each month in which the Fund carried out activity,

§ translation of items of the statement of profit or loss for 2020 – the arithmetic mean of the mid exchange rates quoted by the National Bank of Poland as at the last day of each month, i.e. January–December 2020: 4.4742.

Foreign exchange gains or losses on the measurement of the Fund are recognised in other comprehensive income.

Translation of foreign currency items

Foreign exchange gains (losses) arising from the settlement of transactions and the accounting measurement of monetary assets and liabilities denominated in foreign currencies are recognised in profit or loss.

Foreign exchange gains (losses) arising from translation of equity instruments classified as financial assets measured at fair value through other comprehensive income are recognised in other comprehensive income.

At the end of each reporting period:

§ foreign currency monetary items are translated at the closing rate,

§ non-monetary items that are measured in terms of historical cost in a foreign currency are translated using the exchange rate at the date of the transaction,

§ non-monetary items measured at fair value in a foreign currency are translated using the exchange rates at the date when the fair value was measured.

Assets and liabilities, and off-balance-sheet liabilities in foreign currencies and indexed to a foreign exchange rate are measured at the mid- exchange rate quoted for a given currency by the National Bank of Poland as at the reporting date.

Mid- exchange rates of selected foreign currencies relative to the Polish złoty:

Currency	31 Dec 2020	31 Dec 2019
EUR	4.6148	4.2585
GBP	5.1327	4.9971
USD	3.7584	3.7977
CHF	4.2641	3.9213

2.5.4 Cash and cash equivalents

Cash and cash equivalents include cash in hand and in nostro account at the National Bank of Poland as well as cash in the current accounts in banks and other cash with original maturity of up to 3 months. These assets are recognised at nominal value.

2.5.5 Financial assets and financial liabilities

2.5.5.1 Initial recognition

The Group recognises a financial asset or a financial liability in its statement of financial position when, and only when, it becomes party to the contractual provisions of the financial instrument.

2.5.5.2 Classification and measurement

Classification of financial assets that are not equity instruments

The Group classifies financial assets that are not equity instruments to one of the following categories:

1) financial assets at amortised cost;

2) financial assets at fair value through other comprehensive income;

3) financial assets at fair value through profit or loss, including:

§ obligatorily measured at fair value through profit or loss,

§ irrevocably designated as at fair value through profit or loss at initial recognition.

Financial assets at amortised cost

The Group classifies financial assets that are not equity instruments to this category, if:

1) the asset is held within a business model whose objective is to hold financial assets in order to collect contractual cash flows, and

2) the contractual terms of the financial asset give rise on specified dates to cash ﬂows that are solely payments of principal and interest on the principal amount outstanding (SPPI – solely payments of principal and interest).

Financial assets classified in this category are measured at amortised cost with the use of the effective interest rate method and taking into account allowances for expected credit losses. Amortised cost is determined with regard to a discount or a premium as well as fees, charges and transaction costs, which form an integral part of the effective interest rate. The effect of measurement is recognised under “Interest income” in the statement of profit or loss. Loss allowance for expected credit losses are recognised in the statement profit or loss under “Net impairment losses and provisions”.

The financial assets at amortised cost category includes primarily: loans and advances to customers, securities, amounts due from banks, and reverse repurchase agreements.

Financial assets at fair value through other comprehensive income

The Group classifies financial assets that are not equity instruments to this category, if:

a) the asset is held within a business model whose objective is achieved by both collecting contractual cash flows and selling financial assets, and

b) the contractual terms of the financial asset give rise on specified dates to cash ﬂows that are solely payments of principal and interest on the principal amount outstanding.

Changes in fair value are recognised in other comprehensive income until an asset is removed from the statement of financial position, at which time accumulated gains (losses) are recognised in profit or loss. The revaluation reserve is recognised in profit or loss when the asset is sold.

For financial assets classified in this category the Bank determines allowances for expected credit losses, which are recognised under other comprehensive income in correspondence with the statement of profit or loss. Allowances for expected losses do not adjust the carrying amount of financial assets measured at fair value through other comprehensive income.

Interest income and a discount or a premium related to debt instruments are deferred – with the use of an effective interest rate and recognised in net interest income as “Interest income”.

Quoted market prices based on which the fair value of government debt instruments is measured are obtained from widely available information systems. Where no quoted market prices are available for a given debt instrument (e.g. municipal bonds, corporate bonds), the fair value is not determined on the basis of the quoted market prices but using the NPV technique (net present value of future cash flows). The present value is calculated by reference to market yield curves obtained from widely available information systems (zero-coupon yield curves or curves based on the yield on government debt instruments are used, depending on the instrument type). For non-government debt instruments, the present value of future cash flows is determined considering the issuer credit risk and the liquidity risk spread.

The financial assets at fair value through other comprehensive income measurement category includes in particular: securities, i.e. treasury bills, and municipal and corporate bonds.

Financial assets at fair value through profit or loss

The Group classifies the following items as financial assets at fair value through profit or loss:

1) derivative financial instruments;

2) securities held for trading;

3) securities not held for trading whose objective is achieved by selling financial assets;

4) securities which are obligatorily classified to this category;

5) financial assets, including securities, which were designated to this category at initial recognition, if doing so eliminates or significantly reduces a measurement or recognition inconsistency that would otherwise arise from measuring assets or liabilities or recognising the gains and losses on them on different bases.

Equity instruments

The Group classifies equity instruments:

1) to financial assets (securities) at fair value through profit or loss, or

2) to financial assets (securities) at fair value through other comprehensive income, provided that:

§ they are not held for trading,

§ they are not contingent consideration recognised by the Group in a business combination.

Changes in fair value and any other items (e.g. dividend, gains/losses on sales) for equity instruments classified in the financial assets at fair value through profit or loss measurement category are recognised in the statement of profit or loss.

The Group classifies in the fair value through other comprehensive income measurement category those equity instruments, which are not held for sale and are held as a long-term commitment related to the implementation of the parent entity’s strategy, implementation of government economic programmes or access to infrastructure which is material for the parent entity. The Group may make such classification only at initial recognition of an asset in the accounting books and cannot subsequently reclassify the asset to other category.

A change in the fair value of equity instruments classified in the financial assets at fair value through other comprehensive income measurement category is recognised in other comprehensive income.

Only dividend is recognised in the statement of profit or loss. Changes in the fair value of such equity instruments will never be reclassified to profit or loss (including upon disposal).

Business models

The Group identifies the following business models for holding financial assets:

§ holding financial assets to collect cash flows,

§ holding financial assets to collect cash flows and sell the financial assets,

§ selling financial assets.

Business models are determined at a level that reflects how groups of financial assets are managed together to achieve a particular business objective.

The Group accepts a sales transaction as consistent with the assumptions of the holding financial assets to collect cash flows model, if:

§ the sales resulted from an increase in the credit risk and were aimed at minimising potential credit losses due to credit deterioration, or

§ the sales were made close to maturity and the proceeds from the sales approximate the collection of the remaining contractual cash flows, or

§ the sales are infrequent, or

§ sales are insignificant in value, both individually and in aggregate.

The condition of infrequent sales is deemed fulfilled if not more than 1% (by volume) of all transactions out of a portfolio are sold in a given year.

The condition of sales insignificant in value is deemed fulfilled if not more than 5% (by value) of all transactions out of a portfolio are sold in a given year.

Assessment of the nature of cash flows

For the purposes of the assessment of the nature of collected cash flows (SPPI test) the Group defines:

§ capital as the fair value of a financial instrument at initial recognition,

§ interest as a reflection of the time value of money and the credit risk associated with the nominal value of a financial instrument in a given period, as well as margin, liquidity risk and administrative costs.

The SPPI test consists in verifying whether the contractual terms of the financial asset give rise on specified dates to cash ﬂows that are solely payments of principal and interest on the principal amount outstanding. In particular, the following conditions are assessed:

§ contingent events that affect the amount of the cash flows,

§ financial leverage,

§ terms of prepayment or extension of financing,

§ terms limiting the right to seek legal claims to the collected cash flows,

§ terms modifying the consideration for a change in the time value of money.

The assessment of the terms modifying the change in the time value of money is performed based on a qualitative or quantitative analysis.

Where a qualitative assessment does not make it possible to confirm the conclusion that the SPPI test has been passed, it is necessary to perform an assessment of the impact of the modified time value of money element. The objective of such assessment is to determine how different the contractual undiscounted cash flows could be from the undiscounted cash flows that would arise if a given agreement would not provide for a modified time value of money element. If the analysed cash flows are significantly different, the assessed asset is obligatorily classified to fair value through profit or loss measurement category, because the SPPI test has not been passed, i.e. the contractual terms result in the fact that the contractual cash flows are not solely payments of principal and interest on the principal amount outstanding.

Financial liabilities

The Group classifies all financial liabilities as measured at amortised cost, except for:

1) derivative instruments which are liabilities;

2) financial liabilities at fair value through profit or loss;

3) financial guarantee contracts, which after initial recognition the Group (as an issuer of such a contract) subsequently measures at the higher of:

§ the amount of the allowance for expected credit losses, and

§ the fair value less, when appropriate, the cumulative amount of income recognised (settled amount of commission).

2.5.5.3 Reclassification

Reclassification of financial assets occurs only when the business model for managing financial assets is changed. In such an event, the asset is reclassified into a given category in accordance with the new business model.

Upon reclassification:

§ of a financial asset out of the amortised cost measurement category and into the fair value through profit or loss measurement category, its fair value is measured at the reclassification date. Any gain or loss arising from a difference between the previous amortised cost of the financial asset and fair value is recognised in the statement of profit or loss,

§ of a financial asset out of the fair value through profit or loss measurement category and into the amortised cost measurement category, its fair value at the reclassification date becomes its new gross carrying amount,

§ of a financial asset out of the amortised cost measurement category and into the fair value through other comprehensive income measurement category, its fair value is measured at the reclassification date. Any gain or loss arising from a difference between the previous amortised cost of the financial asset and fair value is recognised in other comprehensive income,

§ of a financial asset out of the fair value through other comprehensive income measurement category and into the amortised cost measurement category, the financial asset is reclassified at its fair value at the reclassification date. The cumulative gain or loss previously recognised in other comprehensive income is removed from equity and adjusted against the fair value of the financial asset at the reclassification date. As a result, the financial asset is measured at the reclassification date as if it had always been measured at amortised cost,

§ of a financial asset out of the fair value through profit or loss measurement category and into the fair value through other comprehensive income measurement category, the financial asset continues to be measured at fair value and the effect of measurement is recognised in other comprehensive income,

§ of a financial asset out of the fair value through other comprehensive income measurement category and into the fair value through profit or loss measurement category, the financial asset continues to be measured at fair value. The cumulative gain or loss previously recognised in other comprehensive income is reclassified from equity to profit or loss.

2.5.5.4 Modification of financial assets

A substantial modification of contractual cash flows related to a financial asset results in derecognition of the asset and recognition of a (new) modified financial asset.

The Group considers a modification as substantial when one of the following criteria is met:

1) quantitative criteria:

§ extension of the credit duration by more than one year and more than twofold extension of the period remaining until the original maturity date (when both these conditions are met jointly),

§ increase in the amount of credit by at least 50%,

2) qualitative criteria:

§ redenomination of the loan,

§ assumption of debt (change of borrower),

§ change in terms resulting in a change of the SPPI test result,

§ change of funded assets where the purpose of the loan is changed.

A non-substantial modification of contractual cash flows related to a financial asset does not result in derecognition of the asset. In such situation the Group recalculates the gross carrying amount of the financial asset and recognises a modification gain or loss in profit or loss.

The modification is treated as a change in estimates if the change in cash flows related to a financial asset results from existing contractual terms and it is solely related to the exercise by a customer of an available option.

2.5.5.5 Impairment

The Group measures and recognises an allowance for expected credit losses on financial assets that are not equity instruments, which are:

1) measured at amortised cost;

2) measured at fair value through other comprehensive income;

3) contract assets or loan commitments and financial guarantee contracts.

A financial asset is credit-impaired when one or more events that have a detrimental impact on the estimated future cash flows of that financial asset have occurred.

Evidence of impairment

Evidence that a financial asset is credit-impaired includes observable data about one or more of the following events:

1) significant financial difficulty of the issuer or the borrower;

2) a breach of contract, such as a default or non-payment;

3) the parent entity or other lender of the borrower, for economic or contractual reasons relating to the borrower’s financial difficulty, having granted to the borrower a concession that the lender would not otherwise consider;

4) it is becoming probable that the borrower will enter bankruptcy or other financial reorganisation;

5) the disappearance of an active market for a given financial asset due to financial difficulties;

6) the purchase or origination of a financial asset at a deep discount that reflects the incurred credit losses.

Measurement of allowances for expected credit losses

The Group measures an allowance for expected credit losses on financial assets in the following manner:

1) at an amount equal to 12-month expected credit losses (Stage 1) – if the credit risk on a financial instrument has not increased significantly since initial recognition; for such assets impairment is measured as 12-month expected credit losses;

2) at an amount equal to lifetime expected credit losses (Stage 2) – if the credit risk on that financial instrument has increased significantly since initial recognition (whether assessed on an individual or portfolio basis) – considering all reasonable and supportable information, including that which is forward-looking. For such assets the impairment loss is measured as lifetime expected credit losses;

3) at an amount equal to accumulated changes in lifetime expected credit losses from their initial recognition (Stage 3) – for impaired financial assets, for which impairment will be measured as lifetime expected credit losses.

The classification of financial assets to three stages and the determined impairment calculation method affect the recognition of interest income. Interest income on financial assets classified to Stages 1 and 2 are determined based on gross exposures (amortised cost of a financial asset, before adjustment for any allowances for expected credit losses) using the effective interest method. For Stage 3 assets – based on the amortised cost of those assets.

POCI assets comprise a separate category of financial assets. They are purchased or originated financial assets which at initial recognition are impaired due to a credit risk. Interest income on POCI assets is calculated based on net carrying amount using the effective interest rate adjusted for the credit risk recognised for the entire useful life of the asset.

Recognition of allowances for expected credit losses

Allowances for expected credit losses on financial assets at amortised cost adjust the carrying amount of the relevant asset and are recognised in profit or loss.

Allowances for expected credit losses on financial assets at fair value through other comprehensive income are recognised in other comprehensive income in correspondence with the profit or loss. Such loss allowances do not adjust the carrying amount of financial assets, because the assets are recognised at fair value.

Allowances for expected credit losses on trade receivables

The Group applies the simplified method of measurement of allowances for expected credit losses on trade receivables. The loss allowance is calculated based on fixed indicators dependent on actual payment default.

2.5.5.6 Derecognition of financial assets and financial liabilities from the statement of financial position

The Group derecognises a financial asset when, and only when:

1) the contractual rights to the cash flows from the financial asset expire, or

2) it transfers the financial asset.

While transferring a financial asset, the Group evaluates the extent to which it retains the risks and rewards of ownership of the financial asset. In this case:

1) if the Group transfers substantially all the risks and rewards of ownership of the financial asset, it derecognises the financial asset and separately recognises as assets or obligations all the rights and obligations arising or maintained as a result of transfer;

2) if the Group retains substantially all the risks and rewards of ownership of the financial asset, the entity continues to recognise the financial asset;

3) if the Group neither transfers nor retains substantially all the risks and rewards of ownership of the financial asset, it determines whether it has retained control of the financial asset. In that event:

§ if the Group has not retained control, it derecognises the financial asset and recognises separately as assets or liabilities any rights and obligations created or retained in the transfer,

§ if the Group has retained control, it continues to recognise the financial asset to the extent of its continuing involvement in the financial asset.

Upon derecognition of a financial asset in whole, the difference between the carrying amount (measured at the date of derecognition) and the consideration received (including any new asset obtained less any new liability assumed) is recognised in profit or loss.

The Group derecognises a financial liability (or its part) from its statement of financial position when the obligation specified in the contract is discharged or cancelled or expires.

2.5.6 Fair value measurement

The fair value of a financial asset, financial liability or off-balance-sheet liabilities is measured using the assumptions that market participants would use when pricing the asset or liability, assuming that market participants act in their economic best interest.

Determination of fair value is based on the following assumptions:

1) the financial asset or liability is exchanged in an orderly transaction between market participants to sell the financial asset or transfer the financial liability at the measurement date under current market conditions;

2) the sale of the financial asset or transfer of the financial liability is made:

§ in the principal market for the financial asset or liability; or

§ in the absence of a principal market, in the most advantageous market for the financial asset or liability.

When a quoted price for the transfer of an identical or a similar financial liability is not available and the identical item is held by another party as a financial asset, the Group measures the fair value of the liability from the perspective of a market participant that holds the identical item as a financial asset at the measurement date.

When a quoted price for the transfer of an identical or a similar financial liability is not available and the identical item is not held by another party as a financial asset, the Group measures the fair value of the liability using a valuation technique from the perspective of a market participant that owes the financial liability.

The Group uses valuation techniques that are appropriate in the circumstances and for which sufficient data are available to measure fair value, maximising the use of relevant observable inputs and minimising the use of unobservable inputs.

Inputs for valuation techniques designed to determine the fair value of financial assets and liabilities are classified into three levels:

1) Level 1 inputs are quoted prices (unadjusted) in active markets for identical financial assets or liabilities that the Group can access at the measurement date;

2) Level 2 inputs are inputs other than quoted prices in active markets, that are observable, either directly or indirectly. Such inputs include in particular, the following:

§ quoted prices for similar financial assets or liabilities in active markets,

§ quoted prices for identical or similar financial assets or liabilities in markets that are not active,

§ observable inputs other than quoted prices, in particular: interest rates and yield curves observable at commonly quoted intervals, implied volatilities and credit spread, or market-corroborated inputs;

3) Level 3 inputs are unobservable inputs reflecting the assumptions that market participants would use when pricing financial assets or liabilities, including assumptions about risk.

If a quoted price in an active market is not available, the Group determines the fair value of financial assets or liabilities by applying valuation techniques incorporating all factors that market participants would consider in setting a price, which are consistent with accepted economic methodologies for pricing financial instruments.

2.5.7 Repurchase and reverse repurchase transactions

Repo and sell-buy-back as well as reverse repo and buy-sell-back transactions are transactions involving the sale or purchase of securities with a commitment to repurchase or resell the security at an agreed date and at an agreed price.

Financial assets sold with a commitment to buy them back (repo and sell-buy-back transactions) are recognised by the Group in the statement of financial position, with liabilities arising from the commitment to buy the securities back as a corresponding item of liabilities. Such a solution is possible only where the Group retains the risks and rewards of ownership of the financial asset despite its transfer. For transactions involving the purchase of securities with a commitment to resell them (reverse repo and buy-sell-back), the financial assets held are presented as receivables arising from the repurchase clause.

Reverse repurchase agreements and liabilities due to repurchase agreements are measured at amortised cost. The difference between the sale/purchase and repurchase/resale price is treated as interest expense or income and deferred over the term of agreement. Securities in repo and sell-buy-back transactions are not derecognised from the statement of financial position and are measured using the principles applicable to the relevant categories of financial assets.

2.5.8 Derivatives

Derivative financial instruments and forward and futures transactions with a symmetrical risk profile are measured using the NPV technique (net present value of future cash flows). The present value of future cash flows is measured for each transaction based on properly constructed projection and discount curves. Projection curves are built based on quoted prices of deposits, FRA, IRS and basis swap rates appropriate for a given currency and the reference rate. Discount curves are built based on quoted prices of deposits, FRA and IRS rates, business swaps, currency swap basis, as well as swap points. OIS transactions are measured using a curve based on OIS rates in the transaction currency. Quoted market prices for curve building purposes are obtained from widely available information systems. Instruments denominated in a currency other than the Polish złoty are measured by reference to the mid- exchange rate quoted by the National Bank of Poland for the measurement date.

Transactions with an asymmetrical risk profile (option transactions) are measured using Black-Scholes and Bachelier models, which are widely used on the market and rely on the implied (if quoted market prices are available) or historical volatilities (determined with the use of statistical models based on quoted market prices).

The fair value of financial instruments reflects the credit risk. In the case of debt instruments, a liquidity margin and a margin for the issuer’s credit risk is applied. For derivatives, the credit value adjustment (CVA) and the debit value adjustment (DVA) are calculated.

In these financial statements, derivatives are presented on a net basis at the transaction level (positive fair values as assets and negative fair values as liabilities).

2.5.9 Hedge accounting

As of 2020, the Group permits the application of fair value and cash flow hedge accounting in accordance with IFRS 9.

The Group may apply hedge accounting for the following hedging relationships:

1) fair value hedge;

2) cash flow hedge.

For hedge accounting purposes, the Group designates hedging instruments so that a change in their fair value or cash flows covers, in whole or in part, the change in the fair value or future cash flows of the hedged item.

Fair value hedges are accounted for as follows:

1) the gain or loss on the hedging instrument is recognised in profit or loss (or other comprehensive income, if the hedging instrument hedges an equity instrument for which the Group has elected to present changes in fair value in other comprehensive income);

2) the hedging gain or loss on the hedged item adjust the carrying amount of the hedged item (if applicable) and are recognised in profit or loss. If the hedged item is a financial asset (or a component thereof) that is measured at fair value through other comprehensive income, the hedging gain or loss on the hedged item is recognised in profit or loss. However, if the hedged item is an equity instrument for which the Group has elected to present changes in fair value in other comprehensive income, those amounts remain in other comprehensive income. When a hedged item is an unrecognised firm commitment (or a component thereof), the cumulative change in the fair value of the hedged item subsequent to its designation is recognised as an asset or a liability with a corresponding gain or loss recognised in profit or loss.

Cash flow hedges are accounted for as follows:

1) the separate component of equity associated with the hedged item (cash flow hedge reserve) is adjusted to the lower of the following (in absolute amounts):

§ the cumulative gain or loss on the hedging instrument from inception of the hedge; and

§ the cumulative change in fair value (present value) of the hedged item (i.e. the present value of the cumulative change in the hedged expected future cash flows) from inception of the hedge;

2) the portion of the gain or loss on the hedging instrument that is determined to be an effective hedge (i.e. the portion that is offset by the change in the cash flow hedge reserve calculated in accordance with 1)) is recognised in other comprehensive income;

3) any remaining gain or loss on the hedging instrument (or any gain or loss required to balance the change in the cash flow hedge reserve calculated in accordance with 1)) is hedge ineffectiveness that is recognised in profit or loss.

The Group discontinues hedge accounting only when the hedging relationship (or a part of a hedging relationship) ceases to meet the qualifying criteria (after taking into account any rebalancing of the hedging relationship, if applicable). This includes instances when the hedging instrument expires or is sold, terminated or exercised, as well as a situation where there is a change in the risk management objective referring to the risk management objective specified in the documentation of the hedging relationship.

If fair value hedge accounting is discontinued, any adjustments arising from the fair value hedge accounting are amortised to profit or loss if the hedged item is a financial instrument (or a component thereof) measured at amortised cost. Amortisation may begin as soon as an adjustment exists, but no later than when the hedged item ceases to be adjusted for hedging gains and losses. The amortisation is based on a recalculated effective interest rate at the date that amortisation begins. In the case of a financial asset (or a component thereof) that is a hedged item and that is measured at fair value through other comprehensive income, amortisation applies in the same manner but to the amount that represents the cumulative gain or loss previously recognised in accordance with these rules instead of by adjusting the carrying amount.

When hedge accounting for a cash flow hedge is discontinued, if the hedged future cash flows are still expected to occur, that amount remains in the cash flow hedge reserve until the future cash flows occur or until a cumulative loss occurs in the cash flow hedge reserve and the Group expects that all or a portion of that loss will not be recovered in one or more future periods. When future cash flows occur, the amount is reclassified to profit or loss as a reclassification adjustment in the same period or periods during which the hedged expected future cash flows affect profit or loss.

In the period from 1 January to 31 December 2020, the Group did not designate any hedging relationships.

2.5.10 Investments in associates

The Bank accounts for investments in associates using the equity method.

The impact of the COVID-19 pandemic on estimated impairment losses on investments in associates and other investments is described in Note 53.

2.5.11 Property, plant and equipment, intangible assets

Property, plant and equipment

Property, plant and equipment (PPE) includes controlled fixed assets and expenditure on their development. These are assets of an estimated useful life exceeding one year, which are held for internal use or to be leased to third parties under a lease agreement, or for administrative purposes. Property, plant and equipment is recognised at historical cost less depreciation and impairment allowances.

Historical cost includes the cost of acquisition/construction of an asset and expenses directly related to its acquisition and bringing it to a working condition.

Intangible assets

An intangible asset is an identifiable non-monetary asset without physical substance. At initial recognition, intangible assets are measured at cost, and their value is subsequently decreased by accumulated amortisation and impairment allowances, if any.

Intangible assets of the Group include assets with an estimated useful life of over one year, in particular: copyrights, licences.

Depreciation charges related to property, plant and equipment and amortisation charges related to intangible assets

Depreciation and amortisation apply to all items of non-current assets whose value is reduced as a result of their use over their estimated useful lives.

Each part of an item of property, plant and equipment with a cost that is significant in relation to the total cost of the item is depreciated separately.

Items of property, plant and equipment and intangible assets are depreciated/amortised over their useful lives, starting from the first day of the month following immediately the month when the item was made available for use.

Depreciation and amortisation periods for groups of property, plant and equipment and intangible assets, as applicable at the Group:

Property, plant and equipment	Periods
Buildings, premises, cooperative rights to premises	between 40 and 50 years
Leasehold improvements (to buildings and premises)	between 2 and 13 years
Machines, technical equipment, tools and devices	between 2 and 18 years
Computer sets	between 4 and 8 years
Vehicles	5 years

Intangible assets	Periods
Software	between 2 and 14 years
Other intangible assets	between 2 and 10 years

The residual value and the useful life are reviewed on an annual basis and adjusted if necessary.

Impairment of property, plant and equipment and intangible assets

The Group assesses whether there is any evidence of impairment of any non-financial non-current assets. The Group estimates the recoverable amount as the fair value less cost of sale or the value in use of such assets (whichever is higher), if such evidence is identified. Impairment allowances are recognised where the carrying amount of the asset exceeds its recoverable amount.

2.5.12 Investment property

Investment property is a property (land or a building – or part of a building – or both) held to earn rentals or for capital appreciation or both. At the same time, such property:

§ is occupied by the Group only to an inconsiderable extent,

§ is not intended for sale in the ordinary course of the Group’s business.

Initially, investment property is recognised at cost. After initial recognition, its value is measured in the fair value model. Any gains or losses resulting from changes in its value are recognised in the statement of profit or loss for the period. Valuation services are provided by independent property appraisers.

2.5.13 Leases

The Group as a lessor

The Group is a party to lease agreements whereby it grants investment property for a fee for an agreed period of time. In the case of leases which transfer substantially all risks and rewards incidental to the ownership of an underlying asset (financial lease), the leased asset is derecognised from the Group’s statement of financial position, but the Group recognises a receivable in an amount equal to the present value of lease payments. Lease payments under agreements which do not qualify as finance leases are treated as operating leases and are recognised as revenue in the statement of profit or loss over the lease term, using the straight-line method.

The table below presents information on operating leases concluded by the Group as the lessor:

Operating lease agreements	2020	2019
Total future lease payments under irrevocable operating lease:	130,172	105,027
up to 1 year	52,735	40,925
between 1 and 5 years	35,335	33,276
over 5 years	42,102	30,826

The Group as a lessee

The Group is also party to lease agreements under which it accepts third parties’ property, plant and equipment to use it against consideration or to derive benefits from it over a defined term. They include agreements on lease of property (including perpetual usufruct of land), cars, IT infrastructure and equipment.

The Group uses the right of perpetual usufruct of land, whether acquired for consideration or free of charge. The right of perpetual usufruct of land acquired for consideration (from third parties) is presented as leases under right-of-use assets. The right of perpetual usufruct of land acquired free of charge from the State Treasury is not disclosed in the statement of financial position.

In the case of agreements which are, or contain, a lease, the Group presents right-of-use assets and lease liabilities in the statement of financial position. At initial recognition, right-of-use assets are measured in an amount equal to lease liabilities increased by any lease payments made before the date of initial recognition or any initial direct costs incurred by the Group. Lease liabilities are measured at the present value of the remaining lease payments, discounted using the lessee’s incremental borrowing rate determined as a risk-free interest rate (e.g. T-bond interest rate) for a given agreement term, plus a margin.

The incremental borrowing rates applied to lease liabilities in 2020 stood as follows:

§ for PLN – from 0.56% to 3.79%,

§ for EUR – from 0.26% to 0.54%,

§ for USD – 2.33%,

§ for GBP – 1.42%.

The incremental borrowing rates applied to lease liabilities in 2019 stood as follows:

§ for PLN – from 1.57% to 3.79%,

§ for EUR – from 0.43% to 0.55%,

§ for USD – 3.25%.

The Group applies the exemptions specified in IFRS 16 with regard to short-term leases (up to 12 months) and leases of low-value assets (where the acquisition price of a new asset does not exceed PLN 10 thousand) and does not recognise them as leases.

In determining the lease term, the Group takes into account the non-cancellable period of a lease together with periods covered by an option to extend or terminate the lease. At the commencement date of a lease agreement, the Group assesses whether it is reasonably certain to exercise an extension option, or not to exercise a termination option. To make the assessment, the Group considers all relevant facts and circumstances that create an economic incentive to exercise, or not to exercise, the option. In determining the lease term and assessing the length of the non-cancellable period of a lease, the Group applies the definition of an agreement and determines the period for which the agreement is enforceable. A lease is no longer enforceable when the Group members and the lessor each has the right to terminate the lease without permission from the other party with no more than an insignificant penalty.

In the case of contracts executed for an indefinite term, the Group defines the lease term as a period in which the Group is the most likely to use an asset, taking into account the costs relating to the termination of the lease. If such costs may be considered significant for either party, the lease term covers a period, in which such costs remain significant. The costs

include both financial penalties provided for in the agreement and other non-contractual economic losses (e.g. loss of leasehold improvements undertaken, costs of acquisition of a new lease, such as negotiation costs, relocation costs). If the lessor and the lessee have the right to terminate the agreement without permission of the other party, and if no costs were incurred in connection with a given agreement or there are no costs relating to the termination of the lease, or if such costs are insignificant, the lease term is considered equal to the termination period.

After the commencement date, the Group measures the right-of-use asset at cost less any accumulated depreciation and any accumulated impairment losses and adjusted for any remeasurement of the lease liability. Right-of-use assets are depreciated on a straight-line basis.

The table below presents depreciation periods for major groups of right-of-use assets, as applicable at the Group:

Right-of-use assets	Depreciation periods
Buildings and structures	between 1 and 7 years
Right of perpetual usufruct of land	between 25 and 74 years
Civil engineering structures	3 years
Vehicles	between 2 and 3 years
IT hardware	between 2 and 4 years

After the commencement date, lease liabilities are measured at amortised cost, i.e. taking into account interest accrued on the lease liability less any interest paid and lease payments made, and revised interest in the case of reassessment or change of the lease term or reflecting any change of in-substance fixed lease payments.

For details on right-of-use assets see Note 24. The maturity analysis of liabilities is presented in Note 45.

In accordance with the requirements of IFRS 16 Leases, the Group presents the depreciation charge for right-of-use assets, interest expense on lease liabilities, expenses relating to the use of right-of-use assets, expense relating to short-term leases and expense relating to leases of low-value assets in the statement of profit or loss.

Expense relating to leases incurred in 2020 are presented in the table below:

Amounts relating to leases recognised in statement of profit or loss	2020	2019
Expense relating to leases of low-value assets presented under “General administrative expenses”	2,471	124
Expense relating to short-term leases presented under “General administrative expenses”	107	1,482
Interest expense on lease liabilities	1,037	884
Expense relating to service charges and non-deductible value added tax (VAT) not included in the measurement of lease liabilities	14,713	10,785

As at 31 December 2020, the Group recognised the following impairment of right-of-use assets:

Impairment of right-of-use assets	2020	2019
Property	4,227	0

2.5.14 Other prepayments and deferred expenses

Prepayments are recognised if the expenses pertain to months following the month when they were incurred. Prepayments (recognised in the statement of financial position under “Other assets”) include mainly prepaid expenses and accrued revenue. Prepaid expenses include different types of expenses that will be recognised in profit or loss after the lapse of time, in future reporting periods.

Deferred expenses include costs of services provided to the Group which have not been classified as their liabilities yet. Deferred expenses include expenses to be incurred in the future, including the cost of bonuses, outstanding annual leaves, and jubilee awards.

The Group settles deferred income where it receives payment for services or goods to be provided or delivered in future reporting periods. This in particular comprises deferred commissions and other income collected in advance whose recognition in profit or loss will be effected in future reporting periods.

Deferred expenses and deferred income are disclosed in the statement of financial position in “Other liabilities”.

2.5.15 Provisions

Provisions are liabilities the amount or due date of which are not certain. They are recognised when the Group has a present (legal or constructive) obligation as a result of a past event, while it is probable that an outflow of resources embodying economic benefits will be required to fulfil the obligation and the amount of the obligation can be estimated reliably.

Where the effect of the time value of money is material, the amount of provision is determined by discounting estimated future cash flows to their present value using a pre-tax discount rate that reflects current market assessments of the time value of money and any potential risks specific to the liability.

The Group recognises provisions in particular for litigation and claims with its counterparties, customers and third-party institutions, provisions for legal risk, retirement, disability and post-mortem benefits.

2.5.16 Employee benefits

Short-term employee benefits include benefits due within twelve months from the end of the reporting period, in which employees performed work, in particular salaries, wages, bonuses, paid annual leave, and social security contributions. The Group recognises the estimated undiscounted amount of short-term employee benefits as an expense in the period they concern.

Long-term employee benefits include benefits which are due after 12 months from the end of the reporting period, in which employees performed work, in particular retirement, disability, post-mortem, and jubilee benefits. The relevant provision is measured using actuarial methods by a third-party actuary as the present value of future liabilities to employees considering the payroll and the level of salaries and wages as at the measurement date. Provision for employee benefits is presented under “Provisions” or “Other liabilities” and as other operating income and other operating expenses, as appropriate, or general administrative expenses. A certain amount of provisions for retirement, disability, and post-mortem benefits resulting from changes in actuarial (financial, demographic and other) assumptions made for purposes of measurement is recognised in other comprehensive income.

The parent entity offers a post-employment benefit plan, known as the defined contribution plan, whereby it has a contractual obligation to make specified contributions to an employee pension plan. The fund, which also includes a return on invested contributions, is used for payment of post-employment benefits to employees. As a result, the parent entity is not subject to a legal or constructive obligation to make additional contributions, if the pension fund’s assets are insufficient to finance the benefits.

2.5.17 Contingent liabilities assumed

In the course of operations, transactions are executed which are not recognised in the statement of financial position as assets or liabilities at the conclusion date but result in the occurrence of contingent liabilities. A contingent liability is:

§ a possible obligation that arises from past events and whose existence will be confirmed only by the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of the Group; or

§ a present obligation that arises from past events but is not recognised in the statement of financial position because it is not probable that an outflow of funds or other assets will be required to settle the obligation or the amount of obligation cannot be measured with sufficient reliability.

Off-balance-sheet liabilities granted include mainly credit commitments and guarantee liabilities granted.

At initial recognition, off-balance-sheet liabilities granted are measured at fair value. In subsequent periods, at the reporting date they are measured at an amount of the allowance for expected credit losses in accordance with IFRS 9.

2.5.18 Equity

Classification into the items presented below is made in compliance with the requirements of the Act on Bank Gospodarstwa Krajowego and the Bank’s Articles of Association adopted by way of Regulation of the Minister of Development.

Equity includes:

§ statutory capital,

§ supplementary capital,

§ revaluation reserve (including in particular the value of financial assets at fair value through other comprehensive income, actuarial gains and losses, and gain or loss on investment property revaluation),

§ other capital reserves (including the general banking risk reserve and reserve fund),

§ retained earnings/accumulated loss,

§ net profit (loss) for the period.

Items of equity of the subsidiaries, other than their share capital, to the extent that the parent entity is the owner of the subsidiary, are added to the relevant items of the parent entity’s equity.

The equity of the Group comprise only those parts of equity of subsidiaries which was created after the acquisition of shares or stock by the parent entity.

2.5.19 Income tax

Income tax consists of current tax and deferred tax. Current tax is recognised in the statement of profit or loss or the statement of comprehensive income where a profit or loss is made on equity financial instruments presented in the statement of comprehensive income. Deferred tax, depending on the source of the temporary differences, is recognised in profit or loss or in the statement of comprehensive income.

Current tax

Current tax is a tax liability related to taxable profit and determined using a tax rate in force as at the end of the reporting period.

Deferred tax

The Group recognises deferred tax assets and liabilities. Deferred tax liabilities are the amounts of income taxes payable in future periods in respect of taxable temporary differences. Deferred tax assets are the amounts of income taxes recoverable in future periods in respect of deductible temporary differences, the carryforward of unused tax losses, and the carryforward of unused tax credits. The Group’s deferred tax assets and liabilities are recognised in the statement of financial position as assets or liabilities, as the case may be. A change in the deferred tax liabilities and assets is recognised directly in the statement of profit or loss except for the effects of measurement of financial assets measured at fair value through other comprehensive income, investment property at fair value through other comprehensive income, actuarial gains and losses recognised in other comprehensive income, shares in associates recognised in other comprehensive income, and foreign exchange gains or losses on translating subordinates, in case of which changes in the deferred tax liabilities and assets are also recognised in other comprehensive income. Deferred tax reflected in the statement of profit and loss is measured by reference to the deferred tax assets and liabilities at the beginning and at the end of the reporting period.

The carrying amount of deferred tax assets is reviewed at the end of each reporting period and reduced to the extent that it is no longer probable that future taxable profit will be available against which the deferred tax assets can be realised in whole or in part.

The deferred tax assets and liabilities are measured by reference to tax rates that are expected to apply to the period when the asset is realised or the liability is settled, based on tax rates (and tax laws) in effect at the end of the reporting period or those certain to enter into force in the future as at the end of the reporting period.

With regard to deferred tax the Group entities apply a 19% tax rate, except for entities which, under Article 19.1.2 of the Corporate Income Tax Act, apply a 9% tax rate. The Group offsets deferred tax assets against deferred tax liabilities when, and only when, there is a legally enforceable right to set oﬀ current tax assets against current tax liabilities and when the deferred tax relates to the same income tax levied by the same taxation authority.

Where the Group is a party to lease agreements under which it uses third parties’ property, plant and equipment for which it pays consideration and derives benefits from it over a defined term, thus presents right-of-use assets and lease liabilities in the statement of financial position, it is assumed that the tax value of such assets and liabilities is zero. In such

cases, the Group recognises deferred tax liabilities calculated based on the current carrying amount of right-of-use asset and deferred tax assets calculated based on the current carrying amount of lease liabilities.

2.5.20 Measurement of profit/loss

Interest income and expense

Interest income comprises interest and fees (received or due) taken into account in the calculation of the effective interest rate for, inter alia: loans with agreed repayment schedules, interbank deposits, and financial instruments classified to the fair value through other comprehensive income or profit or loss measurement category.

Interest expense includes interest on, inter alia, current accounts, deposits and securities.

In the case of financial assets for which a Stage 3 allowance for expected credit losses was recognised, the item includes impairment interest adjustment.

Fee and commission income and expense

Bank fee and commission income and expense concern mainly financial services offered by the Group and comprise in particular: commissions on credits granted and guarantee liabilities, costs of securities operations, and management fees as well as costs related to administration and management of funds and programmes. Commissions/fees are settled in the period of transactions, except for fees and commissions on administrative activities which are recognised on a one-off basis in profit or loss. The parent entity’s consideration under fees for services, such as asset management or commissioned activities, is recognised in accordance with IFRS 15 as income in the amount which the Bank expects to receive for the provided services or up to the amount of costs incurred. Depending on the provisions of agreements and data availability, the Bank uses fee allocation keys based on the structure of costs (incurred and forecast) throughout the period of a given programme.

Commission income and expense also include fees, whether received or paid, on financial instruments without an agreed repayment schedule. Fees on overdraft facilities, guarantees granted, and other revolving facilities are deferred and classified as commission income.

In relation to bancassurance products, the parent entity, as the policyholder, offers free-of-charge insurance coverage to credit card holders in the form of an additional card functionality, which is an integral feature of the payment card and does not involve any additional fees on the part of the customer. Payment card insurance costs are deferred and recognised in profit or loss as commissions.

Net gains (losses) on financial instruments at fair value through profit or loss and foreign exchange gains (losses)

Net gains (losses) on financial instruments at fair value through profit or loss comprises gains and losses resulting from changes in the fair value of assets classified as held for trading and those which were designated as at fair value through profit or loss at initial recognition or are obligatorily measured at fair value through profit or loss.

Foreign exchange gains or losses comprise gains or losses, whether realised or not, resulting from the daily measurement of foreign currency assets and liabilities at the mid- exchange rate quoted by the National Bank of Poland (NBP) as at the end of the reporting period. In addition, foreign exchange gains (losses) include the net realised and unrealised gain/loss, including the effects of changes in the measurement related to such derivatives as FX FORWARD, FX SWAP (including swap points), CIRS or FX options.

The item does not include the interest portion of the net gain/loss on interest rate derivatives and swap points on FX derivatives classified in the banking book, which are recognised under interest income and expenses.

Net gains (losses) on investments in financial assets

Net gains (losses) on investments in financial assets comprises gains and losses arising from the sale of financial instruments classified to the portfolio of financial assets at fair value through profit or loss, at fair value through other comprehensive income as well as dividend income. In addition, net gains (losses) on investments in financial assets include gains and losses arising from the derecognition of financial assets measured at amortised cost following the recognition of a substantial modification of cash flows.

Net gains (losses) on modifications

Net gains (losses) on modifications include gains and losses on a non-substantial modification, which did not result in derecognition of an asset from the statement of financial position. Upon a non-substantial modification, the modification gain or loss in a given asset is recognised in the statement of profit or loss and is subsequently amortised until derecognition of the asset from the statement of financial position.

Other operating income and expenses

Other operating income and expenses comprise income and expenses which are not directly related to banking operations. Other operating income includes mainly income from: positive fair value measurement of investment property, bad debt that has been recovered, received damages, penalties, fines, reversal of provisions for litigation and legal claims and other receivables as well as from the sale of property, plant and equipment and investment property.

Other operating expenses include mainly: costs of donations, costs of debt collection, recognition of provisions for litigation and legal claims, legal risk, other amounts due, and the costs of fair-value measurement, cost of maintenance of investment property, and loss allowance.

General administrative expenses

The item includes costs relating to: employee benefits (including payroll, social insurance and training), material costs, depreciation and amortisation (of property, plant and equipment, intangible assets and right-of-use assets) along with taxes and charges.

Net impairment losses and provisions

The item includes increases and decreases related to allowances for expected credit losses on assets at amortised cost (in particular loans and advances, purchased debt and fulfilled guarantees and sureties), the related loan commitments and financial guarantee contracts, subordinates and financial assets at fair value through other comprehensive income.

3. Operating segments

The presentation of information on operating segments is based on the internal management model, division criteria based on client classification and the nature of business of individual segments.

The model for the presentation of segment performance covers all items of the statement of financial position and the statement of profit or loss up to profit before tax. Inter-segment transactions are accounted for as if they were transactions between non-related entities. The segments were assigned direct revenue, internal transfers of interest income based on average balances, market prices depending on currency, maturities and liquidity margins, direct operating expenses and operating expenses allocated using internal allocation models, as well as other items of the statement of profit or loss.

Four operating segments have been identified for the purpose of evaluation of the nature and financial consequences of the operations carried out by the Group entities:

§ Treasury and asset-liability management.

The segment’s assets and liabilities as well as net profit or loss are composed of the following items:

– items related to liquidity, foreign exchange risk and interest rate risk management (including interbank deposits and placements, buy-sell-back and sell-buy-back transactions, transactions in T-bonds and money bills, nostro accounts, the account at the National Bank of Poland, derivatives, FX swaps);

– securities comprising portfolios classified as investment portfolios;

– deposit and derivative services at the request of the Ministry of Finance as well as financing the Parent Entity’s operations in the medium and long term, such as loans obtained from financial institutions and issues of own bonds;

– gain/loss on internal fund transfer pricing settlements with the remaining segments, which is based on percentage rates determined by reference to market rates and rates approved by the Bank’s Asset and Liability Committee, accounting for transaction currency, maturity and liquidity margins.

§ Public sector

The segment identification criterion is based on customer classification for management reporting purposes and the type of business activities. It comprises:

– local government units, central budget entities, and public health care institutions, excluding those items which fall within the scope of Treasury and asset-liability management and are related to deposits and derivatives for the Ministry of Finance;

– the key products generating the segment’s revenue are loans granted, bonds acquired by the Group as well as current accounts and term deposits;

– settlements under commissioned activities related to supporting the State and managing government and EU programmes.

§ Corporate

The segment identification criterion is based on customer classification for management reporting purposes and the type of business activities. It comprises:

– private companies and state-owned enterprises, municipal companies, private health care institutions as well as entities using the support received as part of the parent entity’s export support activities and construction support activities;

– the key products generating the segment’s revenue are corporate loans and investment project finance products (including as part of a consortium with other banks) in the form of loans and issues of non-Treasury securities, sureties and guarantees as well as current accounts and term deposits.

§ Other Activities

The segment comprises:

– the Group’s investing activities, mainly in the form of acquired investment fund certificates (in the consolidated financial statements, certificates issued by funds with the majority interest held by the parent entity are recognised as shares in associates measured with the equity method);

– shares (mainly in subsidiaries) and their effect on the consolidated financial statements, other shares, and investment property;

– and items which are not recognised in any other segment, such as transactions with financial sector entities other than banks or services provided to individuals, which are being discontinued, as well as other non-interest elements of the statement of financial position.

The presentation of segment performance was changed in 2020. The division into four main segments corresponding to 2019 has been retained. The main calculation changes concern internal transfer pricing settlements and allocation rules and specific items assigned to individual segments.

To ensure comparability of performance, note for 2019 has been restated.A

3.1. Selected items of the statement of profit or loss and the statement of financial position

The tables below present data on revenue, costs, and performance of each operating segment of the Bank Gospodarstwa Krajowego Group for 2020 and 2019 as well as assets and liabilities as at 31 December 2020 and 31 December 2019.

Information on operating segments for the year ended 31 December 2020	Continuing operations
	Treasury and asset-liability management	Public sector	Corporate	Other activities	Total Group
Net interest income	256,197	145,785	504,558	44,610	951,150
Net external interest income	245,535	100,919	586,356	18,340	951,150
Net internal interest income/expense*	10,662	44,866	-81,798	26,270	0
Net fee and commission income/expense	-1,390	87,942	167,240	-5,761	248,031
Net gain/loss on financial instruments at fair value through profit or loss and investments in financial assets	197,118	38,757	-28,585	49,632	256,922
Income from banking activities	451,925	272,484	643,213	88,481	1,456,103
Other operating income and expenses	465	-1,259	-320	22,490	21,376
Net gains (losses) on modifications	0	470	2,910	142	3,522
General administrative expenses**	-37,514	-230,227	-218,608	-137,798	-624,147
Net impairment losses and provisions	2,233	25,514	-358,853	-53,796	-384,902
Operating result	417,109	66,982	68,342	-80,481	471,952
Share of profit or loss of associates	0	0	0	-24,968	-24,968
Profit before tax	417,109	66,982	68,342	-105,449	446,984
Income tax					-80,414
Net profit					366,570

* The net internal interest income includes expense/income related to internal fund transfers based on transfer prices determined by reference to market rates and allocation of liquidity margins and revenue from capital.

** General administrative expenses were allocated to each client segment based on the cost of internal services determined in line with the allocation model adopted by the Parent Entity.

Information on operating segments for the year ended 31 December 2019	Continuing operations
	Treasury and asset-liability management	Public sector	Corporate	Other activities	Total Group
Net interest income	136,469	222,964	592,509	1,470	953,412
Net external interest income	275,727	42,092	625,369	10,224	953,412
Net internal interest income/expense*	-139,258	180,872	-32,860	-8,754	0
Net fee and commission income/expense	-1,879	86,999	139,488	-6,011	218,597
Net gain/loss on financial instruments at fair value through profit or loss and investments in financial assets	44,276	19,866	24,008	117,237	205,387
Income from banking activities	178,866	329,829	756,005	112,696	1,377,396
Other operating income and expenses	0	-644	93,353	99,116	191,825
Net gains (losses) on modifications	-190	904	-9,985	100	-9,171
General administrative expenses**	-23,658	-214,510	-208,004	-154,644	-600,816
Net impairment losses and provisions	-1,580	-33,187	-200,220	3,572	-231,415
Operating result	153,438	82,392	431,149	60,840	727,819
Share of profit or loss of associates	0	0	0	-268,622	-268,622
Profit before tax	153,438	82,392	431,149	-207,782	459,197
Income tax					-68,990
Net profit					390,207

* The net internal interest income includes expense/income related to internal fund transfers based on transfer prices determined by reference to market rates and allocation of liquidity margins and revenue from capital.

** General administrative expenses were allocated to each client segment based on the cost of internal services determined in line with the allocation model adopted by the Parent Entity.

Operating segments as at 31 December 2020	Continuing operations
Operating segments as at 31 December 2020	Treasury and asset-liability management	Public sector	Corporate	Other activities	Total Group
Total assets	108,043,903	12,934,319	29,372,811	9,974,506	160,325,539
Total liabilities	39,647,694	31,226,468	49,317,001	16,210,405	136,401,568

Operating segments as at 31 December 2019	Continuing operations
Operating segments as at 31 December 2019	Treasury and asset-liability management	Public sector	Corporate	Other activities	Total Group
Total assets	50,982,132	11,236,027	29,409,995	8,893,086	100,521,240
Total liabilities	24,103,033	26,307,611	24,916,442	6,540,237	81,867,323

3.2. Geography

The Group operates within the territory of the Republic of Poland. Its operations focus on the Polish market.

Notes to the consolidated statement of profit or loss and other comprehensive income

4. Interest income and expense

Interest income	2020	2019
Interest income calculated with the use of the effective interest rate method	1,382,181	2,034,993
Income on financial instruments at amortised cost, including:	972,629	1,357,988
amounts due from banks	41,951	162,191
loans and advances to customers	757,758	1,000,053
debt instruments	172,920	195,744
Income from financial instruments at fair value through other comprehensive income	409,552	677,005
Income of similar nature to interest income on instruments at fair value through profit or loss	126,148	177,338
Income on derivatives	121,861	169,463
Income on financial assets held for trading	323	532
Income on financial assets obligatorily measured at fair value through profit or loss	2,440	4,949
Income on financial assets designated as at fair value through profit or loss	1,524	2,394
Total	1,508,329	2,212,331

Interest expense	2020	2019
Interest expense related to financial instruments at amortised cost, including	516,617	1,205,444
amounts due to banks	39,659	120,953
liabilities to customers	388,060	941,810
issue of debt securities	87,861	141,797
lease liabilities	1,037	884
Interest expense on amounts due from banks	19,904	14,086
Costs of derivatives	20,658	39,389
Total	557,179	1,258,919

5. Fee and commission income and expense

Fee and commission income relates to:	2020	2019
Securities operations	11,916	10,621
Settlements	13,157	13,937
Loans and advances granted	61,587	43,283
Custody activity	1,181	189
Fund and programme management	69,931	63,792
Guarantee commitments	86,373	84,885
Other commissions	16,451	14,772
Total	260,596	231,479

Fee and commission expense relates to:	2020	2019
Commissions on operating services	1,476	2,259
Custody activity	59	28
Brokerage services	3,143	2,434
Settlement activity	2,297	2,653
Fund and programme management	1,160	1,447
Guarantee commitments	368	237
Maintenance of nostro accounts	1,678	1,204
Other commissions	2,384	2,620
Total	12,565	12,882

6. Net gains (losses) on financial instruments at fair value through profit or loss and foreign exchange gains (losses)

Net gains (losses) on financial instruments at fair value through profit or loss and foreign exchange gains (losses)	2020	2019
Gain/loss on financial liabilities designated as at fair value through profit and loss, including:	-1,418	-314
Debt instruments	-1,418	-314
Gain/loss on financial instruments obligatorily measured at fair value through profit or loss, including:	3,187	72,854
Debt instruments	-48,059	1,528
Equity instruments	-11,965	-13,844
Loans and advances	-1,409	-30
Other*	64,620	85,200
Gain/loss on financial instruments held for trading, including:	-6,181	-3,194
debt instruments	987	546
derivatives	-7,168	-3,740
Foreign exchange gains (losses)	119,682	50,344
Total	115,270	119,690

* Relates to investments in Marguerite funds and the Polish Growth Fund of Funds (PGFF)

7. Net gains (losses) on investments in financial assets

Net gains (losses) on investments in financial assets	2020	2019
Sale of debt securities measured at fair value through other comprehensive income	146,894	44,986
Derecognition of financial assets at amortised cost due to modifications	4,465	3,753
Disposal of investments in subsidiaries and associates	1,002	0
Dividend, including:	21	36,958
from issuers of equity instruments designated as at fair value through other comprehensive income	21	36,958
Redemption of investment certificates	-10,730	0
Net gains (losses) on investments in financial assets	141,652	85,697

As regards debt instruments at fair value through other comprehensive income, following the sale of those instruments the Group transferred PLN 146,894 thousand in 2020 from other comprehensive income to profit or loss, compared to PLN 44,986 thousand transferred in 2019.

As regards financial assets at amortised cost, the Bank recognised in profit or loss a PLN 4,465 thousand gain on substantial modification of cash flows (derecognition).

8. Net gains (losses) on modifications

The table below presents the net gain/loss on modification of cash flows related to a financial asset.

	2020	2019
Financial assets at amortised cost	3,522	-9,171
Total	3,522	-9,171

9. Other operating income and expenses

Other operating income	2020	2019
Rental income, including:	59,365	56,389
- rental income from investment property	59,259	56,212
Income on sale or liquidation of property, plant and equipment	2	2,207
Received damages, penalties and fines	79	132
Bad debt collected	12	170
Release of provisions and impairment allowances on other assets*	34,617	93,568
Measurement of investment property at fair value	22,504	73,958
Income on reversal of impairment allowances on intangible assets	245	0
Other income	22,034	9,346
Total	138,858	235,770

* For detailed information see Note 32.

Other operating expenses	2020	2019
Cost of donations, including:	66,192	21,051
- statutory activities of J.K. Steczkowski BGK Foundation	14,000	13,000
Cost of debt collection	2,438	908
Cost of recognition of provisions for litigation and legal claims, other future liabilities	15,278	2,367
Cost of writing off past due and cancelled receivables, bad debt, damages, penalties and fines	11	55
Cost of recognition of impairment allowances on other assets	2,121	747
Cost of discontinued investment projects – investment property	768	364
Cost of recognition of an impairment allowance on right-of-use assets	4,227	0
Cost of investment property	702	817
Disposal of investment property	779	0
Measurement of investment property at fair value	22,659	11,985
Other operating expenses	2,307	5,651
Total	117,482	43,945

10. General administrative expenses

General administrative expenses	2020	2019
Employee benefits	335,757	319,832
Material costs	219,719	227,682
Depreciation and amortisation, including:	48,790	35,285
- property, plant and equipment	15,358	13,843
- intangible assets	10,850	8,299
- right-of-use assets	22,582	13,143
Taxes and charges	19,881	18,017
Total	624,147	600,816

Employee benefits	2020	2019
Salaries and wages	279,559	262,359
Social security	46,670	39,786
Other employee benefits	9,528	17,687
Total	335,757	319,832

11. Net impairment losses and provisions

Net impairment losses and provisions	2020	2019
Amounts due from banks at amortised cost	1,370	-720
Loans and advances to customers at amortised cost	-289,393	-76,711
Debt securities at amortised cost	8,704	-16,360
Debt securities at fair value through other comprehensive income	-1,009	-2,232
Investments in associates	0	-2,765
Provision for contingent liabilities and guarantees granted	-104,574	-132,627
Total	-384,902	-231,415

12. Income tax

Major items of the tax charge and reconciliation of the effective tax rate for the year ending on 31 December 2020 and 31 December 2019:

Items of the tax charge	2020	2019
Current tax charge	-142,146	-153,199
Deferred tax related to occurrence and reversal of temporary differences	61,732	84,209
Income tax in the consolidated statement of profit or loss	-80,414	-68,990
Current income tax presented in other comprehensive income (new recognition)	-357	0
Income tax presented in other comprehensive income and related to occurrence and reversal of temporary differences	10,771	24,752
Tax charge presented in other comprehensive income	10,414	24,752
Total	-70,000	-44,238

Reconciliation of the effective tax rate	2020	2019
Profit before tax	446,984	459,197
Income tax at Poland’s statutory tax rate (19% or 9%)	-84,927	-97,271
Effect of permanent differences between profit before tax and taxable income, including:	4,513	28,281
Non-deductible loss allowance for off-balance-sheet assets and liabilities	-2,519	-1,766
Effect of other differences between profit before tax and taxable income, including donations	-548	-11,602
Other differences	0	-198
Activities exempt from taxation	7,580	41,847
Income tax presented in the statement of profit or loss	-80,414	-68,990
Effective tax rate	17.99%	15.02%

Under Article 17.1.37 and Article 17.1.51 of the Corporate Income Tax Act of 19 February 1992 (Journal of Laws of 2020, item 1406), any income generated by the funds and government programmes is not subject to income tax where it is used for purposes related to their activities. In light of the above, the Bank does not recognise any income tax charge on the profit generated by the funds or government programmes, which applies to the Residential Construction Support Government Programme, Social Rental Housing Government Programme, and Support of Entrepreneurship with BGK Sureties and Guarantees Government Programme, and applied to the Inland Waterways Fund when it was recognised in the Bank’s assets and liabilities.

Deferred tax for the year ending on 31 December 2020 and 31 December 2019 results from the following items:

Deferred tax assets/liabilities	31 Dec 2020	2020	31 Dec 2020	2019	31 Dec 2019	2019
Deferred tax assets/liabilities	Consolidated statement of financial position	Consolidated statement of profit or loss	Consolidated other comprehensive income	Consolidated statement of financial position	Consolidated statement of profit or loss	Consolidated other comprehensive income
Interest accrued on credit exposures	56,180	3,640	0	52,540	45,351	0
Valuation of derivative financial instruments	37,784	21,274	0	16,510	4,205	0
Discount, interest and securities valuation	94,304	-184	6,654	87,834	2,874	-24,052
Difference between the carrying amount and the tax base of property, plant and equipment and intangible assets, including: leases and measurement of investment property	67,582	16,337	-281	51,526	23,642	-13
Other	18,652	11,393	219	7,040	6,767	8
Gross deferred tax liabilities	274,502	52,460	6,592	215,450	82,839	-24,057
Interest accrued on deposit liabilities	1,932	-5,265	0	7,197	1,468	0
Valuation of derivative financial instruments	43,242	19,398	0	23,844	5,553	0
Premium, interest and securities valuation	42,245	-11,380	17,131	36,494	10,272	113
Debt securities issued	1,795	-6,361	0	8,156	1,292	0
Provisions for employee benefits	34,218	15,283	0	18,935	2,643	582
Provisions for future liabilities	9,024	-4,230	0	13,254	68	0
Impairment allowances for assets and provisions for off-balance sheet liabilities	391,930	106,206	0	285,724	129,486	0
Accrued commissions	27,259	2,649	0	24,610	4,860	0
Accrued expenses	8,186	5,234	232	2,720	67	0
Tax loss	0	-3,331	0	3,331	1,216	0
Other, including leases	8,565	-4,013	0	12,578	10,122	0
Gross deferred tax assets	568,396	114,190	17,363	436,843	167,047	695
Total effect of temporary differences	293,894	61,730	10,771	221,393	84,208	24,752
Deferred tax assets (disclosed in the statement of financial position)	325,237	0	0	247,376	0	0
Deferred tax liabilities (disclosed in the statement of financial position)	31,342	0	0	25,982	0	0
Net effect of deferred tax on deconsolidation adjustment following the sale of shares	0	-2	0	0	-1	0
Net effect of deferred tax on the statement of profit or loss	0	61,732	0	0	84,209	0

The long-term portion of deferred tax to be realised or paid following the expiry of 12 months is:

	31 Dec 2020	31 Dec 2019
assets – long-term portion	421,837	322,014
liabilities – long-term portion	42,378	79,028

	31 Dec 2020	31 Dec 2019
The nature of evidence supporting recognition of deferred tax assets in connection with realisation of deferred tax assets depending on generation of a taxable profit in the future in the amount that will exceed gains from reversal of the existing taxable temporary differences and on loss incurred in the current or previous period in the tax jurisdiction, to which the deferred tax asset relates, is:	based on future yield rate in the upcoming 5 years at the cumulative level of at least PLN 1,546.8 million	based on future yield rate in the upcoming 5 years at the cumulative level of at least PLN 1,302.0 million

13. Earnings per share

The Bank is not an issuer of shares. The legal status of the parent entity is described in Note 1.

14. Contribution to the State Budget

In 2020 the Bank did not make any contribution to the State Budget from the net profit for 2019.

In 2019, the Bank made a contribution to the State Budget from the net profit for 2018 in the amount of PLN 364,745 thousand.

Notes to the consolidated statement of financial position

15. Cash and balances with the Central Bank

Cash and balances with the Central Bank	31 Dec 2020	31 Dec 2019
Current account	5,262,257	8,729,184
Deposits	27,000,000	14,000,192
Total	32,262,257	22,729,376

The Bank is obliged to maintain a statutory reserve at the NBP that can be used by the Bank on condition that an average balance per month in the current account at NBP is not lower than declared.

From 31 December 2020 to 31 January 2021, the Bank was obliged to keep an average balance totalling PLN 663,753 thousand, whereas from 31 December 2019 to 30 January 2020 – a total of PLN 2,416,567 thousand.

16. Amounts due from banks

Amounts due from banks	31 Dec 2020	31 Dec 2019
Current accounts	834,761	5,318,522
Deposits in banks	3,874,541	1,083,759
Loans and advances	413,319	514,074
Purchased debt	12,624	12,969
Other receivables	471,641	11,174
Total	5,606,886	6,940,498
Impairment allowances for receivables	-503	-1,805
Total, net	5,606,383	6,938,693

Cash deposited with banks includes assets securing the payment of the Bank’s liabilities, including settlements related to loss on valuation of derivatives. As at 31 December 2020, the assets totalled PLN 469,791 thousand, relative to PLN 6,079 thousand as at 31 December 2019.

The tables below present the change in gross amounts and impairment allowances on amounts due from banks.

Amounts due from banks at amortised cost	Stage 1	Stage 2	Stage 3	POCI	TOTAL
Gross carrying amount as at 31 December 2019	6,939,810	0	688	0	6,940,498
New/purchased/granted financial assets	51,969,336	0	0	0	51,969,336
Derecognition of financial assets	-53,548,926	0	-693	0	-53,549,619
Other changes (including partial repayments and disbursements of further tranches)	246,666	0	5	0	246,671
Gross carrying amount as at 31 December 2020	5,606,886	0	0	0	5,606,886
Impairment allowance
Impairment allowances as at 31 December 2019	1,578	0	227	0	1,805
New/purchased/granted financial assets	20,640	0	0	0	20,640
Derecognition of financial assets	-21,847	0	-240	0	-22,087
Changes in credit risk level (excluding transfers between stages)	72	0	5	0	77
Other changes (foreign exchange gains (losses))	60	0	8	0	68
Impairment allowances as at 31 December 2020	503	0	0	0	503

Amounts due from banks at amortised cost	Stage 1	Stage 2	Stage 3	POCI	TOTAL
Gross carrying amount as at 31 December 2018	8,366,053	0	0	0	8,366,053
Transfer to Stage 3	-348	0	348	0	0
New/purchased/granted financial assets	48,369,922	0	688	0	48,370,610
Derecognition of financial assets	-49,303,348	0	-346	0	-49,303,694
Other changes (including partial repayments and disbursements of further tranches)	-492,469	0	-2	0	-492,471
Gross carrying amount as at 31 December 2019	6,939,810	0	688	0	6,940,498
Impairment allowance
Impairment allowances as at 31 December 2018	1,085	0	0	0	1,085
New/purchased/granted financial assets	8,306	0	218	0	8,524
Derecognition of financial assets	-8,778	0	-118	0	-8,896
Changes in credit risk level (excluding transfers between stages)	1,005	0	129	0	1,134
Other changes (foreign exchange gains (losses))	-40	0	-2	0	-42
Impairment allowances as at 31 December 2019	1,578	0	227	0	1,805

17. Derivative financial instruments

The fair values of derivatives as at 31 December 2020 and 31 December 2019 are presented in the table below:

Derivatives – fair value
Contract type	31 Dec 2020		31 Dec 2019
Contract type	Assets	Liabilities	Assets	Liabilities
FX Swap	186,988	421,623	67,682	2,737
Forward	5,191	16,068	14,854	16,841
Options	0	0	104	104
CIRS	606,447	560,861	405,481	372,831
IRS	198,771	326,248	86,786	218,817
Total	997,397	1,324,800	574,907	611,330

Derivatives – nominal value
Contract type	31 Dec 2020		31 Dec 2019
Contract type	Call	Put	Call	Put
FX Swap	5,821,661	15,460,391	343,301	8,672,687
Forward	741,459	478,332	866,605	923,801
Options	0	0	36,701	36,701
CIRS	10,888,147	11,824,419	12,348,740	13,278,620
IRS	6,538,622	5,247,287	6,800,306	5,423,728
Total	23,989,889	33,010,429	20,395,653	28,335,537

18. Securities

Securities – carrying amount as at 31 December 2020	Held for trading	Not held for trading measured at fair value through profit or loss		Measured at fair value through other comprehensive income	At amortised cost		Total
Debt securities	19,675	192,043		54,956,960		20,232,471	75,401,149
NBP (money market) bills	0	0		39,482,056		13,999,727	53,481,783
treasury bonds	19,675	93,232		10,247,711		194,264	10,554,882
corporate bonds	0	98,811		1,393,111		4,588,804	6,080,726
subordinated bonds	0	0		1,465,799		0	1,465,799
covered bonds	0	0		67,618		0	67,618
municipal bonds	0	0		2,300,665		1,449,676	3,750,341
Equity securities	0	7,403		812,303		0	819,706
listed shares in other entities	0	7,403		756,372		0	763,775
unlisted shares in other entities	0	0		55,931		0	55,931
Other financial assets*	0	681,325		0		0	681,325
Total	19,675	880,771		55,769,263		20,232,471	76,902,180
* Include investments in the funds:
- Marguerite I			257,340
- Marguerite II SCSp			290,097
- Polish Growth Fund of Funds (PGFF)			133,888

	Securities – carrying amount as at 31 December 2019	Held for trading		Not held for trading measured at fair value through profit or loss	Measured at fair value through other comprehensive income	At amortised cost		Total
	Debt securities	1,666		227,171	19,121,315		7,397,934	26,748,086
	NBP (money market) bills	0		0	3,598,124		0	3,598,124
	treasury bonds	1,666		87,051	10,636,369		0	10,725,086
	corporate bonds	0		140,120	1,399,403		6,087,725	7,627,248
	subordinated bonds	0		0	1,451,512		0	1,451,512
	commercial bills	0		0	161,200		0	161,200
	covered bonds	0		0	68,141		0	68,141
	municipal bonds	0		0	1,806,566		1,310,209	3,116,775
	Equity securities	0		11,657	969,116		0	980,773
	listed shares in other entities	0		11,657	910,022		0	921,679
	unlisted shares in other entities	0		0	59,094		0	59,094
	Other financial assets*	0		582,370	0		0	582,370
	Total	1,666		821,198	20,090,431		7,397,934	28,311,229
	* Include investments in the funds:
- Marguerite I			286,332
- Marguerite II SCSp			189,226
- Polish Growth Fund of Funds (PGFF)			106,812

18.1. Securities held for trading

Debt securities held for trading by issuer	31 Dec 2020	31 Dec 2019
Issued by the State Treasury	19,675	1,666
treasury bonds	19,675	1,666
Total	19,675	1,666

18.2. Securities not held for trading measured at fair value through profit or loss

Securities obligatorily measured at fair value through profit or loss
At carrying amount	31 Dec 2020	31 Dec 2019
Issued by non-financial entities	5,975	54,036
- corporate bonds	5,975	54,036
Equity instruments	7,403	11,657
Other financial assets	681,325	582,370
Total	694,703	648,063

The parent entity presents debt securities with a negative SPPI test result and equity instruments for which the Bank has not applied the option of measurement at fair value through other comprehensive income as obligatorily measured at fair value through profit or loss, and investments in Marguerite I and II and the PGFF that do not meet the definition of an equity instrument under IAS 32 in “Other financial assets”.

Debt securities designated as at fair value through profit or loss
At carrying amount	31 Dec 2020	31 Dec 2019
Issued by the State Treasury	93,232	87,051
- treasury bonds	93,232	87,051
Issued by banks	92,836	86,084
- corporate bonds	92,836	86,084
Total	186,068	173,135

In this item the parent entity presents debt securities for which the option of measurement at fair value was applied historically due to accounting mismatch – transactions hedged with derivatives

18.3. Securities measured at fair value through other comprehensive income

Securities at fair value through other comprehensive income	31 Dec 2020	31 Dec 2019
Debt securities	54,956,960	19,121,315
Issued by the State Treasury	10,247,711	10,636,369
- treasury bonds	10,247,711	10,636,369
Issued by the National Bank of Poland (NBP)	39,482,056	3,598,124
- money bills	39,482,056	3,598,124
Issued by banks	834,773	1,204,162
- corporate bonds	37,103	252,221
- subordinated bonds	730,052	722,600
- commercial bills	0	161,200
- covered bonds	67,618	68,141
Issued by other financial entities	308,907	314,568
- subordinated bonds	308,907	314,568
Issued by non-financial entities	1,782,848	1,561,526
- corporate bonds	1,356,008	1,147,182
- subordinated bonds	426,840	414,344
Issued by local government units	2,300,665	1,806,566
- municipal bonds	2,300,665	1,806,566
Equity instruments*	812,303	969,116
- listed shares in other entities	756,372	910,022
- unlisted shares in other entities	55,931	59,094
Total	55,769,263	20,090,431
Impairment allowance on debt securities at fair value through other comprehensive income**	7,873	6,864

* These are instruments, for which the Bank applied an irrevocable option of measurement at fair value through other comprehensive income.

** The impairment allowance on debt securities at fair value through other comprehensive income is recognised under other comprehensive income and does not decrease the carrying amount of securities.

The tables below present the change in the value of receivables and impairment allowances on debt instruments at fair value through other comprehensive income.

Debt securities at fair value through other comprehensive income	Stage 1	Stage 2	Stage 3	Total
Carrying amount as at 31 December 2019	19,085,034	36,281	0	19,121,315
Transfer to Stage 1	161,192	-161,192	0	0
Transfer to Stage 2	-420,202	420,202	0	0
New/purchased/granted financial assets	685,127,015	0	0	685,127,015
Derecognition of financial assets	-642,948,358	-33,001	0	-642,981,359
Other changes (including partial repayments and disbursements of further tranches)	-6,312,017	2,006	0	-6,310,011
Carrying amount as at 31 December 2020	54,692,664	264,296	0	54,956,960
Impairment allowance
Impairment allowances as at 31 December 2019	6,608	256	0	6,864
Transfer to Stage 1	2,316	-2,316	0	0
Transfer to Stage 2	-839	839	0	0
New/purchased/granted financial assets	10,294	0	0	10,294
Derecognition of financial assets	-7,668	-23	0	-7,691
Changes in credit risk level (excluding transfers between stages)	-5,288	3,694	0	-1,594
Impairment allowances as at 31 December 2020	5,423	2,450	0	7,873

Debt securities at fair value through other comprehensive income	Stage 1	Stage 2	Stage 3	Total
Carrying amount as at 31 December 2018	14,718,720	34,736	1,220	14,754,676
Transfer to Stage 2	-2,438	2,438	0	0
Transfer to Stage 3	0	-309	309	0
New/purchased/granted financial assets	379,642,921	0	0	379,642,921
Derecognition of financial assets	-372,489,426	0	-1,529	-372,490,955
Other changes (including partial repayments and disbursements of further tranches)	-2,784,743	-584	0	-2,785,327
Carrying amount as at 31 December 2019	19,085,034	36,281	0	19,121,315
Impairment allowance
Impairment allowances as at 31 December 2018	4,004	412	216	4,632
Transfer to Stage 2	-5	5	0	0
Transfer to Stage 3	0	-1	1	0
New/purchased/granted financial assets	60,512	0	0	60,512
Derecognition of financial assets	-56,727	0	-319	-57,046
Changes in credit risk level (excluding transfers between stages)	-1,176	-160	102	-1,234
Impairment allowances as at 31 December 2019	6,608	256	0	6,864

18.4. Securities measured at amortised cost

Debt securities at amortised cost	31 Dec 2020	31 Dec 2019
Issued by the State Treasury	194,264	0
- treasury bonds	194,264	0
Issued by the National Bank of Poland (NBP)	13,999,727	0
- money bills	13,999,727	0
Issued by non-financial entities	4,588,804	6,087,725
- corporate bonds	4,588,804	6,087,725
Issued by local government units	1,449,676	1,310,209
- municipal bonds	1,449,676	1,310,209
Total	20,232,471	7,397,934

The tables below present the change in the gross carrying amount and impairment allowances on debt instruments at amortised cost.

Debt securities at amortised cost	Stage 1	Stage 2	Stage 3	Total
Gross carrying amount as at 31 December 2019	6,545,033	309,189	675,371	7,529,593
Transfer to Stage 1	189,303	-189,303	0	0
Transfer to Stage 2	-37,123	37,123	0	0
New/purchased/granted financial assets	188,091,556	0	0	188,091,556
Derecognition of financial assets	-174,897,842	-64,948	-8,019	-174,970,809
Other changes (including partial repayments and disbursements of further tranches)	-183,469	1,570	-33,623	-215,522
Gross carrying amount as at 31 December 2020	19,707,458	93,631	633,729	20,434,818
Impairment allowance
Impairment allowances as at 31 December 2019	30,231	8,648	92,780	131,659
Transfer to Stage 1	2,679	-2,679	0	0
Transfer to Stage 2	-73	73	0	0
New/purchased/granted financial assets	6,308	0	0	6,308
Derecognition of financial assets	-9,862	-259	-130	-10,251
Changes in credit risk level (excluding transfers between stages)	-9,497	-2,319	86,385	74,569
Other changes (foreign exchange gains (losses))	177	0	-115	62
Impairment allowances as at 31 December 2020	19,963	3,464	178,920	202,347

Debt securities at amortised cost	Stage 1	Stage 2	Stage 3	POCI	Total
Gross carrying amount as at 31 December 2018	5,313,854	1,019,275	681,389	0	7,014,518
Transfer to Stage 1	769,983	-769,983	0	0	0
Transfer to Stage 2	-306,308	306,308	0	0	0
New/purchased/granted financial assets	1,316,053	0	17,405	0	1,333,458
Derecognition of financial assets	-338,225	-255,933	-17,992	0	-612,150
Other changes (including partial repayments and disbursements of further tranches)	-210,324	9,522	-5,431	0	-206,233
Gross carrying amount as at 31 December 2019	6,545,033	309,189	675,371	0	7,529,593
Impairment allowance
Impairment allowances as at 31 December 2018	11,405	15,547	105,796	0	132,748
Transfer to Stage 1	13,934	-13,934	0	0	0
Transfer to Stage 2	-677	677	0	0	0
New/purchased/granted financial assets	9,091	0	180	0	9,271
Derecognition of financial assets	-1,915	-1,357	-766	0	-4,038
Financial assets that have been written off in the statement of financial position	-166	0	0	0	-166
Changes in credit risk level (excluding transfers between stages)	-1,408	7,715	-11,997	0	-5,690
Other changes	-33	0	-433	0	-466
Impairment allowances as at 31 December 2019	30,231	8,648	92,780	0	131,659

18.5. Reclassification of financial assets

In 2020 and 2019, the Bank did not reclassify any financial assets.

19. Receivables and liabilities under reverse repurchase/repurchase agreements

Securities under repurchase agreements/reverse repurchase agreements	31 Dec 2020		31 Dec 2019
	Receivables	Liabilities	Receivables	Liabilities
From banks	1,999,902	2,254,543	1,394,020	1,544,089
From customers	2,207,332	3,563,446	3,907,517	7,569,299
Total	4,207,234	5,817,989	5,301,537	9,113,388

20. Loans and advances to customers

20.1. Loans and advances to customers measured at amortised cost

Loans and advances to customers at amortised cost	31 Dec 2020			31 Dec 2019
Loans and advances to customers at amortised cost	Gross loans	Impairment allowances	Net loans	Gross loans	Impairment allowances	Net loans
Loans and advances to customers, including:	34,703,927	1,354,518	33,349,409	31,855,244	1,067,785	30,787,459
financial sector	1,711,652	17,768	1,693,884	1,609,938	11,811	1,598,127
loans and advances	1,543,335	17,616	1,525,719	1,492,416	11,746	1,480,670
guarantees and sureties	280	114	166	171	65	106
other receivables	168,037	38	167,999	117,351	0	117,351
non-financial sector	23,682,233	1,202,798	22,479,435	21,991,904	915,128	21,076,776
loans and advances	23,109,644	1,009,382	22,100,262	21,555,721	770,053	20,785,668
purchased debt	257,880	159	257,721	252,189	1,347	250,842
guarantees and sureties	314,685	193,257	121,428	183,986	143,728	40,258
other receivables	24	0	24	8	0	8
public sector	9,310,042	133,952	9,176,090	8,253,402	140,846	8,112,556
loans and advances	9,172,959	130,948	9,042,011	8,175,378	136,525	8,038,853
purchased debt	133,296	3,004	130,292	77,916	4,321	73,595
other receivables	3,787	0	3,787	108	0	108

The tables below present the change in the gross carrying amount and impairment allowances on loans and advances to customers at amortised cost.

Loans and advances to customers at amortised cost	Stage 1	Stage 2	Stage 3	POCI	Total
Gross carrying amount as at 31 December 2019	27,454,064	2,433,860	1,967,265	55	31,855,244
Transfer to Stage 1	849,474	-814,338	-35,136	0	0
Transfer to Stage 2	-2,764,630	2,772,174	-7,544	0	0
Transfer to Stage 3	-68,591	-313,078	381,669	0	0
New/purchased/granted financial assets	11,635,437	420,447	358,322	29,560	12,443,766
Derecognition of financial assets	-3,209,124	-223,765	-128,247	-548	-3,561,684
Financial assets that have been written off in the statement of financial position	0	0	-3,646	0	-3,646
Other changes (including partial repayments and disbursements of further tranches)	-5,400,818	-448,297	-179,882	-756	-6,029,753
Gross carrying amount as at 31 December 2020	28,495,812	3,827,003	2,352,801	28,311	34,703,927
Impairment allowance
Impairment allowances as at 31 December 2019	179,799	121,165	774,524	-7,703	1,067,785
Transfer to Stage 1	25,099	-17,595	-7,504	0	0
Transfer to Stage 2	-28,838	30,078	-1,240	0	0
Transfer to Stage 3	-2,170	-58,935	61,105	0	0
New/purchased/granted financial assets	34,494	818	44,024	0	79,336
Derecognition of financial assets	-27,112	-1,306	-15,070	0	-43,488
Financial assets that have been written off in the statement of financial position	-31	0	-1,244	0	-1,275
Changes in credit risk level (excluding transfers between stages)	19,134	69,699	151,342	8,622	248,797
Other changes (foreign exchange gains (losses))	1,695	629	1,039	0	3,363
Impairment allowances as at 31 December 2020	202,070	144,553	1,006,976	919	1,354,518

Loans and advances to customers at amortised cost	Stage 1	Stage 2	Stage 3	POCI	Total
Gross carrying amount as at 31 December 2018	21,471,051	3,164,300	1,968,581	126,137	26,730,069
Transfer to Stage 1	2,780,084	-2,566,715	-213,369	0	0
Transfer to Stage 2	-2,423,653	2,505,565	-81,912	0	0
Transfer to Stage 3	-145,778	-105,441	251,219	0	0
New/purchased/granted financial assets	12,840,757	564,523	432,396	0	13,837,676
Derecognition of financial assets	-2,183,239	-537,375	-123,435	-8,041	-2,852,090
Financial assets that have been written off in the statement of financial position	-8,011	0	-5,503	0	-13,514
Other changes (including partial repayments and disbursements of further tranches)	-4,877,147	-590,997	-260,712	-118,041	-5,846,897
Gross carrying amount as at 31 December 2019	27,454,064	2,433,860	1,967,265	55	31,855,244
Impairment allowance
Impairment allowances as at 31 December 2018	164,989	84,351	715,358	-27,322	937,376
Transfer to Stage 1	40,864	-24,530	-16,334	0	0
Transfer to Stage 2	-41,965	47,216	-5,251	0	0
Transfer to Stage 3	-8,299	-4,454	12,753	0	0
New/purchased/granted financial assets	36,317	4,156	31,686	0	72,159
Derecognition of financial assets	-17,367	-4,179	-1,825	0	-23,371
Financial assets that have been written off in the statement of financial position	-10,387	0	-17,314	0	-27,701
Changes in credit risk level (excluding transfers between stages)	16,719	18,907	59,627	19,619	114,872
Other changes (foreign exchange gains (losses))	-1,072	-302	-4,176	0	-5,550
Impairment allowances as at 31 December 2019	179,799	121,165	774,524	-7,703	1,067,785

20.2. Loans and advances to customers obligatorily measured at fair value through profit or loss

Loans and advances to customers obligatorily measured at fair value through profit or loss	31 Dec 2020	31 Dec 2019
public sector	102,266	124,870
loans and advances	102,266	124,870

Change in loans and advances to customers obligatorily measured at fair value through profit or loss	2020	2019
Carrying amount as at the beginning of the period	124,870	146,088
Decreases	22,604	21,218
repayments	21,186	21,186
change in interest accrued	9	2
changes in fair value	1,409	30
Carrying amount as at the end of the period	102,266	124,870

21. Investments in associates

In the consolidated financial statements all associates are measured using the equity method.

Investments in associates	31 Dec 2020	31 Dec 2019
Value at cost	4,594,272	3,851,986
Measurement using the equity method	-215,501	-188,717
Impairment allowances	0	-10,436
Carrying amount	4,378,771	3,652,833

Changes in investments in associates	2020	2019
Investments in associates at the beginning of the period	3,652,833	3,883,564
Increases, including:	956,861	115,806
Share of profit in the statement of profit or loss	88,816	73,943
Share of profit in comprehensive income	1,916	0
Acquisition of investment certificates/shares*	855,693	41,863
Other changes	10,436	0
Decreases, including:	243,896	345,970
Share of loss in the statement of profit or loss	113,784	342,565
Sale of shares	3,000	640
Redemption of investment certificates	127,112	0
Change in impairment allowances	0	2,765
Foreign exchange gain/loss	12,973	-567
Investments in associates at the end of the period	4,378,771	3,652,833
* The Group purchased investment certificates/shares (value at cost) of the following entities:
- Three Seas Investment Fund SA SICAV RAIF (the Three Seas Initiative Investment Fund)	791,949	8,189
- KUKE S.A.	50,000	x
- Fundusz Inwestycji Infrastrukturalnych – Dłużny FIZ AN	177	x
- Esotiq Germany GmbH	x	3,194
- UAB EMP Recycling	x	3,777
- ASM Germany GmbH	x	5,029
- Elemental USA INC.	x	11,879
- Recat GmbH	x	9,795
- G+M GMBH	13,567	x

** In 2020, Fundusz Inwestycji Infrastrukturalnych Dłużny FIZ AN was wound up, thus the certificates were redeemed and the Bank received PLN 116,381 thousand.

In 2020 and 2019, the parent entity did not receive dividends from the associates.

Share of profit/loss in the statement of profit or loss is the effect of measurement of associates with the equity method. In 2019, the share of loss was mostly affected by the loss on operations suffered by Fundusz Inwestycji Polskich Przedsiębiorstw FIZ AN due to a decrease in the value of the fund’s investments (PLN 296,050 thousand, gross), while the share of profit primarily resulted from a profit on operations earned by Fundusz Inwestycji Infrastrukturalnych Kapitałowy FIZ AN (PLN 49,111 thousand, gross).

Condensed information about associates measured using the equity method as at 31 December 2020
Entity name	Current assets	Property, plant and equipment	Short-term liabilities	Long-term liabilities	Revenue	Net profit/loss	Net assets	% interest in capital	% interest in voting rights	Adjusted net assets	Carrying amount
KUKE S.A.	492,998	5,881	0	0	127,407	14,193	286,634	48.45	48.45	286,634	126,949
Śląski Regionalny Fundusz Poręczeniowy Sp. z o.o.	44,014	84	24,065	4,417	2,345	5	9,733	46.08	46.08	9,693	4,467
Poznański Fundusz Poręczeń Kredytowych Sp. z o.o.	34,116	322	3	9,750	1,212	-79	18,952	44.44	44.44	8,954	3,979
Kujawsko-Pomorski Fundusz Poręczeń Kredytowych Sp. z o.o.	44,978	982	40	10,317	3,391	194	31,777	49.38	24.64	8,827	4,359
Dolnośląski Fundusz Gospodarczy Sp. z o.o.	24,362	20	61	0	2,496	-1,059	20,684	42.62	42.62	20,644	8,798
Opolski Regionalny Fundusz Poręczeń Kredytowych Sp. z o.o.	13,026	0	22	6,221	1,486	514	6,143	48.27	34.25	6,128	2,958
Bydgoski Fundusz Poręczeń Kredytowych Sp. z o.o.	2,033	771	22	675	497	2	1,920	31.09	22.64	1,913	594
Samorządowy Fundusz Poręczeń Kredytowych Sp. z o.o. of Gostyń	44,239	72	131	10,500	2,273	456	22,071	37.51	37.51	19,063	7,151
Fundusz Pomerania Sp. z o.o.	20,293	11,385	178	0	3,848	19	30,284	41.15	41.15	15,028	6,185
Warmińsko-Mazurski Fundusz „Poręczenia Kredytowe” Sp. z o.o.	48,615	2,908	25	33,990	2,251	-151	16,844	36.19	23.49	6,076	2,199
Małopolski Fundusz Poręczeń Kredytowych Sp. z o.o. w likwidacji (in liquidation)	4,440	253	3,213	0	388	3	-248	32.86	32.86	-248	0
Krajowa Grupa Poręczeniowa Sp. z o.o.	43	244	9	0	256	-112	268	39.29	39.29	268	105
Świętokrzyski Fundusz Poręczeniowy Sp. z o.o.	26,611	424	19,882	0	1,412	336	6,822	49.99	49.99	6,068	3,034
Małopolski Regionalny Fundusz Poręczeniowy Sp. z o.o.	54,573	186	29,835	0	3,275	-742	13,528	36.87	36.87	12,225	4,507
Fundusz Inwestycji Infrastrukturalnych Kapitałowy FIZ AN	2,273,952	0	269	0	17,101	-24,524	2,273,683	86.45	86,45*	2,273,683	1,965,689
Fundusz Inwestycji Polskich Przedsiębiorstw FIZ AN	1,220,946	0	934	0	28,628	35,794	1,220,012	86.40	86,40*	1,220,312	1,054,350
Fundusz Inwestycji Samorządowych FIZ AN	619,944	0	602	0	2,433	-2,737	619,342	50.00	50,00*	619,342	309,671
Three Seas Initiative Investment Fund S.A. SICAV RAIF	867,828	0	14,483	0	0	-46,605	853,345	89.29	96.15	853,345	760,683
Esotiq Germany GmbH	4,149	2,469	11,459	0	3,657	-3,223	-4,984	48.78	48.78	-4,984	1,676
UAB EMP Recycling	52,914	30,074	30,071	7,387	192,635	11,453	45,529	49.00	49.00	45,529	37,827
ASM Germany GmbH	1,452	2,354	744	4,233	403	634	-1,244	49.90	49.90	-1,244	0
Elemental USA Inc.	155,717	88,079	82,822	50,596	1,406,603	68,239	110,378	49.00	49.00	110,378	47,362
Recat GMBH	41,741	2,839	32,097	898	277,066	6,164	11,586	32.20	32.20	11,586	12,661
G+M GmbH	1,474	5,608	3,901	0	1,022	1,446	3,151	24.00	24.00	3,151	13,567
Total											4,378,771

* The Funds were classified as associates due to the fact that certain decisions require a unanimous vote of the Investors’ Meeting.

Condensed information about associates measured using the equity method as at 31 December 2019
Entity name	Current assets	Property, plant and equipment	Short-term liabilities	Long-term liabilities	Revenue	Net profit/loss	Net assets	% interest in capital	% interest in voting rights	Adjusted net assets	Carrying amount
KUKE S.A.	367,570	4,101	152,332	0	100,758	6,240	219,339	36.69	36.69	219,339	69,162
Śląski Regionalny Fundusz Poręczeniowy Sp. z o.o.	44,843	62	24,061	5,446	2,338	15	9,728	46.08	46.08	9,692	4,467
Fundusz Rozwoju i Promocji Województwa Wielkopolskiego S.A.	45,632	868	307	7,500	8,481	174	36,449	22.47	22.47	18,810	4,227
Poznański Fundusz Poręczeń Kredytowych Sp. z o.o.	30,933	152	45	6,500	1,793	90	19,031	44.44	44.44	8,160	3,626
Kujawsko-Pomorski Fundusz Poręczeń Kredytowych Sp. z o.o.	44,663	2,710	24	11,764	3,867	305	31,681	49.38	24.64	8,859	4,375
Dolnośląski Fundusz Gospodarczy Sp. z o.o.	25,063	20	57	0	3,141	-1,920	21,715	42.62	42.62	20,981	8,942
Opolski Regionalny Fundusz Poręczeń Kredytowych Sp. z o.o.	13,443	0	24	6,273	1,038	-1,049	5,681	48.27	33.50	5,671	2,737
Bydgoski Fundusz Poręczeń Kredytowych Sp. z o.o.	4,814	799	12	2,966	646	108	1,923	31.09	22.64	1,911	594
Samorządowy Fundusz Poręczeń Kredytowych Sp. z o.o. of Gostyń	39,463	107	41	7,000	3,622	143	21,046	41.01	41.01	18,039	7,398
Fundusz Pomerania Sp. z o.o.	21,894	9,946	94	0	4,889	7	30,409	41.15	41.15	14,616	6,015
Warmińsko-Mazurski Fundusz „Poręczenia Kredytowe” Sp. z o.o.	50,809	2,950	152	36,162	2,603	33	16,995	36.19	23.49	5,938	2,149
Małopolski Fundusz Poręczeń Kredytowych Sp. z o.o. w likwidacji (in liquidation)	5,185	253	3,889	0	221	216	-251	32.86	32.86	-261	0
Krajowa Grupa Poręczeniowa Sp. z o.o.	26	366	7	0	279	-72	380	39.29	39.29	380	149
Świętokrzyski Fundusz Poręczeniowy Sp. z o.o.	27,272	481	20,499	0	1,562	-427	6,487	49.99	49.99	6,155	3,077
Małopolski Regionalny Fundusz Poręczeniowy Sp. z o.o.	58,753	107	33,297	0	3,244	480	14,879	36.87	36.87	12,103	4,462
Fundusz Inwestycji Infrastrukturalnych Kapitałowy FIZ AN	2,299,693	0	1,718	0	33,602	56,806	2,298,207	86.45	86,45*	2,298,207	1,986,892
Fundusz Inwestycji Polskich Przedsiębiorstw FIZ AN	1,185,490	0	1,136	0	37,461	-342,651	1,184,518	86.40	86,40*	1,184,518	1,023,424
Fundusz Inwestycji Samorządowych FIZ AN	622,267	0	450	0	6,266	9,304	622,079	50.00	50,00*	622,079	311,040
Fundusz Inwestycji Infrastrukturalnych Dłużny FIZ AN	135,657	0	862	0	1,489	-4,255	134,863	5.89% (86.45%)**	5.89% (86.45%)**	134,658	116,416
Three Seas Initiative Investment Fund S.A. SICAV RAIF	6,668	0	1,654	0	0	-3,539	5,014	96.15	96.15	5,014	4,787
Esotiq Germany GmbH	4,574	2,874	8,760	0	4,932	-3,974	-1,414	48.78	48.78	-1,414	3,042
UAB EMP Recycling	26,401	16,024	13,224	493	158,805	5,390	28,708	49.00	49.00	28,708	30,105
ASM Germany GmbH	50,679	51,177	55,966	0	246,761	-11,949	18,333	49.90	49.90	18,333	34,073
Elemental USA Inc.	-	-	-	-	-	-	-	49.00	49.00	-	11,879
Recat GmbH	14,578	3,351	11,546	1,322	127,286	2,419	5,062	32.20	32.20	5,062	9,795
Total											3,652,833

* The Funds were classified as associates due to the fact that certain decisions require a unanimous vote of the Investors’ Meeting.

** Target interest, with the provison that the Fund was classified as an associate, inter alia due to the fact that certain decisions require a unanimous vote of the Investors’ Meeting.

The adjustment of net assets in surety funds relates to alignment of the funds’ accounting principles with regard to the recognition of impairment allowances on off-balance-sheet liabilities granted with the principles applied by the parent entity.

22. Intangible assets

Intangible assets	31 Dec 2020	31 Dec 2019
Licences, copyrights (including software)	47,742	33,866
Expenditure on intangible assets	21,678	21,115
Other intangible assets	4	1
Total	69,424	54,982

§ Change in intangible assets from 1 January to 31 December 2020

Change in intangible assets in 2020	Licences, copyrights (including software)	Expenditure on intangible assets	Other intangible assets	Total
Gross carrying amount at the beginning of the period	132,961	34,034	35	167,030
Increases, including:	24,791	25,174	34	49,999
- purchase	0	25,208	0	25,208
- reclassification from expenditure	24,791	0	0	24,791
- other	0	-34	34	0
Decreases, including:	0	24,870	0	24,870
- reclassification from expenditure	0	24,791	0	24,791
- other	0	79	0	79
Gross carrying amount at the end of the period	157,752	34,338	69	192,159
Accumulated amortisation at the beginning of the period	99,095	14	34	99,143
Increases, including:	10,915	-14	31	10,932
- amortisation for the period	10,833	0	17	10,850
- other	82	-14	14	82
Accumulated amortisation at the end of the period	110,010	0	65	110,075
Impairment losses at the beginning of the period	0	12,905	0	12,905
Decreases, including:	0	245	0	245
- reversal in the period	0	245	0	245
Impairment losses at the end of the period	0	12,660	0	12,660
Net carrying amount at the beginning of the period	33,866	21,115	1	54,982
Net carrying amount at the end of the period	47,742	21,678	4	69,424

§ Change in intangible assets from 1 January to 31 December 2019

Change in intangible assets in 2019	Licences, copyrights (including software)	Right of perpetual usufruct of land	Expenditure on intangible assets	Other intangible assets	Total
Gross carrying amount as at 31 December 2018	124,949	3,664	24,332	3,280	156,225
Effect of application of IFRS 16	0	-3,641	0	0	-3,641
Gross carrying amount as at 1 January 2019	124,949	23	24,332	3,280	152,584
Increases, including:	8,012	0	18,111	0	26,123
- purchase	0	0	18,111	0	18,111
- reclassification from expenditure	8,012	0	0	0	8,012
Decreases, including:	0	23	8,409	3,245	11,677
- liquidation	0	0	0	3,245	3,245
- reclassification to investment property	0	23	0	0	23
- reclassification from expenditure	0	0	8,012	0	8,012
- reclassification from expenditure on property, plant and equipment	0	0	86	0	86
- other	0	0	311	0	311
Gross carrying amount at the end of the period	132,961	0	34,034	35	167,030
Accumulated amortisation as at 31 December 2018	90,759	200	0	3,279	94,238
Effect of application of IFRS 16	0	-198	0	0	-198
Accumulated amortisation as at 1 January 2019	90,759	2	0	3,279	94,040
Increases, including:	8,336	0	14	0	8,350
- amortisation for the period	8,285	0	14	0	8,299
- other	51	0	0	0	51
Decreases, including:	0	2	0	3,245	3,247
- reclassification to investment property	0	2	0	0	2
- liquidation	0	0	0	3,245	3,245
Accumulated amortisation at the end of the period	99,095	0	14	34	99,143
Impairment losses at the beginning of the period	0	0	12,905	0	12,905
Impairment losses at the end of the period	0	0	12,905	0	12,905
Net carrying amount as at 1 January 2019	34,190	21	11,427	1	45,639
Net carrying amount at the end of the period	33,866	0	21,115	1	54,982

The value of intangible assets considered material for the financial statements of the Group

The parent entity holds licences/copyrights for the use of:

§ the DEF system (modifications) with a value of PLN 7,982 thousand (net). The expected useful life ends on 31 December 2025,

§ the bgk24 system (core system + modifications) with a net value of PLN 5,162 thousand. The expected useful life ends on 30 November 2023,

§ the KONDOR+ system (core system and modifications) with a net value of PLN 7,961 thousand. The expected useful life ends on 30 April 2030,

§ SIEM and DAM licences (core system and modifications) with a net value of PLN 4,832 thousand. The expected useful life ends on 30 June 2025.

As at 31 December 2020 and 31 December 2019, the Group did not hold any intangible assets whose legal title would be limited or which would have been provided as collateral securing the payment of liabilities.

The parent entity entered into agreements to purchase in future periods the intangible assets of PLN 2,468 thousand.

23. Property, plant and equipment

Property, plant and equipment	31 Dec 2020	31 Dec 2019
Buildings and structures	76,549	86,158
Leasehold improvements	355	430
Plant and equipment	33,717	36,169
PPE under construction	17,690	8,388
Other property, plant and equipment	1,452	1,215
Total	129,763	132,360

§ Change in property, plant and equipment from 1 January to 31 December 2020

Change in PPE in 2020	Buildings and structures	Leasehold improvements	Plant and equipment	Vehicles	PPE under construction	Other property, plant and equipment	Total
Gross carrying amount of PPE at the beginning of the period	107,594	2,327	124,848	88	9,755	6,565	251,177
Increases, including:	0	111	9,833	0	20,050	626	30,620
- purchase	0	0	0	0	20,050	0	20,050
- reclassification from expenditure	0	111	9,818	0	0	626	10,555
- other	0	0	15	0	0	0	15
Decreases, including:	8,403	735	17,336	0	10,748	475	37,697
- sale	0	0	11	0	0	414	425
- liquidation	0	735	17,241	0	6	61	18,043
- reclassification from expenditure	0	0	0	0	10,555	0	10,555
- reclassification to investment property	8,403	0	0	0	0	0	8,403
- other	0	0	84	0	187	0	271
Gross carrying amount of PPE at the end of the period	99,191	1,703	117,345	88	19,057	6,716	244,100
Accumulated depreciation at the beginning of the period	21,436	1,897	88,679	88	0	5,350	117,450
Increases, including:	3,236	186	12,242	0	0	386	16,050
- depreciation for the period	2,886	179	11,907	0	0	386	15,358
- other	350	7	335	0	0	0	692
Decreases, including:	2,030	735	17,293	0	0	472	20,530
- sale	0	0	11	0	0	411	422
- liquidation	0	735	17,239	0	0	61	18,035
- other	0	0	43	0	0	0	43
- reclassification to investment property	2,030	0	0	0	0	0	2,030
Accumulated depreciation at the end of the period	22,642	1,348	83,628	88	0	5,264	112,970
Impairment losses at the beginning of the period	0	0	0	0	1,367	0	1,367
Impairment losses at the end of the period	0	0	0	0	1,367	0	1,367
Net carrying amount at the beginning of the period	86,158	430	36,169	0	8,388	1,215	132,360
Net carrying amount at the end of the period	76,549	355	33,717	0	17,690	1,452	129,763

§ Change in property, plant and equipment from 1 January to 31 December 2019

Change in PPE in 2019	Buildings and structures	Leasehold improvements	Plant and equipment	Vehicles	PPE under construction	Other property, plant and equipment	Total
Gross carrying amount of PPE at the beginning of the period	110,632	3,360	112,624	4,308	15,347	7,994	254,265
Increases, including:	0	149	16,939	0	10,303	207	27,598
- purchase	0	0	0	0	10,303	0	10,303
- reclassification from expenditure	0	149	15,408	0	0	167	15,724
- reclassification from expenditure on intangible assets	0	0	86	0	0	0	86
- other	0	0	1,445	0	0	40	1,485
Decreases, including:	3,038	1,182	4,715	4,220	15,895	1,636	30,686
- sale	0	0	30	4,220	0	131	4,381
- liquidation	0	1,071	2,391	0	0	66	3,528
- reclassification from expenditure	0	0	0	0	15,724	0	15,724
- reclassification to investment property	3,038	0	0	0	0	0	3,038
- other	0	111	2,294	0	171	1,439	4,015
Gross carrying amount of PPE at the end of the period	107,594	2,327	124,848	88	9,755	6,565	251,177
Accumulated depreciation at the beginning of the period	18,685	2,838	81,646	4,263	0	6,597	114,029
Increases, including:	3,328	223	11,739	45	0	368	15,703
- depreciation for the period	3,224	215	10,032	8	0	364	13,843
- other	104	8	1,707	37	0	4	1,860
Decreases, including:	577	1,164	4,706	4,220	0	1,615	12,282
- sale	0	0	27	4,220	0	131	4,378
- liquidation	0	1,068	2,391	0	0	66	3,525
- reclassification to investment property	577	0	0	0	0	0	577
- other	0	96	2,288	0	0	1,418	3,802
Accumulated depreciation at the end of the period	21,436	1,897	88,679	88	0	5,350	117,450
Impairment allowances at the beginning of the period	0	0	0	0	1,367	0	1,367
Impairment allowances at the end of the period	0	0	0	0	1,367	0	1,367
Net carrying amount at the beginning of the period	91,947	522	30,978	45	13,980	1,397	138,869
Net carrying amount at the end of the period	86,158	430	36,169	0	8,388	1,215	132,360

As at 31 December 2020 and 31 December 2019, the Group did not hold any property or equipment whose legal title would be limited or which would have been provided as collateral securing the payment of liabilities.

The parent entity signed agreements on future purchase of property, plant and equipment worth PLN 11,607 thousand.

24. Right-of-use assets

Right-of-use assets	31 Dec 2020	31 Dec 2019
Buildings and structures	87,172	24,223
Right of perpetual usufruct of land	10,481	10,612
Civil engineering structures	149	0
Plant and equipment	4,992	7,077
Vehicles	1,985	3,931
Total	104,779	45,843

Change in right-of-use assets in 2020	Buildings and structures	Right of perpetual usufruct of land	Civil engineering structures	Plant and equipment	Vehicles	Total
Gross carrying amount of right-of-use assets at the beginning of the period	35,496	10,770	0	7,697	6,023	59,986
Increases, including:	91,852	33	179	0	283	92,347
- purchase (new agreements)*	91,390	0	179	0	283	91,852
- indexation	452	33	0	0	0	485
- other	10	0	0	0	0	10
Decreases, including:	12,373	0	0	0	0	12,373
- lease termination	6,366	0	0	0	0	6,366
- other	6,007	0	0	0	0	6,007
Gross carrying amount of right-of-use assets at the end of the period	114,975	10,803	179	7,697	6,306	139,960
Accumulated depreciation at the beginning of the period	11,273	158	0	620	2,092	14,143
Increases, including:	18,669	164	30	2,085	2,229	23,177
- depreciation for the period	18,214	164	30	1,987	2,187	22,582
- other	455	0	0	98	42	595
Decreases, including:	6,366	0	0	0	0	6,366
- lease termination	6,366	0	0	0	0	6,366
Accumulated depreciation at the end of the period	23,576	322	30	2,705	4,321	30,954
Impairment losses at the beginning of the period	0	0	0	0	0	0
Increases, including:	4,227	0	0	0	0	4,227
- recognition	4,227	0	0	0	0	4,227
Impairment losses at the end of the period	4,227	0	0	0	0	4,227
Net carrying amount at the beginning of the period	24,223	10,612	0	7,077	3,931	45,843
Net carrying amount at the end of the period	87,172	10,481	149	4,992	1,985	104,779

* The increase in “Buildings and structures” results from the executed lease agreement for office space which is the Bank’s temporary office in the VARSO 2 building, accounted for as a lease as required by IFRS 16. The agreement was executed for the expected time of alteration of the Bank’s head office. The right-of-use assets related to the temporary office is the most significant item of the ‘increase’ line.

Change in right-of-use assets in 2019	Buildings and structures	Right of perpetual usufruct of land	Plant and equipment	Vehicles	Total
Gross carrying amount of right-of-use assets as at 31 December 2018	x	x	x	x	x
Effect of application of IFRS 16*	27,368	10,899	0	5,546	43,813
Gross carrying amount of right-of-use assets as at 1 January 2019	27,368	10,899	0	5,546	43,813
Increases, including:	8,128	389	7,697	477	16,691
- purchase (new agreements)	7,873	0	7,048	477	15,398
- indexation	255	0	0	0	255
- other	0	389	649	0	1,038
Decreases, including:	0	518	0	0	518
- other	0	518	0	0	518
Gross carrying amount of right-of-use assets at the end of the period	35,496	10,770	7,697	6,023	59,986
Accumulated depreciation as at 31 December 2018	x	x	x	x	x
Effect of application of IFRS 16	0	0	0	0	0
Accumulated depreciation as at 1 January 2019	0	0	0	0	0
Increases, including:	11,273	164	620	2,092	14,149
- depreciation for the period	10,314	164	611	2,054	13,143
- other	959	0	9	38	1,006
Decreases, including:	0	6	0	0	6
- other	0	6	0	0	6
Accumulated depreciation at the end of the period	11,273	158	620	2,092	14,143
Net carrying amount as at 1 January 2019	27,368	10,899	0	5,546	43,813
Net carrying amount at the end of the period	24,223	10,612	7,077	3,931	45,843

25. Investment property

Change in investment property	2020	2019
Carrying amount at the beginning of the period	1,501,811	1,178,986
Increases, including:	234,776	342,013
- purchase of investment property	205,604	265,572
- fair value measurement	22,799	73,958
- reclassification from property, plant and equipment and intangible assets	6,373	2,483
Decreases, including:	25,321	19,188
- sale/discontinuation of investment projects	1,045	4,084
- fair value measurement	22,659	11,985
- discontinued investments	768	364
- other (transfer free of charge)	0	2,210
- other	849	545
Carrying amount at the end of the period	1,711,266	1,501,811

The Group adopted the fair value measurement model for investment property. The fair value of investment property is classified at Level 3 of the fair value measurement hierarchy.

The fair value of property investments is recognised in the valuation prepared by independent property appraisers.

The valuations were carried out based on a comparative method (pairwise comparison) and an income method (by investment).

The best indicator of fair value is the applicable prices on an active market for similar assets. If no such information is available, the fair value is estimated. Various information are taken into account (including unobservable inputs) to carry out the valuation, including:

§ the market price for property (transactions) of a similar nature, condition, and location (or provided for in a different agreement or contract), adjusted to consider the difference between the properties,

§ discounted cash flow projections based on reliable estimations of future cash flows specified in the terms and conditions of present lease agreements and other contracts or in external sources, such as current market rental prices of similar property in the same location and condition, rental price growth rate, the time where flats are not inhabited, along with occupancy rate.

Fair value measurement was recognised in profit or loss as “Other operating expenses” and “Other operating income”, in the revaluation reserve and in the statement of comprehensive income.

The following items of revenue and expenses related to investment property were recognised in profit or loss:

	2020	2019
Rental income from investment property	59,259	56,212
Direct operating expenses (including the cost of repair and maintenance) related to property, which generated rental income in the period	402	709
Direct operating expenses (including the cost of repair and maintenance) related to property, which did not generate any rental income in the period	300	104

Moreover, the parent entity entered into contracts for repair, maintenance or improvement of investment property in subsequent periods with a value of PLN 63 thousand.

26. Other assets

Other assets	31 Dec 2020	31 Dec 2019
Accrued income, including:	34,444	19,254
- fees for asset management as part of European Union Perspective 2014–2020	23,743	14,182
Sundry debtors	38,315	62,320
Public law settlements	2,104	3,786
Payment card settlements	3,274	4,806
Pre-paid costs, including:	12,203	9,957
- costs of telecommunication services	7,423	7,309
- costs of commissions on guarantees received	717	923
Prepayments for property	87,200	19,160
Other	7,999	4,929
Total other assets (gross)	185,539	124,212
- impairment allowances	6,879	6,248
Total other assets (net)	178,660	117,964
including financial assets (net)*	69,154	80,132

* Financial assets include: accrued revenue, sundry debtors and payment card settlements

Change in impairment allowances on other assets	2020	2019
Impairment allowances on other assets at the beginning of the period	6,248	5,897
Recognition	2,121	747
Reversal	1,382	240
Utilisation	11	244
Other changes	-97	88
Impairment allowances on other assets at the end of the period	6,879	6,248

27. Amounts due to banks

Amounts due to banks	31 Dec 2020	31 Dec 2019
Current accounts	69,015	90,228
Bank deposits	514,960	531,004
Loans and advances received*	3,264,166	3,202,153
Other	59,756	296,261
Total	3,907,897	4,119,646
* Including received from:
- European Investment Bank	2,690,604	2,691,017
- Council of Europe Development Bank	310,057	207,079
- KfW (Kreditanstalt für Wiederaufbau)	263,505	304,057

28. Liabilities to customers

Liabilities to customers	31 Dec 2020	31 Dec 2019
Liabilities to financial sector	14,510,330	5,841,901
Current accounts and O/N deposits	3,522,135	740,002
Term deposits	10,963,733	5,096,908
Other liabilities	24,462	4,991
Liabilities to non-financial sector	46,856,776	22,640,500
Current accounts and O/N deposits	13,842,887	6,263,008
Term deposits	31,993,432	15,267,146
Other liabilities	1,020,457	1,110,346
Liabilities to the public sector	54,770,980	31,218,973
Current accounts and O/N deposits	38,284,653	27,159,555
Term deposits	16,354,126	3,941,600
Other liabilities	132,201	117,818
Total	116,138,086	59,701,374

29. Debt securities issued

Issue date	Nominal value	Currency	Maturity date	Interest rate	Carrying amount as at 31 December 2020
28 Oct 2019	1,850,000	PLN	28 Oct 2023	6M WIBOR + margin	1,852,146
19 Feb 2019	2,000,000	PLN	19 Feb 2023	6M WIBOR + margin	2,005,320
25 Jan 2018	500,000	PLN	25 Jan 2021	6M WIBOR + margin	500,840
3 Oct 2017	500,000	PLN	3 Oct 2021	6M WIBOR + margin	501,140
Total	4,850,000				4,859,446

Issue date	Nominal value	Currency	Maturity date	Interest rate	Carrying amount as at 31 Dec 2019
28 Oct 2019	1,850,000	PLN	28 Oct 2023	6M WIBOR + margin	1,857,215
19 Feb 2019	2,000,000	PLN	19 Feb 2023	6M WIBOR + margin	2,016,560
25 Jan 2018	500,000	PLN	25 Jan 2021	6M WIBOR + margin	504,450
3 Oct 2017	500,000	PLN	3 Oct 2021	6M WIBOR + margin	502,725
19 May 2017	1,200,000	PLN	19 May 2020	6M WIBOR + margin	1,203,144
27 Feb 2017	1,158,600	PLN	27 Feb 2020	6M WIBOR + margin	1,167,429
Total	7,208,600				7,251,523

30. Lease liabilities

Change in lease liabilities	31 Dec 2020	31 Dec 2019
Amount at the beginning of the period	43,099	0
Effect of application of IFRS 16	0	40,370
Increases, including:	96,852	17,878
- new agreements	84,741	14,478
- indexation of payments/ modifications	4,603	2,187
-interest expense on lease liabilities	1,064	924
- foreign exchange gain/loss	6,439	283
- other	5	6
Decreases, including:	26,789	15,149
- repayment of lease liabilities	20,202	14,342
- indexation of payments/ modifications	2,728	0
- foreign exchange gain/loss	3,832	292
- sale	0	511
- other	27	4
Amount at the end of the period	113,162	43,099

31. Other liabilities

Other liabilities	31 Dec 2020	31 Dec 2019
Deferred costs	19,499	13,629
Deferred income	220,502	98,803
Provisions for annual holidays	10,595	8,817
Personnel costs – annual and jubilee awards, payments in lieu of leave, bonuses	92,343	73,820
Other liabilities (by basis):	3,298,757	283,914
- interbank settlements	2,074	32,538
- settlements with the COVID-19 Response Fund	2,121,376	0
- settlements with other funds and programmes	251,510	106,973
- liabilities to suppliers of works and services	23,430	15,619
- employee settlements	205	216
- fuel charge liabilities	604,081	0
- payment card liabilities	633	985
- other	295,448	127,583
Total	3,641,696	478,983

As at 31 December 2020 and 31 December 2019, the parent entity had no delinquent contractual liabilities under concluded agreements.

32. Provisions

Provisions	31 Dec 2020	31 Dec 2019
Provisions for liabilities and guarantees	449,697	344,311
Provisions for litigation and legal risks	51,513	80,351
Provisions for defined benefit plans	18,852	17,128
Total provisions	520,062	441,790

Provisions for the year ending on 31 December 2020	Provision for financial and guarantee liabilities granted	Provisions for litigation and legal risks	Provisions for defined benefit plans	Total
Balance at the beginning of the period	344,311	80,351	17,128	441,790
Recognition	408,211	13,494	1,784	423,489
Reversal	303,637	33,235	0	336,872
Utilisation	0	9,097	1,281	10,378
Other changes and reclassifications	0	0	1,221	1,221
Other	812	0	0	812
Balance as at 31 December 2020, including:	449,697	51,513	18,852	520,062
Short-term provision	70,277	4,950	4,084	79,311
Long-term provision	379,420	46,563	14,768	440,751

Provisions for the year ending on 31 December 2019	Provision for financial and guarantee liabilities granted	Provisions for litigation and legal risks	Provisions for defined benefit plans	Other provisions	Total
Balance at the beginning of the period	211,684	79,869	13,320	93,328	398,201
Recognition	395,112	482	1,812	0	397,406
Reversal	262,485	0	0	93,328	355,813
Utilisation	0	0	1,024	0	1,024
Other changes and reclassifications	0	0	3,020	0	3,020
Balance as at 31 December 2019, including:	344,311	80,351	17,128	0	441,790
Short-term provision	55,466	0	3,669	0	59,135
Long-term provision	288,845	80,351	13,459	0	382,655

Provisions for financial and guarantee liabilities granted

The tables below present financial and guarantee liabilities granted, together with relevant provisions, by stage, in accordance with IFRS 9.

	Stage 1	Stage 2	Stage 3	Total
Financial and guarantee liabilities granted
Financial liabilities granted	51,779,197	907,916	38,614	52,725,727
Guarantee liabilities granted	16,555,046	970,019	532,719	18,057,784
As at 31 December 2020	68,334,243	1,877,935	571,333	70,783,511
Provision for financial and guarantee liabilities granted
Provision for financial liabilities granted	72,264	8,115	9,862	90,241
Provision for guarantee liabilities granted	116,834	33,529	209,093	359,456
As at 31 December 2020	189,098	41,644	218,955	449,697
	Stage 1	Stage 2	Stage 3	Total
Financial and guarantee liabilities granted
Financial liabilities granted	48,580,610	255,026	116,697	48,952,333
Guarantee liabilities granted	14,518,420	311,962	408,900	15,239,282
As at 31 December 2019	63,099,030	566,988	525,597	64,191,615
Provision for financial and guarantee liabilities granted
Provision for financial liabilities granted	52,156	1,853	47,024	101,033
Provision for guarantee liabilities granted	97,178	6,273	139,827	243,278
As at 31 December 2019	149,334	8,126	186,851	344,311

Provisions for litigation and legal claims

In 2018, the Bank recognised a PLN 67,231 thousand provision for operational risk related to the distribution of funds as part of Regional Operational Programmes for 2014-2020 in connection with irregularities in performance of agreements with one of financial intermediaries and reported a suspected crime related to the case to the prosecutor’s office.

In 2019, following the takeover of operational agreements from the financial intermediary the Bank launched the procedure to seek claims under loans advanced as part of individual operational agreements. The prosecution and court proceedings are pending.

Due to the progress in making arrangements with some Managing Authorities of individual projects in which irregularities occurred, it was possible to finalise the settlement of those projects and reverse part of the related provisions. By the end of 2020, the provision was reduced by a total of PLN 32,765 thousand, to PLN 34,466 thousand.

Provisions for legal risk related to the portfolio of CHF-indexed mortgage loans

As of 31 December 2020, the Bank carried receivables from CHF-indexed mortgage loans with a gross carrying amount of PLN 32,941 thousand (PLN 33,798 thousand as at 31 December 2019), which represented 0.095% of gross loans and advances to customers.

In addition, as at 31 December 2020 the Bank carried CHF 30,803 thousand repaid CHF-indexed mortgage loans and CHF 559 thousand loans converted into PLN.

As at 31 December 2020, five individual court cases were pending against the Bank and there were two opened petitions for settlement concerning active CHF-indexed mortgage loans and one court case was pending concerning a repaid loan. The Bank created individual provisions for those disputed in the amount of PLN 2,449 thousand.

Despite a negligible share of CHF-indexed mortgage loans in the total loan portfolio, in 2020 the Bank estimated and recognised a provision for the related legal risk on a portfolio basis, in the amount of PLN 9,900 thousand (PLN 8,900 thousand for active loans and PLN 1,000 thousand for repaid loans).

The estimate of the portfolio provision was based on a scenario of settlements with clients following from the proposal of the Polish Financial Supervision Authority of December 2020, i.e. conversion into PLN, in which the interest rate was determined based on WIBOR, taking into account the credit margin resulting from the average interest rate applicable to new loans in PLN in the month when the loan in CHF was granted, published in the statistical data of the NBP, and the expected number of court cases calculated based on the Bank’s judgement resulting from its past experience gained from a pilot project and the current analysis of the market situation.

The estimates of the provision for the portfolio of mortgage loans in CHF recognised in the statement of financial position required the use of professional judgement. The main uncertainties in estimating the provision were the assumptions concerning:

1) the number of settlements on the terms provided for in the scenario consistent with the PFSA’s proposal;

2) the number of settlements on other terms;

3) the number of potential disputes ending with the cancellation of the agreement or other arrangements;

4) portfolios not covered by voluntary settlements or disputes;

5) the likelihood of filing claims under agreements derecognised from the statement of financial position.

Provisions for defined benefit plans

Provisions for defined benefit plans include: retirement, disability and post-mortem benefits. Provisions are estimated based on actuarial valuation using the discount rate: market yield of 10-year T-bonds of 1.5% and 2.0% assumed at the end of 2020 and at the end of 2019, respectively. The long-term annual nominal salary growth rate of 2.0% has been assumed for calculation purposes. The provision for actuarial valuation is recognised and revalued annually.

Reconciliation of the present value of liabilities due to defined benefit plans

The table below presents the change in the present value of liabilities due to defined benefit plans.

Liabilities due to defined benefit plans	2020	2019
Balance at the beginning of the period	17,128	13,320
Current employment costs	1,515	1,490
Interest expense	269	322
Revaluation of liabilities:	1,221	3,020
- actuarial gains/losses arising from changes in demographic assumptions	28	0
- actuarial gains/losses arising from changes in financial assumptions	657	1,117
- actuarial gains/losses arising from ex-post adjustments of actuarial assumptions	536	1,903
Benefits paid	-1,281	-1,024
Balance at the end of the period	18,852	17,128

Employment costs comprise:

§ current service cost: the increase in the present value of the defined benefit obligation resulting from employee service in the current period,

§ any gain or loss on settlement.

Sensitivity analysis of liabilities with respect to adopted assumptions as at 31 December 2020

The impact of 1 p.p. changes in actuarial valuations on liabilities due to defined benefit plans is presented below.

Liabilities due to defined benefit plans	31 Dec 2020		31 Dec 2019
Increase/decrease in value	+1%	-1%	+1%	-1%
Discount rate	-1,271	1,474	-1,117	1,292
Payroll growth rate	1,451	-1,277	1,279	-1,127

Maturity of liabilities due to defined benefit plans

Maturity of liabilities due to defined benefit plans is presented in the table below.

	31 Dec 2020	31 Dec 2019
Weighted average period of liabilities due to defined benefit plans (years)	7.72	7.31

Other provisions

In line with the Act of 2 April 2009 amending the Act on Sureties and Guarantees Granted by the State Treasury and Certain Legal Persons, the Act on Bank Gospodarstwa Krajowego and Certain Other Acts (Journal of Laws, No. 65, item 545), the National Housing Fund was liquidated as of 31 May 2009 and its net assets, whose value was determined based on the data from the financial statements drawn up at the liquidation date, increased the statutory capital of the parent entity.

Consequently, the parent entity recognised a provision for liabilities resulting from the submitted initial customers’ applications, in response to which the applicants received BGK’s decision approving the eligibility of the applications for further procedure to obtain a loan for an investment and construction project, but until the date of the liquidation of NHF did not yet receive a decision granting a promise neither notified the Bank of their resignation from applying for a loan.

In 2019, all initial applications, as described above, for NHF loans have been converted into loan agreements, now held in the Bank’s portfolio or were withdrawn by customers or expired, and as a result the remaining provision was released.

33. Equity

Statutory capital

The statutory capital of the Bank is created in accordance with the Articles of Association and the Act on Bank Gospodarstwa Krajowego and is supplied from:

§ cash and other assets contributed by the State Treasury, including treasury securities provided by the minister competent for public finance,

§ annual appropriations of the Bank’s net profit in the amount of at least 10% of the profit.

In 2020, the statutory capital was:

1) increased by PLN 110,770 thousand from distribution of net profit for 2019;

2) increased following a capital injection in the form of Treasury bonds in the amount of PLN 4,934,500 thousand.

In 2019, the statutory capital was:

1) increased by PLN 44,535 thousand from distribution of net profit for 2018;

2) decreased by PLN 500,000 thousand due to a contribution made to the Polish Science Fund. Under the Act on Supporting Scientific Activities from the Polish Science Fund of 4 April 2019 (Journal of Laws of 2019, item 823, as amended), in June 2019 BGK established the Polish Science Fund (“PSF”) operating as a flow fund. Based on said Act, BGK injected into the PSF a total of PLN 500 million.

Supplementary capital

In 2020, PLN 439,980 thousand was transferred to supplementary capital from distribution of net profit for 2019 and PLN 4,875 thousand of loss brought forward was covered at the Group entities.

In 2019, PLN 98,143 thousand was transferred to supplementary capital from distribution of net profit for 2018 and PLN 16,960 thousand of loss brought forward was covered at the Group entities.

Revaluation reserve

Revaluation reserve comprises: the effects of measurement of financial assets at fair value through other comprehensive income, profit/loss on sale of equity instruments designated as at fair value through other comprehensive income, effects of revaluation of property, plant and equipment and property upon their reclassification to investment property, actuarial gains and losses and the related deferred tax.

Other capital reserves

Other capital reserves comprise appropriations of net profit and are used for purposes specified in the Articles of Association or other provisions of law applicable to the parent entity.

They also include the reserve for general banking risk established for unidentified risks arising from banking activity, which in line with the parent entity’s Articles of Association is established from appropriations of the annual net profit of the parent entity.

Detailed information on payments from capital to the State budget is presented in Note 14.

33.1. Non-controlling interests

Name of subsidiary	Country of incorporation and place of business activity	Percentage non-controlling interest (in the entity’s capital)		Net profit/loss attributable to non-controlling interests		Total non-controlling interest
Name of subsidiary	Country of incorporation and place of business activity	31 Dec 2020	31 Dec 2019	31 Dec 2020	31 Dec 2019	31 Dec 2020	31 Dec 2019
Projekt Municypalny Jarocin 1 Sp. z o. o.	Poland	7.97%	7.01%	-46	-32	2,736	2,235
Projekt Municypalny Kępice 1 Sp. z o. o.	Poland	13.04%	13.04%	-20	-10	941	961
Projekt Municypalny Kępno 1 Sp. z o.o.	Poland	10.15%	10.15%	-5	19	610	614
MDR Katowice Sp. z o.o.	Poland	8.62%	9.41%	377	179	6,674	6,297
Projekt Municypalny Nysa 1 Sp. z o.o.*	Poland	-	-	-	-1	-	-1
Projekt Municypalny Zgorzelec 1 Sp. z o.o.	Poland	0.08%	0.11%	0	-	1	1
MDR Toruń Sp. z o.o.	Poland	45.26%	45.26%	-323	54	3,404	3,728
Projekt Municypalny Nidzica 1 Sp. z o.o.	Poland	25.00%	25.00%	-3	-2	-5	-1
MDR Radom Sp. z o.o.	Poland	8.14%	48.24%	20	-132	738	718
MDR Katowice 2 Sp. z o.o.	Poland	48.78%	-	-606	-	3,042	-
MDR Dębica Sp. z o.o.	Poland	13.15%	-	231	-	2,615	-
MDR Świdnik Sp. z o.o.	Poland	16.82%	-	31	-	1,851	-
MDR Zamość Sp. z o.o.	Poland	27.01%	-	-293	-	370	-
MDR Łowicz Sp. z o.o.	Poland	13.23%	-	-90	-	723	-
MDR Nakło nad Notecią Sp. z o.o.	Poland	0.05%	-	0	-	1	-
FSMnW FIZ AN	Poland	0.00002%		0	-	1	-
FSMdR FIZ AN	Poland	0.00012%		0	-	0
Total				-727	75	23,702	14,552

* entity sold in July 2019.

Other notes

34. Contingent liabilities and off-balance-sheet liabilities granted and received

34.1. Securities underwriting (maximum underwriting amount committed by the parent entity)

Issuer of securities underwritten as at 31 December 2020	Type of underwritten securities	Maximum underwriting amount committed by the parent entity	Guarantee term	Transferability
Client 1	municipal bonds	10,000	30 Dec 2021	transferable
Client 2	municipal bonds	5,000	10 Dec 2021	transferable
Client 2	municipal bonds	2,500	15 Dec 2021	transferable
Client 2	municipal bonds	6,500	15 Dec 2022	transferable
Client 3	municipal bonds	2,600	15 Dec 2020	transferable
Client 4	municipal bonds	6,000	15 Dec 2021	transferable
Client 4	municipal bonds	4,000	15 Dec 2022	transferable
Client 5	municipal bonds	7,400	15 Dec 2021	transferable
Client 5	municipal bonds	5,400	15 Dec 2022	transferable
Client 7	municipal bonds	4,600	20 Dec 2021	transferable
Client 8	municipal bonds	100,000	10 Dec 2023	non-transferable
Client 9	municipal bonds	2,220	31 Dec 2034	non-transferable
Client 10	municipal bonds	5,155	15 Dec 2021	transferable
Client 10	municipal bonds	7,061	15 Dec 2022	transferable
Client 12	municipal bonds	9,000	15 Dec 2021	transferable
Client 11	commercial bonds	14,060	15 Dec 2022	non-transferable
Client 6	commercial bonds	30,000	30 Dec 2020	non-transferable
Client 6	commercial bonds	41,950	30 Dec 2020	non-transferable
Client 8	commercial bonds	300,000	31 Dec 2023	non-transferable
Client 54	commercial bonds	114,840	31 Mar 2022	non-transferable
Client 55	commercial bonds	7,640	30 Sep 2021	non-transferable
Total		685,926

Issuer of securities underwritten as at 31 December 2019	Type of underwritten securities	Maximum underwriting amount committed by the parent entity	Guarantee term	Transferability
Client 1	municipal bonds	6,800	15 Dec 2020	transferable
Client 1	municipal bonds	5,000	15 Dec 2021	transferable
Client 3	municipal bonds	9,000	20 Dec 2020	transferable
Client 4	municipal bonds	50,000	31 Dec 2020	transferable
Client 5	commercial bonds	25,000	31 Jul 2021	non-transferable
Client 6	commercial bonds	30,000	30 Dec 2020	non-transferable
Client 6	commercial bonds	114,750	30 Dec 2020	non-transferable
Client 7	municipal bonds	2,360	31 Dec 2020	transferable
Client 8	commercial bonds	45,000	4 Jan 2020	non-transferable
Client 9	municipal bonds	2,000	5 Dec 2020	transferable
Client 10	municipal bonds	10,250	31 Dec 2020	transferable
Client 11	commercial bonds	22,060	15 Dec 2022	non-transferable
Client 18	municipal bonds	2,500	31 Dec 2020	transferable
Client 20	municipal bonds	15,510	31 Dec 2020	transferable
Client 24	municipal bonds	800	31 Dec 2020	transferable
Client 26	municipal bonds	46,300	10 Dec 2020	transferable
Client 27	municipal bonds	4,100	31 Dec 2020	transferable
Client 30	municipal bonds	3,500	31 Dec 2020	transferable
Client 33	municipal bonds	4,400	31 Dec 2020	transferable
Client 35	commercial bonds	22,714	31 Mar 2020	non-transferable
Client 54	commercial bonds	93,510	31 Mar 2022	non-transferable
Client 54	commercial bonds	9,580	31 Mar 2020	non-transferable
Client 55	commercial bonds	3,600	31 Dec 2020	non-transferable
Total		528,734

34.2. Off-balance-sheet liabilities granted

Financial liabilities granted	31 Dec 2020	31 Dec 2019
Credit lines and limits	51,896,332	47,135,540
- to financial institutions	806,409	486,003
- to non-financial institutions	11,521,814	8,326,032
- to public sector entities	39,568,109	38,323,505
Other liabilities	829,396	1,816,793
Certificates, declared contribution*	3,015,005	406,344
Total	55,740,733	49,358,677

* As at 31 December 2020, the item included, among other things, the declared contribution to the Three Seas Initiative Investment Fund S.A. SICAV RAIF in the amount of PLN 2,651,945 thousand, which results from subscription agreements signed in 2020 for a total of EUR 750 million less cash contributed by the Bank until 31 December 2020.

Guarantee liabilities granted	31 Dec 2020	31 Dec 2019
Guarantees and sureties	18,040,318	15,157,334
- to financial institutions	1,346,032	605,905
- to non-financial institutions	16,433,724	14,369,435
- to public sector entities	260,562	181,994
Letters of credit granted	17,466	81,948
- to financial institutions	17,466	81,948
Total	18,057,784	15,239,282

34.3. Off-balance-sheet liabilities received

At nominal value	31 Dec 2020	31 Dec 2019
Financial	11,235,600	11,378,556
Guarantee	29,912,128	28,270,025
Total	41,147,728	39,648,581

As at 31 December 2020, FEZ FIZ AN, FSMdR FIZ AN and FSMnW FIZ AN did not carry any contingent liabilities under executed investment agreements.

Right to sell or pledge a collateral established for the Group

As at 31 December 2020 and 31 December 2019, the Group held no collaterals which could be sold or pledged if the collateral owner met all of its obligations.

35. Additional information to the consolidated statement of cash flows

Cash and cash equivalents include: cash in hand and in the nostro account at the National Bank of Poland as well as cash in the current accounts in banks and other cash with a maturity period of up to 3 months.

Cash recognised in the statement of cash flows	31 Dec 2020	31 Dec 2019
Cash in Central Bank	32,262,257	22,729,376
Cash in other banks	4,708,737	6,401,738
Total	36,970,994	29,131,114

Differences between changes in items of the consolidated statement of financial position and changes in those items presented in the operating activity of the consolidated statement of cash flows	31 Dec 2020	31 Dec 2019
Interest and dividends	124,814	163,507
a) interest:	124,859	200,465
- interest expense on loans and advances received	35,961	57,767
- cost of interest on debt securities issued	87,861	141,814
- interest expense on lease liabilities	1,037	884
b) dividends:	-45	-36,958
- PZU S.A.	0	-4,319
- European Investment Fund	0	-50
- VISA International	-45	-21
- PKO BP S.A.	0	-32,568
Change in amounts due from banks	-360,691	392,264
a) changes in the statement of financial position	1,332,310	1,426,275
b) assets included in change in cash	-1,693,001	-1,034,011
Change in amounts due under derivatives	-422,490	403,955
a) changes in the statement of financial position	-422,490	403,955
Change in securities	-43,731,141	-4,954,156
held for trading	-18,009	-1,048
a) changes in the statement of financial position	-18,009	-1,048
not held for trading measured at fair value through profit or loss	-66,857	-81,057
a) changes in the statement of financial position	-59,574	-81,057
b) equity instruments recognised in investment activities	-7,283	0
measured at fair value through other comprehensive income	-30,811,738	-4,355,887
a) changes in the statement of financial position	-35,678,832	-4,228,452
b) measurement recognised in revaluation reserve	-65,256	-127,435
c) contribution of bonds by the State Treasury to increase the statutory capital	4,934,500	0
d) equity instruments recognised in investment activities	-2,150	0
measured at amortised cost	-12,834,537	-516,164
a) changes in the statement of financial position	-12,834,537	-516,164
Change in reverse repurchase agreements	1,094,303	-1,426,877
a) changes in the statement of financial position	1,094,303	-1,426,877
Change in loans and advances to customers	-2,539,345	-4,973,548
measured at amortised cost	-2,561,949	-4,994,766
a) changes in the statement of financial position	-2,561,949	-4,994,766
obligatorily measured at fair value through profit or loss	22,604	21,218
a) changes in the statement of financial position	22,604	21,218
Change in other assets	-96,017	-59,797
a) changes in the statement of financial position	-60,696	-32,690
b) settlement of investment property	-35,323	-27,106
c) deconsolidation	2	-1
Change in amounts due to banks	-273,762	-60,258
a) changes in the statement of financial position	-211,748	240,425
b) loans included in financing activities	-62,014	-300,683
Change in derivatives payables	713,470	-965,665
a) changes in the statement of financial position	713,470	-965,665
Change in liabilities to customers	56,436,712	12,064,076
a) changes in the statement of financial position	56,436,712	12,064,076
Change in liabilities due to repurchase agreements	-3,295,399	3,899,337
a) changes in the statement of financial position	-3,295,399	3,899,337
Changes in liabilities due to securities issued	0	0
a) changes in the statement of financial position	-2,392,077	1,464,314
b) issues included in financing activities	2,392,077	-1,464,314
Change in provisions	77,050	40,569
a) changes in the statement of financial position	78,271	43,589
b) remeasurement of defined benefit plan liabilities	-1,221	-3,020
Change in accumulated loss allowance for non-financial assets and other loss allowances	-6,454	2,765
a) for investments in associates	-10,436	2,765
b) for right-of-use assets	4,227	0
c) for intangible assets	-245	0
Change in other liabilities	3,162,298	-1,023,272
a) changes in the statement of financial position	3,162,713	-522,839
b) appropriation of profit to funds exposed to credit risk	-415	-433
c) establishment of the PSF	0	-500,000
Other adjustments	1,743	2,028
a) transfer of PPE and intangible assets to commissioned activities (flow funds)	1,743	1,877
b) other	0	0
c) settlement resulting from a change in ownership structure	0	151

36. Transactions with the State Treasury and State Treasuryrelated entities

36.1. Transactions with the State Treasury

BGK is a state bank with the State Treasury as the sole shareholder.

The consolidated statement of financial position of the Group presents receivables and liabilities from transactions with the Treasury, the public sector and the State Treasury related entities, with the Treasury as the shareholder. In connection with the executed transactions the Group receives interest and commission income and incurs interest and commission expense.

Transactions of the Group with the State Treasury	31 Dec 2020			2020
Entity	Receivables	Liabilities	Financial and guarantee liabilities granted	Interest and commission income	Interest and commission expense
Entity 1 – the State Treasury	11,482,124	0	37,670,000	292,731	141,758
Other State Treasury entities	0	4,755	0	1	0

Transactions of the Group with the State Treasury	31 Dec 2019			2019
Entity	Receivables	Liabilities	Financial and guarantee liabilities granted	Interest and commission income	Interest and commission expense
Entity 1 – the State Treasury	12,077,542	16,778,935	37,504,000	320,219	372,009
Other State Treasury entities	0	6,364	0	24	0

36.2. Material transactions with entities Related to the State Treasury

The table below presents the BGK Group’s exposure and amounts of liabilities to entities related to the State Treasury with the highest total exposure. A

BGK’s significant transactions with entities related to the State Treasury
Entity	31 Dec 2020			2020
Entity	Receivables	Liabilities	Financial and guarantee liabilities granted	Interest income	Commission income	Interest expense
Entity 1	851,926	10,186,006	1,499,932	15,230	999	24
Entity 2	1,615,489	468,466	1,246,387	45,456	4,028	864
Entity 3	1,255,992	450,023	250,000	31,945	374	0
Entity 4	2,829,111	358,735	677,666	75,665	978	0
Entity 5	0	1,165,289	2,746,986	1,442	7,003	0
Entity 6	1,374,593	1,704,968	1,949,891	32,811	1,499	4
Entity 7	39,002	255,166	1,644,218	896	12,269	477
Entity 8	1,121,427	206,767	0	23,967	22	6
Entity 9	0	1,109,479	0	0	3	0
Entity 10	638,813	91	415,208	10,605	2,595	0
Entity 11	98,448	0	250,000	1,638	277	0
Entity 12	0	1,916,180	0	0	2	0
Entity 13	0	55,222	339,283	2,869	872	0
Entity 14	0	0	628,749	0	956	0
Entity 15	670,257	1,104	1,587,730	6,062	1,412	0
Entity 16	0	899,145	89,218	260	757	8
Entity 17	0	501,853	138,444	0	1,049	929
Entity 18	201,805	523,513	0	7,901	48	187
Entity 20	247,963	0	0	8,680	482	0
Entity 21	0	223,185	0	0	2	2
Entity 23	0	166,757	0	0	105	0
Entity 24	0	187,303	0	0	5	216
Entity 25	0	144,506	0	0	111	0
Entity 26	55,378	2,944	100,000	437	23	10
Entity 27	0	208,768	0	0	13	0
Entity 28	0	245,590	0	0	38	79
Entity 31	0	0	123,520	0	255	0
Entity 32	3,590	140,081	44,158	12	31	122
Entity 33	0	137,185	0	0	14	164
Entity 35	0	423,616	0	0	12	85
Entity 36	0	1,783,727	101,942	0	600	643
Entity 37	47,528	100,029	0	585	192	0
Entity 38	0	121,701	0	101	0	190
Entity 39	0	1,701,512	0	0	3	0
Entity 40	0	268,381	0	0	4	0
Entity 41	91,309	273,002	954,545	108	430	0
Entity 42	0	173,188	0	0	0	195
Entity 43	64,503	47,609	185,499	4	343	3
Entity 44	0	270,006	23,074	0	47	0
Entity 45	159,514	69,552	0	1,311	16	40
Entity 46	0	134,625	0	0	2	0
Entity 47	0	2,287	398,266	209	8	5
Entity 48	0	318,163	0	0	5	1
Total	11,366,648	26,945,724	15,394,716	268,194	37,884	4,254

Group’s significant transactions with entities related to the State Treasury
Entity	31 Dec 2019			2019
Entity	Receivables	Liabilities	Financial and guarantee liabilities granted	Interest income	Commission income	Interest expense
Entity 1	851,858	4,449,443	0	19,368	1,644	237
Entity 2	2,009,117	34,714	1,471,031	76,204	5,382	235
Entity 3	1,416,594	1,679,902	0	42,316	334	0
Entity 4	2,850,570	5	171,176	90,648	974	0
Entity 5	300,079	300,887	2,305,582	2,084	7,483	2
Entity 6	1,955,971	0	744,897	50,694	920	72
Entity 7	28,319	285,920	1,743,121	85	10,833	1,715
Entity 8	1,290,035	250,127	60,000	38,132	16	48
Entity 9	0	1,106,768	0	0	1	0
Entity 10	430,939	121	613,359	8,462	1,534	0
Entity 11	133,369	330,007	250,000	3,554	78	0
Entity 12	0	697,401	0	0	3	0
Entity 13	255,000	267,943	103,001	7,117	1,078	0
Entity 14	0	0	578,596	0	1,288	0
Entity 15	0	50,103	409,937	157	500	0
Entity 16	69,823	208,014	150,147	499	376	9
Entity 17	0	401,881	0	0	2	247
Entity 18	235,301	164,432	0	8,493	5	2
Entity 19	0	344,310	10	0	1,421	4,520
Entity 20	40,987	0	207,781	199	2,817	0
Entity 21	0	201,563	0	0	1	1
Entity 22	0	197,732	0	0	1	0
Entity 23	0	190,863	0	0	103	0
Entity 24	0	182,738	0	0	3	379
Entity 25	0	78,194	85,000	0	46	0
Entity 26	68,137	2,256	80,000	1,321	96	0
Entity 27	0	145,136	0	0	1	0
Entity 28	0	143,165	0	0	54	306
Entity 29	58,668	22,535	58,000	642	116	8
Entity 30	0	133,194	0	0	1	0
Entity 31	39,002	0	90,498	0	207	0
Entity 32	0	66,733	47,834	0	8	511
Entity 33	0	100,789	0	0	9	407
Entity 34	0	100,012	0	0	0	0
Total	12,033,769	12,136,888	9,169,970	349,975	37,335	8,699

37. Related party transactions (capital or personal links)

All related party transactions were entered into on arm’s length terms. Standard market transactions involving loans, current and term deposits, liabilities due to repurchase agreements with related interest and commissions are presented below.

Entity name	31 Dec 2020		2020
Entity name	Receivables	Liabilities	Financial and guarantee liabilities granted	Interest and commission income	Interest and commission expense
Associates
Dolnośląski Fundusz Gospodarczy Sp. z o.o.	0	11,078	0	3	101
Śląski Regionalny Fundusz Poręczeniowy Sp. z o.o.	0	37,819	0	0	358
Poznański Fundusz Poręczeń Kredytowych Sp. z o.o.	0	11,471	0	0	40
Kujawsko-Pomorski Fundusz Poręczeń Kredytowych Sp. z o.o.	0	9,208	0	0	144
Opolski Regionalny Fundusz Poręczeń Kredytowych Sp. z o.o.	0	4,038	0	0	50
Samorządowy Fundusz Poręczeń Kredytowych Sp. z o.o.	0	12,353	0	0	97
Warmińsko-Mazurski Fundusz Poręczenia Kredytowe Sp. z o.o.	0	184	0	1	2
Świętokrzyski Fundusz Poręczeniowy Sp. z o.o.	0	26,540	0	1	249
Małopolski Regionalny Fundusz Poręczeniowy Sp. z o.o.	0	49,342	0	2	803
KUKE S.A.	0	29,997	0	30	76
Fundusz Inwestycji Infrastrukturalnych Kapitałowy FIZ AN	0	437,002	0	0	2,373
Fundusz Inwestycji Polskich Przedsiębiorstw FIZ AN	0	212,312	0	0	763
Fundusz Inwestycji Samorządowych FIZ AN	0	120,001	0	0	703
Fundusz Inwestycji Infrastrukturalnych Dłużny FIZ AN	0	0	0	0	140
Fundusz Pomerania Sp. z o.o.	0	1,757	0	0	86
Three Seas Initiative Investment Fund S.A. SICAV-RAIF	0	0	2,651,945	0	0
Other units
Lubuski Fundusz Poręczeń Kredytowych Sp. z o.o.	0	29,997	0	30	76
Mazowiecki Fundusz Poręczeń Kredytowych Sp. z o.o.	0	24,615	0	4	185
Toruński Fundusz Poręczeń Kredytowych Sp. z o.o.	0	9,401	0	0	45
Polski Fundusz Rozwoju S.A.	0	1,227,002	0	0	932
Krajowy Fundusz Kapitałowy S.A.	0	0	0	0	42
Total	0	2,254,117	2,651,945	71	7,265

Entity name	31 Dec 2019			2019
Entity name	Receivables	Liabilities	Financial and guarantee liabilities granted	Interest and commission income	Interest and commission expense
Associates
Dolnośląski Fundusz Gospodarczy Sp. z o.o.	0	10,240	0	1	191
Śląski Regionalny Fundusz Poręczeniowy Sp. z o.o.	0	35,186	0	0	460
Fundusz Rozwoju i Promocji Województwa Wielkopolskiego S.A.	0	10,799	0	0	109
Poznański Fundusz Poręczeń Kredytowych Sp. z o.o.	0	7,659	0	0	85
Kujawsko-Pomorski Fundusz Poręczeń Kredytowych Sp. z o.o.	0	15,648	0	0	407
Opolski Regionalny Fundusz Poręczeń Kredytowych Sp. z o.o.	0	2,379	0	0	37
Samorządowy Fundusz Poręczeń Kredytowych Sp. z o.o.	0	14,082	0	0	228
Fundusz Pomerania Sp. z o.o.	0	9,531	0	0	209
Warmińsko-Mazurski Fundusz Poręczenia Kredytowe Sp. z o.o.	0	462	0	1	87
Świętokrzyski Fundusz Poręczeniowy Sp. z o.o.	0	20,966	0	2	344
Małopolski Regionalny Fundusz Poręczeniowy Sp. z o.o.	0	53,704	0	1	496
KUKE S.A.	3,000	30,372	0	0	0
Fundusz Inwestycji Infrastrukturalnych Kapitałowy FIZ AN	0	441,065	0	0	6,832
Fundusz Inwestycji Polskich Przedsiębiorstw FIZ AN	0	237,146	0	0	2,370
Fundusz Inwestycji Samorządowych FIZ AN	0	117,283	0	0	1,541
Fundusz Inwestycji Infrastrukturalnych Dłużny FIZ AN	0	25,022	2,746	0	348
Other units
Lubuski Fundusz Poręczeń Kredytowych Sp. z o.o.	0	14,006	0	0	316
Mazowiecki Fundusz Poręczeń Kredytowych Sp. z o.o.	0	19,887	0	0	465
Polski Fundusz Rozwoju S.A.	0	0	0	0	33
Krajowy Fundusz Kapitałowy S.A.	0	59,326	0	2	709
Toruński Fundusz Poręczeń Kredytowych Sp. z o.o.	0	5,032	0	0	93
Pomorski Regionalny Fundusz Poręczeń Kredytowych Sp. z o.o.	0	42,850	0	0	705
Total	3,000	1,172,645	2,746	7	16,065

38. Remuneration of the top executives of the Group entities

Members of the Management Board of BGK are remunerated in accordance with:

§ the Act on Remuneration of the Management of Certain Entities of 9 June 2016 (Journal of Laws of 2020, item 1907),

§ the Declaration of the Minister of Development and Finance of 14 October 2016 on rules for specifying the remuneration of the Members of the Management Board of Bank Gospodarstwa Krajowego,

§ Remuneration Rules for Members of the Management Board of Bank Gospodarstwa Krajowego,

§ the Policy governing variable remuneration components of employees identified to have a significant impact on the risk profile of Bank Gospodarstwa Krajowego.

The Bank’s management staff – excluding the President and Members of the Management Board – are remunerated in accordance with:

§ the Policy of remuneration for employees of Bank Gospodarstwa Krajowego,

§ the Remuneration Rules for employees of Bank Gospodarstwa Krajowego,

§ the Policy governing variable remuneration components of employees identified to have a significant impact on the risk profile of Bank Gospodarstwa Krajowego.

38.1. Remuneration of Members of the Management Board and Supervisory Board

Remuneration of Members of the Supervisory Board of the Bank	2020	2019
Supervisory Board of the Bank	1,183	987

Remuneration paid or due to Members of the Management Board of the Bank

Employee benefits	2020
	Short-term employee benefits		Benefits after the employment period	Other long-term benefits	Termination benefits
	Salaries and wages	Other*			Paid in 2019	Paid at a later date
Management Board	3,652	2,342	none	515	none	none

*Supplementary renumeration for 2018 (60% non-deffered part).

Employee benefits	2019
	Short-term employee benefits		Benefits after the employment period	Other long-term benefits	Termination benefits
	Salaries and wages	Other*			Paid in 2019	Paid at a later date
Management Board	3,912	2,382	none	none	none	none

* Third instalment of the supplementary remuneration for 2016 and non-deferred part of the supplementary remuneration for 2017 (60%), non-financial components: medical care, limit on car expenses, Multi Sport cards

Remuneration of members of management boards and supervisory boards of the Group entities
Short-term employee benefits	2020	2019
Management Board	15	16
Supervisory Board	0	0
Total	15	16

39. Principles of variable remuneration for top executives of the Group

General rules for specifying, awarding and paying variable remuneration components to employees having a significant impact on the Bank’s risk profile for 2020 are defined in the “Policy governing variable remuneration components of employees identified to have a significant impact on the risk profile of Bank Gospodarstwa Krajowego” (“Policy”), approved in its current wording by the Supervisory Board on 13 December 2018.

The following bodies participate in the policy-making processes concerning variable remuneration components of persons having a significant impact on the Bank’s risk profile:

1) The Bank’s Management Board – approval of the List of employees having a significant impact on the Bank’s risk profile, drafting the Variable Remuneration Components Policy and its implementation;

2) The Bank’s Supervisory Board – approval of the Variable Remuneration Components Policy, its review, approval of remuneration rules for the Members of the Management Board; awarding variable remuneration components to Members of the Bank’s Management Board;

3) Remuneration and Nomination Committee at the Supervisory Board of the Bank – monitoring and giving opinions on the Variable Remuneration Components Policy and the list of employees having a significant impact on the Bank’s risk profile applicable at the Bank. The Committee is appointed from among the members of the Supervisory Board. The competencies of the Committee have been defined in the Committee Regulations.

Due to BGK’s legal form (a state-owned bank) and the nature of its business, the Bank neutralises some requirements by way of, among other things, not paying the variable remuneration portion in shares and instruments other than shares.

As regards variable remuneration, the Bank applies the following principles:

§ variable remuneration may not exceed 100% of the fixed remuneration component for a given year,

§ where the variable remuneration base of an identified employee exceeds PLN 100 thousand (gross), the person acquires the right to receive non-deferred variable remuneration in the amount of 60% of the variable remuneration base, and 40% of the variable remuneration base is deferred,

§ 40% of deferred variable remuneration is paid in three equal parts in a period of 3 years from the end of assessment period for which the remuneration is due.

The Bank has developed and followed appropriate policy monitoring procedures, such as those on monitoring the limits of variable remuneration components awarded to persons covered by the Policy. As part of variable remuneration, employees receive a POP bonus, i.e. an annual bonus whose amount depends on performance and evaluation of the employee’s attitude, and a Top up bonus – a discretionary component of the incentive scheme depending on budget availability. For 2020, the POP annual bonus was paid, while the Top up bonus paid by the end of March 2021.

In addition, payments related to termination of an employment contract with an employee may be treated as variable remuneration.

The use of the bonus budget will be triggered by the achievement by the Bank of a positive net financial result cumulatively from the beginning of the year.

40. Changes in Group entities

The table below presents major changes in special purpose vehicles of Fundusz Sektora Mieszkań na Wynajem FIZ AN and Fundusz Sektora Mieszkań dla Rozwoju FIZ AN. The list presents companies established in 2020 and 2019 as well as changes in the legal status of other entities during 2020, as at the reporting date – 31 December 2020.

SPV	Articles of Association of:	Entity entered into the National Court Register on:	As at 31 December 2020
SPV	Articles of Association of:	Entity entered into the National Court Register on:	As at 31 December 2020
Fundusz Sektora Mieszkań na Wynajem FIZ AN
MP Inwestycje Sp. z o.o.	13 Mar 2017	12 May 2017	Liquidation proceedings opened on 31 Dec 2020
FSMnW Warszawa 3 Sp. z o.o.	13 Nov 2015	3 Dec 2015	Liquidation proceedings opened on 31 Dec 2020
Fundusz Sektora Mieszkań dla Rozwoju FIZ AN
PFR Mieszkania S.A.	3 Mar 2020	5 May 2020	New company
MDR Sochaczew Sp. z o.o.	12 Dec 2019	10 Feb 2020	New company Dormant (1 Jun 2020–31 May 2021)
MDR Kraków Igołomska Sp. z o.o. w organizacji (in organisation)	1 Sep 2020	5 Mar 2021	New company Non-consolidated
MDR Września Sp. z o.o.	10 Apr 2018	23 May 2018	Change of name from: MDR Inwestycje 10 Sp. z o.o. (until 13 Feb 2020) and MDR Warszawa Płochocińska Sp. z o.o. (until 31 Dec 2020), dormant (30 Jun 2020–30 Jun 2021)
MP Inwestycje 2 Sp. z o.o.	13 Mar 2017	24 Apr 2017	Dormant (30 Jun 2020–30 Jun 2021)
MDR Inwestycje 6 Sp. z o.o.	21 Mar 2018	24 Apr 2018	Dormant (30 Jun 2020–30 Jun 2021)
MDR Inwestycje 14 Sp. z o.o.	10 Apr 2018	30 May 2018	Dormant (31 Jul 2020–31 Jul 2021)
MDR Warszawa Sp. z o.o.	10 Apr 2018	23 May 2018	Dormant (30 Jun 2020–30 Jun 2021)
MDR Szczecin Sp. z o.o.	10 Apr 2018	30 May 2018	Dormant (30 Jun 2020–30 Jun 2021)
MDR Inwestycje 12 Sp. z o.o.	10 Apr 2018	30 May 2018	Dormant (31 Dec 2020–31 Dec 2021)
MDR Inwestycje 13 Sp. z o.o.	10 Apr 2018	15 May 2018	Dormant (30 Jun 2020–30 Jun 2021)
MDR Zakliczyn Sp. z o.o.	17 Dec 2018	30 Jan 2019	Dormant (31 Jul 2020–1 Jul 2021)
MDR Szczecin Starkiewicza Sp. z o.o.	21 Dec 2018	7 Feb 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Warszawa Ordona Sp. z o.o.	21 Dec 2018	5 Feb 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Wrocław Białowieska Sp. z o.o.	21 Dec 2018	8 Feb 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Mielec Sp. z o.o.	4 Jan 2019	20 Feb 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Przemyśl Sp. z o.o.	4 Jan 2019	6 Feb 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Wrocław Hermanowska Sp. z o.o.	24 Jan 2019	19 Mar 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Poznań Wolne Tory Sp. z o.o.	24 Jan 2019	14 Mar 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Katowice Asnyka Sp. z o.o.	24 Jan 2019	7 Mar 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Gdańsk Kochanowskiego Sp. z o.o.	24 Jan 2019	11 Mar 2019	Dormant (31 Jul 2020–31 Jul 2021)
MDR Wieluń Sp. z o.o.	6 Mar 2019	13 May 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Jedlina-Zdrój Sp. z o.o.	13 Mar 2019	17 May 2019	Dormant (30 Jun 2020–30 Jun 2021)
MDR Inwestycje 16 Sp. z o.o.	10 Apr 2018	29 May 2018	Disposal (change in KRS on 14 Jan 2021)
Changes in 2021:
MDR Lublin Krochmalna Sp. z o.o.	10 Apr 2018	29 May 2018	Change of name from MDR Inwestycje 15 Sp. z o.o. (until 25 Jan 2021)

The activities of the indicated dormant companies were suspended in 2020 for a period of one year, which was entered in the relevant business registers of the National Court Register. The financial statements of those entities and these consolidated financial statement have been prepared on the assumption that the companies will continue as going concerns for 12 months after the reporting date and do not contain any adjustments related to the indicated situation.

The full list of members of the Bank Gospodarstwa Krajowego Group as at 31 December 2020 is presented in Note 1.3.

41. Fair value of financial assets and financial liabilities

41.1. Categories of the measurement of the fair value of financial assets and financial liabilities measured at fair value in the consolidated statement of financial position

Based on fair value measurement methods, the Bank has classified its financial assets and financial liabilities to the following levels:

§ Level 1 - prices quoted in active markets,

§ Level 2 - valuation techniques based on observable market inputs,

§ Level 3 - other valuation techniques.

Level 1 Prices quoted in active markets

Financial assets and liabilities, whose fair values are determined based on unadjusted, quoted prices for identical assets or liabilities in active markets. This category includes debt and equity instruments with an active market in place and the fair value determined based on the market value (prices on BondSpot, WSE):

§ PLN-denominated treasury bonds in the held-for-trading portfolio and the portfolio of securities at fair value through other comprehensive income,

§ shares in listed companies in continuous trading on the Warsaw Stock Exchange held in the portfolio of securities at fair value through profit or loss and in the portfolio of securities at fair value through other comprehensive income,

Level 2 Valuation techniques on observable market inputs

Financial assets and liabilities, whose fair value is determined using valuation models in which all material inputs are observed in the market either directly (as prices indicated by Refinitiv (former Reuters)/Bloomberg information services) or indirectly (based on a model of discounted future cash flows using quotations of interest rates on deposits, OIS, IRS, FRA, basis swap, currency basis swap, swap points, Treasury bond yields). This category includes financial instruments with no active market:

§ NBP (money market) bills held in the portfolio of securities at fair value through other comprehensive income,

§ EUR-denominated treasury bonds in the portfolio of securities at fair value through profit or loss,

§ EUR and USD-denominated treasury bonds in the portfolio of securities at fair value through other comprehensive income,

§ PLN-denominated covered bonds issued by financial institutions held in the portfolio of securities measured through other comprehensive income,

§ PLN-denominated subordinated bonds issued by financial institutions held in the portfolio of securities at fair value though other comprehensive income,

§ derivatives,

§ shares in NYSE-listed companies (shares in VISA).

Level 3 Other valuation techniques

Financial assets and liabilities, whose fair value is determined based on models using unobservable market inputs. In this category, the measurement based on a model of discounted future cash flows using quotations of interest rates on deposits, OIS, IRS, FRA, basis swap, currency basis swap, Treasury bond yields, is adjusted for the risk margin. The category includes:

§ EUR-denominated subordinated bonds issued by financial institutions held in the portfolio of securities measured through other comprehensive income,

§ PLN-denominated corporate bonds and bills issued by financial institutions held in the portfolio of securities measured through other comprehensive income,

§ PLN-denominated subordinated bonds issued by non-financial institutions held in the portfolio of securities measured through other comprehensive income,

§ PLN-denominated corporate bonds issued by non-financial institutions held in the portfolio of securities measured through other comprehensive income,

§ PLN-denominated municipal bonds held in the portfolio of financial assets measured through other comprehensive income,

§ investment certificates and other shares not held for trading and classified in the portfolio of securities at fair value through profit or loss through other comprehensive income and through profit or loss,

§ loans that failed the SPPI test held in the portfolio of assets at fair value through profit or loss.

Financial instruments are transferred between Level 1 and Level 2 based on the availability of quoted prices from the active market at the end of the reporting period. Compared to 2019, in 2020 an exposure to a subordinate bond issued by a financial institution with a carrying amount of PLN 25 million was transferred from Level 1 to Level 2. Reclassification from Level 2 to Level 3 occurs if an observable input is replaced with an unobservable one or if a new unobservable risk is used in the valuation, which, at the same time, considerably affects the price of the instrument. Reclassification from Level 3 to Level 2 occurs if an unobservable input is replaced with an observable one or if the pricing effect of an unobservable input becomes negligible.

Compared to 2019, in 2020 exposures to covered bonds and subordinate bonds issued by financial institutions with a total carrying amount of PLN 786 million were transferred from Level 3 to Level 2 due to the use of quotations available

on the Refinitiv (previously Reuters) information website for measurement purposes. Transfers between individual measurement levels are recognised as at the end of the reporting period.

The carrying amounts of individual categories of financial assets and liabilities by measurement level as at 31 December 2020 are presented below.

Assets and liabilities at fair value as at 31 December 2020	Carrying amount	Level 1	Level 2	Level 3
	Carrying amount	Prices quoted in active markets	Valuation techniques based on observable market inputs	Other valuation techniques
Derivative financial instruments	997,397	0	997,397	0
Securities	56,669,709	8,265,465	43,464,592	4,939,652
Held for trading	19,675	19,675	0	0
debt securities	19,675	19,675	0	0
Not held for trading measured at fair value through profit or loss	880,771	7,403	186,068	687,300
debt securities	192,043	0	186,068	5,975
equity securities	7,403	7,403	0	0
other financial assets	681,325	0	0	681,325
Measured at fair value through other comprehensive income	55,769,263	8,238,387	43,278,524	4,252,352
debt securities	54,956,960	7,482,015	43,274,390	4,200,555
equity securities	812,303	756,372	4,134	51,797
Loans and advances to customers at fair value through profit or loss	102,266	0	0	102,266
Total assets at fair value	57,769,372	8,265,465	44,461,989	5,041,918
Derivative financial instruments	1,324,800	0	1,324,800	0
Total liabilities at fair value	1,324,800	0	1,324,800	0

Assets and liabilities at fair value as at 31 December 2019	Carrying amount	Level 1	Level 2	Level 3
	Carrying amount	Prices quoted in active markets	Valuation techniques based on observable market inputs	Other valuation techniques
Derivative financial instruments	574,907	0	574,907	0
Securities	20,913,295	10,588,875	4,984,344	5,340,076
Held for trading	1,666	1,666	0	0
debt securities	1,666	1,666	0	0
Not held for trading measured at fair value through profit or loss	821,198	11,657	173,135	636,406
debt securities	227,171	0	173,135	54,036
equity securities	11,657	11,657	0	0
other financial assets	582,370	0	0	582,370
Measured at fair value through other comprehensive income	20,090,431	10,575,552	4,811,209	4,703,670
debt securities	19,121,315	9,665,530	4,807,553	4,648,232
equity securities	969,116	910,022	3,656	55,438
Loans and advances to customers at fair value through profit or loss	124,870	0	0	124,870
Total assets at fair value	21,613,072	10,588,875	5,559,251	5,464,946
Derivative financial instruments	611,330	0	611,330	0
Total liabilities at fair value	611,330	0	611,330	0

§ Total Level 3 gains and losses recognised in profit or loss and in equity are presented below.

Instrument type	Gains and losses recognised in profit or loss		Gains and losses recognised in equity
Instrument type	2020	2019	2020	2019
Corporate bonds	26,626	-15,941	20,597	42,444
Municipal bonds	35,778	11,969	18,231	31,360
Shares	83,934	90,589	-1,039	-70

§ Acquisitions, sale, issues and settlements for Level 3 are presented below.

2020
Instrument type	Matured	New issues	Issued and maturing in the same year	Sale
Corporate bonds	33,063	180,000	0	0
Municipal bonds	96,803	572,794	0	3,700

2019
Instrument type	Matured	New issues	Issued and maturing in the same year	Sale
Corporate bonds	0	240,000	0	0
Municipal bonds	83,895	452,940	7,500	6,525

The estimated effect of changes in the fair value measurement of derivatives with a symmetrical risk profile, unlisted debt securities at fair value through other comprehensive income, and receivables classified in the fair value through profit or loss measurement category, due to a parallel shift in the yield curve is presented in the tables below.

Change in the measurement of derivatives with a linear risk profile due to a parallel shift in the yield curve	31 Dec 2020		31 Dec 2019
Change in the measurement due to a parallel shift in the yield curve by:	+ 50bp	- 50bp	+ 50bp	- 50bp
Change in measurement of derivatives (assets decreased by liabilities)	1,445	-1,445	3,260	-3,260

Change in the fair value measurement of unlisted debt securities at fair value through other comprehensive income due to a parallel shift in the yield curve	31 Dec 2020		31 Dec 2019
Change in the measurement due to a parallel shift in the yield curve by:	+ 50bp	- 50bp	+ 50bp	- 50bp
Change in measurement of unlisted financial instruments	-11,182	11,182	-7,673	7,673

Change in the fair value measurement of receivables at fair value through profit or loss due to a parallel shift in the yield curve	31 Dec 2020		31 Dec 2019
Change in the measurement due to a parallel shift in the yield curve by:	+ 50bp	- 50bp	+ 50bp	- 50bp
Change in measurement of receivables	510	-510	701	-701

41.2. Financial assets and financial liabilities not presented at fair value in the statement of financial position

The Group holds financial instruments not presented at fair value in the statement of financial position.

The fair value of part of financial instruments was estimated using valuation techniques. In the absence of expected considerable differences between the carrying amounts and the fair values of other groups of financial instruments, resulting from the characteristics of such groups (such as short term, high correlation with market parameters) and low market interest rates, it was assumed that their carrying amounts approximate their fair values.

The fair values of financial assets and financial liabilities not presented at fair value in the statement of financial position are presented below.

	Fair value hierarchy	31 Dec 2020
	Fair value hierarchy	Carrying amount	Fair value
Cash and balances with the Central Bank	3	32,262,257	32,261,991
Amounts due from banks	3	5,606,383	5,607,136
Securities at amortised cost	3	20,232,471	20,638,816
Reverse repurchase agreements	3	4,207,234	4,207,234
Loans and advances to customers at amortised cost	3	33,349,409	32,285,430
Amounts due to banks	3	3,907,897	3,907,889
Liabilities to customers	3	116,138,086	116,009,762
Repurchase agreements	3	5,817,989	5,817,989
Debt securities issued	3	4,859,446	4,876,121
Lease liabilities	3	113,162	113,162

	Fair value hierarchy	31 Dec 2019
	Fair value hierarchy	Carrying amount	Fair value
Cash and balances with the Central Bank	3	22,729,376	22,728,609
Amounts due from banks	3	6,938,693	6,938,517
Securities at amortised cost	3	7,397,934	7,533,539
Reverse repurchase agreements	3	5,301,537	5,301,537
Loans and advances to customers at amortised cost	3	30,787,459	30,583,990
Amounts due to banks	3	4,119,646	4,120,419
Liabilities to customers	3	59,701,374	59,648,406
Liabilities due to repurchase agreements	3	9,113,388	9,113,388
Debt securities issued	3	7,251,523	7,276,782
Lease liabilities	3	43,099	43,099

The fair value of credit exposures was measured using the discounted cash flow method at an interest rate appropriate for each credit transaction (taking into account the market risk margin). For exposures with no repayment schedule and impaired exposures, the fair value is presented as a net amount.

The fair value of the Group’s assets related to debt securities at amortised cost was estimated using a valuation technique consisting in discounting future cash flows, where a curve based on WIBOR IRS, basis swap and FRA rates were used as the projection curve, while a curve based on the yield on T-bonds, shifted by the credit spread, was used as the discount curve.

The fair value of deposits was determined using the present value of future cash flows using discount curves based on quotations of interbank deposits maturing within one year and IRS transactions with expiration dates after more than one year, available in information systems.

The fair value of the Group’s liabilities due debt securities issued was determined on the basis of:

§ quoted prices in the Catalyst system – for publicly traded bonds,

§ a valuation technique of discounted future cash flows – for other securities – where a curve based on WIBOR, IRS, basis swap and FRA rates were used as the projection curve, while a curve based on the yield on T-bonds, shifted by the credit spread, was used as the discount curve. The credit spread for measurement was based on bonds issue price. Due to the latter component of measurement, which is not an observable quotation, the measurement of these bonds is classified at Level 3.

As regards other assets and liabilities (including current accounts, overnight and term deposits) which are not measured at fair value, it was assumed that there were no major differences between the fair value of an asset or liability and its carrying amount.

The tables below present the estimated effect of changes in the present value of cash flows as well as PD and LGD on the amount of allowances for expected credit losses – for three impairment testing stages.

Effect of an increase/decrease in the present value of cash flows on impairment allowances on/provisions for impaired exposures – tested individually – Stage 3	31 Dec 2020		31 Dec 2019
Increase/decrease in the present value of cash flows	10%	-10%	10%	-10%
Estimated change in impairment allowances on on-balance-sheet exposures tested individually	-232,801	26,793	-109,366	229,257
Estimated change in provisions for off-balance-sheet liabilities tested individually	-26,299	35,032	-25,165	33,533

Effect of an increase/decrease in LGD on impairment allowances on/provisions for impaired exposures – tested on a collective basis – Stage 3	31 Dec 2020		31 Dec 2019
Increase/decrease in LGD	10%	-10%	10%	-10%
Estimated change in impairment allowances on on-balance-sheet exposures tested on a collective basis	11,736	-30,450	5,478	-15,276
Estimated change in provisions for off-balance-sheet liabilities tested on a collective basis	160	-173	164	-184

Effect of an increase/decrease in PD and LGD on impairment allowances on/provisions for non-impaired exposures – Stage 1 and 2	31 Dec 2020		31 Dec 2019
Increase/decrease in PD	10%	-10%	10%	-10%
Estimated change in impairment allowances on non-impaired on-balance-sheet exposures	35,709	-37,802	33,985	-34,640
Estimated change in provisions for non-impaired off-balance-sheet liabilities	23,074	-23,074	13,876	-16,097
Increase/decrease in LGD	10%	-10%	10%	-10%
Estimated change in impairment allowances on non-impaired on-balance-sheet exposures	37,730	-37,802	34,412	-34,446
Estimated change in provisions for non-impaired off-balance-sheet liabilities	23,070	-23,074	16,118	-16,093

42. Custody business

In 2020 and 2019, under the decision of 18 February 2011 of the Polish Financial Supervision Authority on granting Bank Gospodarstwa Krajowego of Warsaw an authorisation for keeping securities accounts (trust activities), the Bank maintained securities accounts with dematerialised securities.

Securities	31 Dec 2020	31 Dec 2019
KDPW	255,376,967	240,795,843
Bonds on deposit accounts	6,672,046	489,925
Bonds in the issue sponsor register	1,142,918	266,482
Treasury bonds entity 1	247,562,003	240,039,436
National Bank of Poland (NBP)	751,000	807,500
Money bills	751,000	807,500
BGK	422,535	434,642
Municipal bonds on deposit accounts	58,067	69,642
Other bonds on deposit accounts	364,468	365,000
Total	256,550,502	242,037,985

In the financial years 2020 and 2019, the Bank maintained securities accounts only with dematerialised financial instruments of its clients.

In accordance with the Act on Trading in Financial Instruments(Journal of Laws of 2021, item 328), since 1 July 2019 the Bank, as part of its trust activities, has acted as the Issue Agent for corporate and municipal bonds. As at 31 December 2020, Bank Gospodarstwa Krajowego has assumed such role in 340 issues for an aggregate of PLN 1,142,918 thousand (issue sponsor register).

Risk management objectives and principles

43. Risk management at the Group

The internal objective of risk management at the Group is to maintain stability and security of the parent entity’s banking operations as well as to maintain a high quality of assets and achieve anticipated financial result within an acceptable risk level.

The main risk management guidelines are defined in the Bank’s Risk Management Strategy as well as in policies for managing particular types of risks. Risk appetite is determined, inter alia, by the acceptable level of total capital ratio, short-term liquidity ratio, and the acceptable level of individual risk types. In the allocation process, the required capital is distributed among individual risk types, with limit levels defined for individual risks at BGK.

The diagram below presents the general structure of the areas subject to the limits.

ImageAlt3

The risk management is based on:

§ Risk Management Strategy at BGK approved by the Supervisory Board of the Bank,

§ Capital Management Policy and Internal Capital Assessment at BGK approved by the Supervisory Board of the Bank,

§ risk management policies, principles, and procedures related to risk identification, measurement or assessment, control, monitoring and reporting, developed in written form and approved by the Supervisory Board or Management Board of the Bank,

§ HR management rules, including rules governing recruitment, monitoring of staffing needs, human resources planning, and the Policy governing variable remuneration components of employees identified to have a significant impact on the risk profile, approved by the Bank’s Supervisory or Management Board.

The regulations are reviewed systematically so that they can be adjusted to the changes in the risk profile, business environment and good professional practices.

In addition, at least each year the parent entity reviews:

1) the implementation of the Bank’s Risk Management Strategy and the functioning of the risk management system, including ILAAP (Internal Liquidity Adequacy Assessment Process);

2) ICAAP (Internal Capital Adequacy Assessment Process).

The risk management system is designed in such a way as to ensure a uniform and efficient process of identification, measurement or assessment, control, monitoring and reporting of risks.

The risk identification process includes determination of risk types, their sources (factors), determination of areas exposed to a given risk and identification of risks related to products, projects, processes and procedures.

The risk measurement/assessment process includes methods of risk quantification and performing stress tests.

The risk control process comprises the determination and enforcement of risk control mechanisms (i.e. limit systems, ensuring independence between first-level risk management from second-level risk management, insurance, risk transfer, financing plans).

The risk monitoring process includes supervision of the level of risk taken, reviews of relevance and accuracy of the applied methods of risk assessment and evaluation of efficiency of the tools used.

The risk reporting process includes information on the risk profile, identification of possible threats, and information on the measures adopted.

Organisation of risk management for the key risk types:

ImageAlt4

Supervisory Board of the Bank

The Supervisory Board exercises supervision over the introduction of risk management system and evaluates its adequacy and efficiency in particular through approving acceptable risk level and monitoring its compliance.

The Bank’s Supervisory Board is supported by the Risk Committee, Audit Committee and Remuneration Committee.

Risk Committee

The Risk Committee supports operations of the Bank’s Supervisory Board, supervising the management system for all risks identified in the Bank’s operations, in particular by providing opinions as to the Bank’s overall ongoing and future risk appetite. The Risk Committee includes persons appointed from among the members of the Bank’s Supervisory Board.

Audit Committee

The Audit Committee supports the Bank’s Supervisory Board, in particular through oversight over the internal audit area and monitoring the financial and management reporting process, as well as financial audit activities carried out at the Bank. The Audit Committee includes persons appointed from among the members of the Bank’s Supervisory Board.

Management Board of the Bank

The Management Board of the Bank is responsible for organising and administering the risk management process and ensuring the efficiency of the risk management system. One of the Management Board members, who has obtained consent of the Polish Financial Supervision Authority to be appointed as a Management Board member, supervises the banking risk area that covers organisational units managing credit, financial, operational risks.

In its risk management activities, the Bank’s Management Board is supported by the Bank’s Asset-Liability Committee (ALCO), Bank’s Operational Risk and Internal Control Committee (ORC), Bank’s Credit Committee (CC) and Model Management Committee.

44. Credit risk management

Definition

Credit risk is defined as a threat of a borrower’s default on the payment of liability under an agreement, i.e. failure to repay receivables under credit exposure along with the Bank’s remuneration within time limits defined in the agreement.

Management purposes

Main credit risk management purposes are as follows:

§ identification of credit risk areas and its mitigation to a level accepted by the Bank,

§ regular review of actions completed in this risk area,

§ composition of balance-sheet and off-balance-sheet items of the Bank to minimise the risk of negative deviation of the financial result from the Bank’s financial plan.

Control

Control of credit risk involves the application of adequate methods, models and monitoring system and setting risk limits which are acceptable with respect to individual sectors and industries, counterparty and product segments. The limit system is subject to the risk guidelines specified by the Bank’s Supervisory and Management Boards.

Monitoring

Credit risk monitoring process involves cyclical review of risk measure levels for the loan portfolio and individual counterparties. In the case of a loan portfolio it involves an analysis of the use of limits and threshold values, while in the case of individual counterparties monitoring is carried out on a continuous basis and consists in identification of elements suggesting a likely decline in creditworthiness.

Another important element of the assessment and monitoring process is a regular review of the Bank’s credit exposure collateral.

Pursuant to applicable regulations, the Bank performs - at least once a year - stress tests of credit exposure sensitivity to changes in the exchange rates, interest rate and the value of the existing mortgage collaterals.

Reporting

The Bank prepares regular reports on its credit risk and risk concentration, including:

§ a monthly report for the Bank’s Management Board and Credit Committee, also made available to the Bank’s Financial Committee, containing inter alia information on the quality and structure of the loan portfolio,

§ a quarterly report for the Bank’s Management Board, Credit Committee, and Risk Committee, and every six months also for the Bank’s Supervisory Board, also made available to the Bank’s Financial Committee, containing inter alia information on the quality and structure of the loan portfolio, including a sub-loan portfolio of mortgage-backed exposures and results of concentration limit stress tests,

§ an annual report for the Bank’s Management Board, Credit Committee, Risk Committee and the Bank’s Supervisory Board, also made available to the Bank’s Financial Committee, containing inter alia detailed information on the quality and structure of the loan portfolio, including a sub-loan portfolio of mortgage-backed exposures, results of concentration limit stress tests, and information on other credit risk aspects important to the Bank,

and a range of other reports and analyses related to the fields of operation exposed to credit risk.

44.1. Credit risk management at the Group

Credit risk management engages relevant units of the Bank’s Risk Division and dedicated units of the Group’s subsidiaries. Among other things they provide opinions about projects and internal regulations regarding subsidiaries and − at the same time − evaluation of credit risk and recommend actions of changes in the regulations.

The credit risk management process is carried out at the level of the loan portfolio and customer risk with individual credit exposure taken into account, on the basis of:

§ Risk Management Strategy at BGK,

§ planned, targeted actions defined in the credit policy,

§ internal regulations,

§ available support systems and tools,

§ recommendations and guidance for regional and other units of the Bank.

Credit risk management helps to identify, measure or estimate, monitor, report, and control the risk.

The Management Board of the Bank defines the credit policy based on the risk appetite specified in the Risk Strategy, business model provided for in the Bank’s Strategy, the existing level of credit risk borne by the Bank, the structure of credit portfolio, the structure of legal collaterals, repayments of the transactions bearing credit risk, and external macroeconomic factors. Among other elements, the credit policy indicates the acceptable level of risk for the credit portfolio, credit purposes and recommendations, credit profile for individual customer and product segments, risk management process, and the related best practices.

44.2. Model for impairment and recognition of impairment allowances

Impairment allowances at the Bank are recognised in accordance with International Financial Reporting Standard 9 Financial Instruments. IFRS 9 provides for calculation of impairment allowances based on expected credit losses and taking into account forecasts and expected future economic conditions in the light of credit risk exposure assessment.

The impairment model applies to financial assets classified, in line with IFRS 9, as financial assets measured at amortised cost (AC), as financial assets measured at fair value through other comprehensive income (FVOCI) and as off-balance-sheet credit exposures.

IFRS 9 introduced a material change in the measurement of impairment of financial assets, under which the concept of expected credit losses (ECL) replaced the previous concept of incurred losses. The change in approach resulted in a significant increase in the importance of estimates and assumptions for impairment measurement, in particular for identification of a significant increase in credit risk and the related measurement of lifetime expected credit losses of an exposure.

In the assessment of expected credit losses a broad range of information is taken into account, including historical and current data and information on future economic conditions expected by the Bank’s unit in charge of macroeconomic forecast.

The impairment model compliant with IFRS 9 is based on a division of exposures into stages depending on the changes in credit quality relative to the initial recognition in accounting records. The manner of calculation of an impairment loss depends on the stage:

Stage	Criterion for classification (stages)	Manner of calculation of an impairment loss
Stage 1	Exposures for which from the initial recognition until the reporting date no significant increase in credit risk was identified and with no impairment	12-month expected credit loss
Stage 2	Exposures for which from the initial recognition until the reporting date a significant increase in credit risk was identified and with no impairment	Lifetime expected credit losses
Stage 3	Impaired exposures
POCI	Exposures impaired at initial recognition

As at the date of these financial statements, in its loan portfolio the Bank held financial assets classified as POCI at initial recognition (i.e. purchased or originated credit-impaired assets). POCI financial assets remain classified as POCI in all subsequent periods until they are derecognised. This principle applies even when the asset is cured in the meantime, which means that assets that have been recognised as POCI retain that status regardless of any future changes in estimates of cash flows to be generated by such assets. For POCI instruments credit losses are recognised at amounts of lifetime expected credit losses throughout the expected life of the instruments.

Impairment of credit exposures

The Bank regularly reviews credit exposures to identify credit exposures in respect of which the credit risk has increased significantly, or with impairment risk, to measure impairment of credit exposure and to recognise impairment allowances.

The process of recognising impairment allowances comprises the following stages:

§ identification of significant increases in credit risk,

§ identifying evidence of impairment and impairment triggers,

§ registering impairment triggers for credit exposures in IT systems of the Bank,

§ determining the method of impairment measurement,

§ measuring impairment and determining the impairment allowance,

§ reviewing and aggregating results of impairment measurement,

§ reporting results of impairment measurement.

The method of determining amount of impairment allowance depends on the type of impairment objective evidence and an individual size of the credit exposure.

Individual impairment triggers include in particular:

§ loan becomes past due more than 90 days,

§ significant deterioration of the customer’s financial condition,

§ conclusion of a debt restructuring agreement or debt relief (evidence is recognised if these actions were required for business and legal reasons resulting from financial difficulties of the client).

When determining the delinquency period, the Bank accounts for overdue interest and principal amounts in excess of thresholds determined.

Impairment testing methods

There are two methods of impairment testing applicable at the Bank:

§ individual testing − applied to exposures which are individually significant, for which an indication of impairment was identified,

§ collective testing – applied to exposures:

- for which no indication for impairment was identified and for which individual testing has not indicated an impairment;

- which are individually insignificant, for which indication for impairment was identified.

When determining the impairment loss amount using the individual approach, expected future cash flows are estimated for each credit exposure individually.

The Bank tests the impairment amount on a collective basis using portfolio parameters estimated with statistical methods, based on historical data on exposures of the same nature.

Impairment loss on credit exposures tested on a collective basis is equal to the difference between the carrying amount of these exposures and the present value of future cash flows estimated using statistical methods based on historical data on exposures in homogeneous portfolios.

Impairment loss on loan and financial guarantee commitments is determined as the difference between the expected value of the balance sheet exposure resulting from the off-balance-sheet liability granted (from the test date to the date of overdue debt constituting the objective evidence of impairment of individually significant exposures) and the present value of future cash flows from the balance sheet exposure resulting from the off-balance-sheet liability.

Calculation of expected credit losses

Calculation of lifetime expected credit losses requires the application of risk parameters for many years. For the purposes of calculation of a credit loss in accordance with IFRS 9, the Bank compares cash flows that it should collect under a loan agreement with the cash flows that the Bank estimates to collect. The Bank discounts the difference with the original effective interest rate, and in the case of POCI assets – with the credit risk-adjusted original effective interest rate.

Method of calculation of collective parameters – PD, RR and EAD

The PD parameters amount to an assessment of the probability of default in subsequent annual periods over the lifetime of an exposure. A PD curve concerning a given exposure is dependent on the current value of the 12-month PD parameter (and the relevant rating class) determined based on the Bank’s internal PD models.

In the estimation process the Bank takes into account both existing and forecast macroeconomic conditions (Paragraph 5.5.17(c) of IFRS 9).

Parameters are calculated depending on the type of homogeneous portfolio. Homogenous groups of exposures were defined based on the following features:

§ customer segment,

§ type of product,

§ credit rating or assessment process in line with an adopted scale,

§ stage of loan handling,

§ delay in repayment.

The most common method of LGD calculation applied at the Bank is the calculation of the expected recovery rates (RR) based on the Roll Rates model, under which within homogenous groups average monthly recoveries are calculated conditionally against the period of default.

Average monthly recovery rates represent repayments and recoveries weighted by the outstanding principal amount observed at the beginning of a given month since default.

As part of measurement of expected credit losses for exposures with a repayment schedule, the Bank determines a single amount of expected loss (allowance). The amount is first charged as an allowance against the credit exposure, up to the equivalent of the book value of the credit exposure. If the total allowance is greater than the book value of the credit exposure, the difference is charged to off-balance-sheet portion of the exposure.

For exposures for which no repayment schedule is available, the allowance is measured separately for the on-balance-sheet and off-balance-sheet portion of the credit exposure (based on calculated amounts of EAD for balance-sheet items and off-balance-sheet items).

For exposures for which it is not possible to determine risk parameters based on internal models, the Bank adopts an approach based on using parameters from other portfolios with similar characteristics or expert parameters, in particular where a portfolio for which a parameter is to be determined is small or treated as a low default portfolio.

The models and parameters used to calculate allowances are periodically reviewed for their adequacy – once every six months, and validated on an annual basis. Validation is implemented as part of a group of processes governed by the “Rules of model management at Bank Gospodarstwa Krajowego” and carried out by the Bank’s Head Office organisational unit which is not involved in creation, implementation and use of the model. The process is aimed at assessing the model’s efficiency and consists in, among other things, analysis of whether the model concept and assumptions are adequate for the decision-making process or mechanism in which the model is applied, and whether it has been properly structured and implemented in practical and formal terms.

The outcome of the validation is documented in a validation report, which includes, inter alia, a description of actions taken and their results, together with recommendations, if any, with the assigned risk category and their materiality assessment. The report is presented at the Model Management Committee and submitted to the Operational Risk Office.

Low credit risk criterion

In accordance with Paragraph 5.5.10 of IFRS 9 exposures that are considered as low risk credit exposures at the reporting date may remain in Stage 1 if the quantitative criterion of a significant increase in credit risk since initial recognition is met. If a qualitative criterion is met or if exposures become past due by more than 30 days, the exposures are transferred to Stage 2. In accordance with Paragraph B.5.5.22 of IFRS 9, the credit risk of a financial instrument is considered low if:

§ the financial instrument has a low default risk,

§ the borrower has a strong capacity to meet its contractual obligations in the near term,

§ adverse changes in economic and business conditions in the longer term may, but will not necessarily, reduce the ability of the borrower to fulfil its contractual obligations.

The Bank does not consider that credit exposures have low credit risk when it regards them as having a low risk of loss simply because of the value of collateral and the credit exposure without that collateral would not be considered low credit risk. Also, the Bank does not consider that credit exposures have low credit risk simply because they have a lower default risk than the borrower’s other credit exposures or relative to the credit risk of the jurisdiction within which the borrower operates.

The Bank applies the low credit risk criterion to credit exposures with a low internal risk rating (first four classes), which do not meet the qualitative or past-due criteria as the criteria of a significant increase in credit risk.

44.3. Financial assets with an identified significant increase in credit risk

Financial assets for which at the reporting date the Bank identifies a significant increase in credit risk since initial recognition are classified in Stage 2. The Bank considers that for a given asset a significant increase in credit risk has been identified if a quantitative or qualitative criterion is met or if contractual payments are more than 30 days past due, whereas the occurrence of a given criterion is assessed at the exposure level.

Quantitative criteria of an increase in credit risk

A quantitative criterion is applied only to homogenous portfolios of credit exposures with assigned internal ratings. Assessment of a quantitative criterion consists in comparing the existing (at the reporting date) level of credit risk (risk of default) with the level of credit risk as at the date of initial recognition. The process is aimed at assessing the increase of credit risk based on a change in the credit risk over the expected life of the exposure (LtPD – life time probability of default).

The transfer of credit exposure from Stage 1 to Stage 2 is made following an assessment of an increase in credit risk and is based only on the risk of default. Changes in LGD do not result in transfers of exposures between Stage 1 and Stage 2.

Classification to Stage 2 is based on the limit of the materiality threshold, determined as a relative value above which an exposure is classified to Stage 2 by comparing the LtPD at the reporting date with the LtPD as at the date of initial recognition. For both curves, the comparison is made for identical period, i.e. from the reporting date until maturity.

For certain portfolios covered by rating models, reclassification of exposures to Stage 2 is based on classification to a specific rating class at the reporting date, above which the exposure is classified to Stage 2, or the credit exposure is ranked above a specific rating class as at the reporting date and there was a change in the rating class by a specific number of classes. A change in rating classes is determined based on comparison of a rating class as at the reporting date with the rating class as at the date of initial recognition.

Limit values of the relative change in credit risk that qualify exposures to be classified to Stage 2 are verified as part of a model review, which is carried out at least each year.

Qualitative criteria of an increase in credit risk

Qualitative criteria of a significant increase in credit risk are selected from the catalogue of Early Warning Signals (EWS) and are defined as “strong” in accordance with the classification applied at the Bank. Their occurrence is associated with a high likelihood of a default of an exposure. The criteria are considered indicative and require confirmation each time they occur.

In addition, a credit exposure which is overdue by more than 30 days is treated as a criterion of a significant increase in risk.

44.4. Financial assets with identified impairment

The Bank assesses all credit exposures (credit exposure groups) for existence of objective evidence of impairment using the most recent data available to the Bank as at the date of revaluation, based on a catalogue of impairment triggers defined in internal regulations governing the recognition and measurement of expected credit losses.

Financial assets for which at the reporting date the Bank has identified the occurrence of an impairment trigger are classified in Stage 3. The Bank analyses the occurrence of evidence of impairment at the level of an agreement/transaction and customer.

If evidence of impairment is identified for a customer of any of its credit exposures, all other credit exposures of that customer are treated as exposures for which evidence of impairment exists.

In the case of related parties, existence of evidence of impairment at either of such parties does not result in the treatment of exposures of other related parties as exposures for which evidence of impairment exists.

44.5. Inclusions of expectations regarding future macroeconomic conditions

IFRS 9 requires the Bank to take into account expectations regarding the macroeconomic situation in the calculation of expected credit losses. As required by Paragraph 5.5.4 of IFRS 9, the Bank adjusts risk parameters to take into account forecast forward-looking macroeconomic information (such as: interest rate, foreign exchange rates), for portfolios for which it has identified a dependency. The source of information on the values of macroeconomic factors are forecasts prepared by the Bank’s economic analysts.

44.6. Derivative financial instruments

In the case of derivatives, the Bank is exposed to the risk of default by the counterparty to a transaction related to a given derivative. In the case of customers other than banks, settlements are usually made in net amounts which protects the Bank against a potential settlement risk. In justified cases, the Banks secures additional collaterals in the form of deposits from customers in order to limit the risk.

44.7. Credit risk resulting from granted liabilities

The Bank offers their customers guarantees whereby the Bank may be obliged to make a payment on their behalf and enter into obligations to extend granted loans to satisfy their liquidity needs. Under the terms of letters of credit and guarantees (including standby letters of credit), the Bank is obliged to make payments on behalf of its customers in specific cases, usually related to imports and exports of goods. Such obligations expose the Bank to a risk similar to the risk related to loans which is mitigated by the same risk control processes and policies.

44.8. Rating system applied at the parent entity

The Bank manages the credit quality of assets using, inter alia, internal credit ratings. The Bank applies internal ratings with respect to local government units, enterprises and healthcare entities conducting full financial reporting, foreign entities, housing cooperatives and social housing associations.

The Bank applies a master scale for the rating methods used for individual customer segments, from 1 to 20.

Pursuant to the adopted policy, the Bank applies risk rating to the majority of credit exposures in the loan portfolio. This helps appropriately manage the existing risk and compare the credit risk with reference to various customer and product segments.

Customers without internal ratings mainly comprise new transactions that finance investment ventures in the form of special purpose vehicles.

44.9. Analysis of the maximum exposure to credit risk, risk related to collaterals, and other elements improving the lending terms and conditions

The table below presents the maximum exposure to credit risk, divided into financial assets classes.

Maximum exposure to credit risk excluding collaterals (by classes of financial instruments)	31 Dec 2020	31 Dec 2019
Cash in Central Bank	32,262,257	22,729,376
Amounts due from banks	5,606,383	6,938,693
Derivative financial instruments	997,397	574,907
Securities	76,902,180	28,311,229
Reverse repurchase agreements	4,207,234	5,301,537
Loans and advances to customers	33,451,675	30,912,329
Other assets	4,557,431	3,770,797
Total	157,984,557	98,538,868

	31 Dec 2020	31 Dec 2019*
Maximum exposure to credit risk in connection with the provided guarantees	18,057,784	15,244,853

* Data adjusted for the recognition of the COSME portfolio guarantee facility

The Bank holds a significant portfolio of guarantees granted mostly to non-financial entities, including enterprises. Maximum exposure to credit risk in connection with guarantees given by the Bank as at the end of 2020 was PLN 18,057,784 thousand.

44.10. Qualitative structure and portfolio distribution

The Bank manages the credit quality of assets using a whole range of methods to mitigate credit risk, including internal credit ratings. The rating system applied at the Bank uses various financial analytical tools and processed market information to obtain major input data for measuring the risk related to an individual customer. The rating models are monitored and validated on an ongoing basis.

When determining and monitoring customers’ credit risk, the Bank also uses the ratings assigned to the customers by reputable rating agencies.

The tables below present portfolio allocation.

· Loans and advances to customers and banks, liabilities under loans and guarantees granted, debt instruments and derivatives by credit risk rating

Loans and advances to customers and banks at amortised cost as at 31 December 2020
Internal rating	Stage 1	Stage 2	Stage 3	POCI	Total
Rating from 1 to 13	23,067,787	2,388,569	394,813	0	25,851,169
Rating from 14 to 17	3,259,238	1,178,976	332,599	23,311	4,794,124
Rating 18 and below*	29,782	78,007	1,304,881	5,000	1,417,670
no rating	2,564,948	181,451	320,508	0	3,066,907
Total gross carrying amount	28,921,755	3,827,003	2,352,801	28,311	35,129,870
Impairment allowances	202,083	144,553	1,006,976	919	1,354,531
Total net carrying amount	28,719,672	3,682,450	1,345,825	27,392	33,775,339

* Clients in Stage 1 and 2 with the assigned final rating of “Rating 18 and below” have the quantitative rating (criterion of evidence of impairment) of less than 18, thus there is no evidence of impairment.

Loans and advances to customers and banks at amortised cost as at 31 December 2019
Internal rating	Stage 1	Stage 2	Stage 3	POCI	Total
Rating from 1 to 13	22,451,468	1,726,491	203,161	55	24,381,175
Rating from 14 to 17	277,668	546,466	285,062	0	1,109,196
Rating 18 and below*	69,098	160,633	1,129,175	0	1,358,906
no rating	5,182,185	270	350,555	0	5,533,010
Total gross carrying amount	27,980,419	2,433,860	1,967,953	55	32,382,287
Impairment allowances	179,855	121,165	774,751	-7,703	1,068,068
Total net carrying amount	27,800,564	2,312,695	1,193,202	7,758	31,314,219

* Clients in Stage 1 and 2 with the assigned final rating of “Rating 18 and below” have the quantitative rating (criterion of evidence of impairment) of less than 18, thus there is no evidence of impairment.

Financial and guarantee liabilities granted at amortised cost as at 31 December 2020
Internal rating	Stage 1	Stage 2	Stage 3	Total
Rating from 1 to 13	20,407,195	939,641	125,005	21,471,841
Rating from 14 to 17	4,003,799	739,608	32,180	4,775,587
Rating 18 and below*	6,961	1,200	413,984	422,145
no rating	43,916,288	197,486	164	44,113,938
Total gross	68,334,243	1,877,935	571,333	70,783,511
Impairment allowances	189,098	41,644	218,955	449,697

* Clients in Stage 1 and 2 with the assigned final rating of “Rating 18 and below” have the quantitative rating (criterion of evidence of impairment) of less than 18, thus there is no evidence of impairment.

Financial and guarantee liabilities granted at amortised cost as at 31 December 2019
Internal rating	Stage 1	Stage 2	Stage 3	Total
Rating from 1 to 13	16,878,530	472,465	112,808	17,463,803
Rating from 14 to 17	573,033	90,662	37,516	701,211
Rating 18 and below*	33,487	3,861	307,790	345,138
no rating	45,613,980	0	67,483	45,681,463
Total gross	63,099,030	566,988	525,597	64,191,615
Impairment allowances	149,334	8,126	186,850	344,310

* Clients in Stage 1 and 2 with the assigned final rating of “Rating 18 and below” have the quantitative rating (criterion of evidence of impairment) of less than 18, thus there is no evidence of impairment.

Loans and advances to customers obligatorily measured at fair value through profit or loss as at 31 December 2020
Internal rating	Stage 1	Stage 2	Stage 3	Total
Rating from 1 to 13	102,266	0	0	102,266
Total carrying amount	102,266	0	0	102,266

Loans and advances to customers obligatorily measured at fair value through profit or loss as at 31 December 2019
Internal rating	Stage 1	Stage 2	Stage 3	Total
Rating from 1 to 13	124,870	0	0	124,870
Total carrying amount	124,870	0	0	124,870

· Exposures to banks under deposits, current accounts and other receivables by internal class of risk (in 2020, the risk classification for banks was extended from I-XII to I-XX (the two scales are not comparable)).

Exposures to banks under deposits, current accounts and other receivables at amortised cost by internal class of risk (in the I-XX scale implemented in 2020)	31 Dec 2020
IV	1,299,966
V	500,001
VI	500,002
VII	350,001
IX	993,878
XI	230,693
no risk class*	1,306,402
Total gross carrying amount	5,180,943
Impairment allowances	490
Total net carrying amount	5,180,453

* nostro current accounts, other

Exposures to banks under deposits, current accounts and other receivables at amortised cost by internal class of risk (in the I-XII scale applicable until 2019)	31 Dec 2019
I	179,019
II	589,221
IV	200,298
V	115,221
no risk class*	5,329,696
Total gross carrying amount	6,413,455
Impairment allowances	1,522
Total net carrying amount	6,411,933

* nostro current accounts, other

· Exposure to debt instruments by external rating

Exposures under debt securities at amortised cost by external rating as at 31 December 2020
Internal rating	Stage 1	Stage 2	Stage 3	Total
BBB	2,688,499	0	0	2,688,499
no rating, including internal rating:	17,018,959	93,631	633,729	17,746,319
Rating from 1 to 13	2,688,850	33,279	202,509	2,924,638
Rating from 14 to 17	135,985	60,352	0	196,337
Rating 18 and below	0	0	431,220	431,220
Rating SP	14,194,124	0	0	14,194,124
Total gross carrying amount	19,707,458	93,631	633,729	20,434,818
Impairment allowances	19,963	3,464	178,920	202,347
Total net carrying amount	19,687,495	90,167	454,809	20,232,471

Exposures under debt securities at amortised cost by external rating as at 31 December 2019
Internal rating	Stage 1	Stage 2	Stage 3	Total
BBB	2,852,244	0	0	2,852,244
BB	125,242	0	0	125,242
no rating, including internal rating:	3,567,547	309,189	675,371	4,552,107
Rating from 1 to 13	3,232,820	113,498	218,332	3,564,650
Rating from 14 to 17	334,727	195,691	234,975	765,393
Rating 18 and below	0	0	222,064	222,064
Total gross carrying amount	6,545,033	309,189	675,371	7,529,593
Impairment allowances	30,231	8,648	92,780	131,659
Total net carrying amount	6,514,802	300,541	582,591	7,397,934

Exposure to debt instruments at fair value through other comprehensive income by external rating as at 31 December 2020
External rating	Stage 1	Stage 2	Stage 3	Total
BBB	811,485	0	0	811,485
BB	515,373	0	0	515,373
no rating, including internal rating:	53,365,806	264,296	0	53,630,102
Rating from 1 to 13	1,553,849	264,296	0	1,818,145
Rating from 14 to 17	0	0	0	0
Rating 18 and below	0	0	0	0
Rating SP*	50,684,344	0	0	50,684,344
Rating from I to VI**	935,746	0	0	935,746
Rating from VII to XIII	191,867	0	0	191,867
Rating from XIV to XX	0	0	0	0
Total gross carrying amount	54,692,664	264,296	0	54,956,960
Impairment allowances***	5,423	2,450	0	7,873
* Exposures with the rating “R_SP” are mainly attributable to the National Bank of Poland (money bills) and the Ministry of Finance (treasury bonds).
** Ratings for banks
*** The impairment allowance on debt instruments at fair value through other comprehensive income is recognised under “Revaluation reserve” and does not decrease the relevant carrying amount

Exposure to debt instruments at fair value through other comprehensive income by external rating as at 31 December 2019
External rating		Stage 1		Stage 2		Stage 3		Total
A / AA		219,528		0		0		219,528
BBB		2,953,865		0		0		2,953,865
BB		460,993		0		0		460,993
no rating, including internal rating:		15,450,648		36,281		0		15,486,929
Rating from 1 to 13		1,455,261		36,281		0		1,491,542
Rating from 14 to 17		0		0		0		0
Rating 18 and below		0		0		0		0
Rating SP*		13,656,576		0		0		13,656,576
Rating from I to VI**		338,811		0		0		338,811
Rating from VII to XIII		0		0		0		0
Rating from XIV to XX		0		0		0		0
Total carrying amount		19,085,034		36,281		0		19,121,315
Impairment allowances***		6,608		256		0		6,864
* Exposures with the rating “R_SP” are mainly attributable to the National Bank of Poland (money bills) and the Ministry of Finance (treasury bonds).
** Ratings for banks
*** The impairment allowance on debt instruments at fair value through other comprehensive income is recognised under “Revaluation reserve” and does not decrease the relevant carrying amount
Reverse repurchase agreements by external rating as at 31 December 2020
External rating	Stage 1		Stage 2		Stage 3		POCI		Total
A / AA	4,207,234		0		0		0		4,207,234
Total	4,207,234		0		0		0		4,207,234

Reverse repurchase agreements by external rating as at 31 December 2019
External rating	Stage 1	Stage 2	Stage 3	POCI	Total
A / AA	5,301,537	0	0	0	5,301,537
Total	5,301,537	0	0	0	5,301,537

Derivatives by external rating as at 31 December 2020
External rating	Banks	Other financial institutions	Non-financial entities	Total
AA	19,728	0	0	19,728
AA-	14,878	0	0	14,878
A+	142,227	0	0	142,227
A	99,536	0	0	99,536
A-	2,937	0	467,761	470,698
BBB+	76,702	0	0	76,702
BBB-	209	0	0	209
BB	1,752	0	0	1,752
no rating, including internal rating:	0	56,605	115,062	171,667
Rating from 1 to 13	0	0	97,108	97,108
Rating from 14 to 17	0	0	7,635	7,635
Rating 18 and below	0	0	10,319	10,319
no rating	0	56,605	0	56,605
Total carrying amount	357,969	56,605	582,823	997,397

Derivatives by external rating as at 31 December 2019
External rating	Banks	Other financial institutions	Non-financial entities	Total
A+	203,502	0	0	203,502
A	106,170	0	0	106,170
A-	42,136	0	0	42,136
AA-	11,872	0	0	11,872
BBB+	44,192	0	0	44,192
BBB	0	0	18,975	18,975
no rating, including internal rating:	0	99,427	48,633	148,060
Rating from 1 to 13	0	0	44,707	44,707
Rating from 14 to 17	0	0	3,509	3,510
Rating 18 and below	0	0	41	41
no rating	0	99,427	375	99,802
Total carrying amount	407,872	99,427	67,607	574,907

Exposure to debt instruments by external rating	31 Dec 2020	31 Dec 2019
Debt instruments held for trading
A / AA	19,675		1,666
Total	19,675		1,666
Debt instruments at fair value through profit or loss
A / AA	93,232		87,051
BBB	92,836		86,084
no rating, including internal rating:	5,975		54,036
Rating from 1 to 13	5,975		54,036
Total carrying amount	192,043		227,171

The parent entity’s portfolio is characterised by a relatively low value of past due exposures in Stage 1 and 2. In those Stages, there were 30 past due exposures in the range of 1-30 days for a total of PLN 7,574 thousand and 4 past due exposures in the range of 31-90 days for a total of PLN 5,458 thousand. Exposures past due by more than 90 days (Phase 3) accounted for 1.2% of the loan portfolio, compared to the ratio of Stage 3 exposures to the loan portfolio at 6.7%.

44.11. Concentration risk analysis

Concentration risk is the risk resulting from exposure with respect to individual entity or entities with capital and organisational relations, entities operating in the same industry, economy sector, entities operating in the same geographical region, using the same type of collateral or collateral offered by the same provider, in the same currency, with respect to the entities referred to in Article 79.1 of the Banking Law, which may have a material impact on the stability and security of the Bank’s operations in case of default by such individual entity, by entities with capital and organisational links or by groups of entities where the probability of a default depends on shared factors.

The Bank controls the level of credit risk exposure:

§ jointly and broken down into own activities as well as related to the service of fund created, entrusted or transferred on the basis of separate acts,

§ for exposure concentration to one entity and/or entities related by capital or organisation,

§ by large exposures,

§ by individual industries,

§ separately by mortgage-backed exposures,

§ by selected segments and products,

§ by currency or currency-indexed transactions,

§ by off-balance-sheet liabilities granted by the Bank (guarantees, sureties, and letters of credit).

Risk of concentration of large exposures

The Bank applies regulatory concentration limits for large exposures resulting from the CRR, Banking Law and specific regulations included in the Act on BGK. These limits are additionally reduced by the resolution of the Bank’s Management Board on the maximum level of exposure to an individual customer or group of related customers as at the time of making a funding decision.

Utilisation of the concentration limit is assessed and monitored on a daily basis. If the concentration limit is exceeded, all parties involved in the lending and investment process are immediately notified of the fact.

The Bank’s adopted safe level of exposure to a group of related entities or to a single customer was not exceeded as at the end of 2020. As at 31 December 2020, large exposure concentration risk for the Bank’s largest exposure (after deductions) to a single entity was 15.5% of the Bank’s eligible capital (as at 31 December 2019: 19.5%).

Group’s exposure to the 20 largest non-bank customers *
	31 Dec 2020		31 Dec 2019
No.	Exposure*	Share in the loan portfolio	Exposure*	Share in the loan portfolio
1.	3,638,452	8.0%	3,480,357	8.0%
2.	3,592,479	7.9%	3,305,662	7.6%
3.	2,956,986	6.5%	3,179,245	7.3%
4.	2,861,996	6.3%	2,969,142	6.8%
5.	2,368,726	5.2%	1,771,440	4.1%
6.	2,257,987	5.0%	1,529,322	3.5%
7.	1,683,220	3.7%	1,480,064	3.4%
8.	1,567,146	3.4%	1,279,648	2.9%
9.	1,320,638	2.9%	1,059,899	2.4%
10.	1,104,285	2.4%	1,002,002	2.3%
11.	1,050,053	2.3%	863,624	2.0%
12.	1,004,341	2.2%	662,046	1.5%
13.	987,236	2.2%	596,983	1.4%
14.	752,699	1.7%	550,592	1.3%
15.	635,056	1.4%	549,617	1.3%
16.	562,793	1.2%	521,972	1.2%
17.	548,169	1.2%	515,131	1.2%
18.	530,928	1.2%	462,793	1.1%
19.	499,904	1.1%	409,937	0.9%
20.	475,275	1.0%	390,063	0.9%
Total	30,398,369	66.9%	26,579,539	61.2%

* includes balance-sheet and off-balance-sheet credit exposure: loans, advances, purchased debts, promissory note discount, guarantees, debt securities, and derivative transaction limits. The amount of exposure is calculated for the purposes of external limits (large exposure concentration limits) without deductions. The data does not cover the exposure to the central government.

As at 31 December 2020, large exposure concentration risk for the Bank’s largest exposure (after deductions) to a group of associated clients was 19.7% of the Bank’s eligible capital (as at 31 December 2019: 30.6%).

Group’s exposure to five largest non-bank groups
	31 Dec 2020		31 Dec 2019
No.	Exposure*	Share in the loan portfolio	Exposure*	Share in the loan portfolio
1.	4,624,397	10.2%	4,829,388	11.1%
2.	4,322,828	9.5%	4,212,677	9.7%
3.	3,962,873	8.7%	4,131,507	9.5%
4.	3,614,695	7.9%	3,480,357	8.0%
5.	3,592,479	7.9%	2,969,142	6.8%
Total	20,117,272	44.2%	19,623,071	45.1%

* Includes balance-sheet and off-balance-sheet credit exposure: loans, advances, purchased debts, promissory note discount, guarantees, debt securities, and derivative transaction limits. The amount of exposure is calculated for the purposes of external limits (concentration limits) without deductions. The data does not cover the exposure to the central government.

Geographical concentration risk

Concentration of exposures from the perspective of geographical areas is monitored based on the existing division into the Bank’s field units (regional units) and by province. The Bank has regional units in all province capitals.

The Bank’s loan portfolio is highly concentrated in geographical terms – nearly 70% of the loan portfolio is concentrated in five provinces. However, such a high concentration follows from the exposure to large groups of entities whose head offices are located in large cities, e.g. in Warsaw, while their production plants are located in different regions of the country. This applies, inter alia, to entities from the power and fuel sectors. Due to the specific nature of the Bank’s clients, the Bank does not set geographical limits.

Industry concentration risk

To ensure that the loan portfolio is secure and effective, the Bank manages industry concentration risk using a system of internal industry limits. Attribution of a given customer to an industry limit is based on customer classification into a given industry made and reviewed by the Bank’s employee based on information on the type of the customer’s business activity.

Concentration of exposures from the perspective of industries is monitored on a daily basis pursuant to the internal procedures for the internal industry limits. If the limit is used in at least 90%, relevant measures are taken to prevent exceeding a given limit.

The used tools and methods that support the monitoring of credit exposures and customers allow to react quickly if the quality of the portfolio or individual credit exposures deteriorate, and take remedial measures.

Concentration of exposures in national economy sectors (balance sheet exposure) *	31 Dec 2020		31 Dec 2019
Branch of industry	Amount of exposure	Total share in exposure	Amount of exposure	Total share in exposure
Public administration and defence, compulsory social security	11,471,179	25.2%	10,204,048	21.9%
Construction	5,070,539	11.2%	5,184,181	11.1%
Production and supply of electricity, gas and steam	4,939,418	11.0%	5,354,674	11.4%
Water supply, sewerage, waste management, and remediation activities	604,813	1.3%	572,003	1.2%
Financial and insurance activities	2,247,774	4.9%	1,884,863	4.0%
Professional, research, and technical activities	2,336,746	5.1%	2,717,160	5.8%
Administrative and support services activities	38,785	0.1%	21,055	0.0%
Education	100,015	0.2%	86,525	0.2%
Mining and extraction	2,234,616	4.9%	2,825,011	6.1%
Wholesale and retail trade	644,300	1.4%	543,142	1.2%
Hotels and restaurants	363,180	0.8%	213,188	0.5%
Information and communication	677,878	1.5%	687,827	1.5%
Property management and administration	1,723,572	3.8%	1,547,369	3.3%
Healthcare and social security	1,564,899	3.4%	1,247,525	2.7%
Other services, cultural, entertainment, and recreation activities	316,977	0.7%	199,211	0.4%
Industrial processing	3,285,305	7.2%	4,147,082	8.9%
Agriculture, forestry, hunting, and fishery	35,584	0.1%	34,319	0.1%
Transport, storage	3,637,679	8.0%	3,819,163	8.2%
Other (no Polish Classification of Activity (PKD) number, natural persons)	4,176,431	9.2%	5,354,674	11.5%
Total	45,469,690	100.0%	46,643,020	100.0%

* Includes balance-sheet credit exposure: loans, advances, purchased debts, promissory note discount, guarantees and debt securities.

The Bank applies industry limits to mitigate the risk related to financing customers operating in selected industries with a high level of credit risk and to avoid excessive levels of industry concentration.

The portfolio is dominated by public administration due to BGK’s close cooperation with the government and local governments. Another relatively large groups of exposures are the electricity, gas and water supply industry, construction, industrial processing and transportation, and storage industries, Mainly due to the fact that the Bank engages in funding ventures which are strategic from the point of view of the State Treasury, including in the sectors of energy, fuel and chemistry, and transport. Such ventures are implemented in the form of large investment projects.

Risk of currency concentration in the loan portfolio

The Bank monitors the currency structure of its loan portfolio and risk associated with individual portfolios on a regular basis. The prevailing currency in the portfolio is PLN (approximately 83.6%). Exposures in EUR and USD account for an aggregate of approximately 14.0%. Exposures in CHF account for an insignificant portion of the Bank’s loan portfolio and chiefly include receivables from retail customers.

Credit risk concentration by currency	31 Dec 2020	31 Dec 2019
PLN	81.5%	83.1%
Foreign currencies, including:	18.5%	16.9%
- EUR	10.6%	9.8%
- USD	7.7%	6.5%
- CHF	0.1%	0.1%
- other	0.1%	0.5%
Total	100.0%	100.0%

44.12. Collaterals and other forms of credit risk mitigation

The main instrument used to reduce the credit risk is legal protection of the Bank’s receivables. The Bank applies an internal procedure for the establishment and evaluation of legal collaterals for receivables as at the inception of the transactions bearing credit risk and for monitoring the collateral during the transaction’s life.

The Bank uses the following instruments and methods to limit or reduce the credit risk to acceptable levels:

§ risk diversification,

§ risk protection,

§ risk sharing,

§ risk compensation.

To mitigate the credit risk, when calculating the risk-weighted exposures in the Bank’s portfolio, the Bank accounts for the credit protection, in line with the internal procedures on legal protection of the Bank’s receivables.

Collateral policy

The amount and type of collateral depends on the evaluation of the credit risk related to an individual counterparty. The Bank follows specific guidelines on the acceptability and evaluation of each type of collateral.

Main types of collaterals:

§ for securities lending and reverse repo − cash and securities;

§ for commercial loans − collateral in the form of mortgages and registered pledges on movables.

The Bank monitors the market value of collateral for each lending transaction and, if necessary, it demands additional collateral in line with the loan agreement.

Pursuant to the adopted policy, the Bank manages the seized collateral in an orderly manner. Any proceeds are used to reduce or repay overdue receivables. The Bank does not use seized collateral for business purposes.

The basis for calculating the recoverable amount of collaterals is the appraisal value verified by the Bank using the indicators adjusting the value of collaterals. Moreover, the fulfilment of formal and legal conditions for collateral acceptance is verified each time, as well as whether it is funded and liquid, and also its correlation to the economic and financial standing of the debtor. In the case of unfunded collaterals, the economic and financial standing of the collateral issuer is additionally examined.

The Bank monitors the legal collaterals of lending transactions on a periodical basis.

Collaterals and other forms of credit risk mitigation
Fair value of the collateral	31 Dec 2020	31 Dec 2019
Mortgages	48,094,752	38,703,081
Pledges	1,338,313	3,059,299
Guarantees and sureties, including:	7,509,787	7,536,403
- bank guarantees	2,211,804	2,106,911
- government guarantees	3,777,714	3,974,308
- other guarantees and sureties	1,520,269	1,455,184
Cash deposits	479,490	224,227
Other	4,371	25,390
Total	57,426,713	49,548,400

Credit exposures are most often secured (at fair value) by mortgages, guarantees and sureties. Credit exposures secured by guarantees provided by the State Treasury and local government units (designated as government guarantees) ensure the maximum risk reduction. Primarily, local government units offer sureties for exposures of affiliated Social Housing Associations, hospitals, and municipal companies.

For credit exposures fully secured by deposits of specific amounts made in the Bank’s account (pursuant to Article 102 of the Banking Law) the Bank does not recognise any allowances for expected credit losses. The gross carrying amount of such exposures as at 31 December 2020 was PLN 477,481 thousand.

Gross carrying amount of financial instruments for which the parent entity has not recognised a loss allowance because of the collateral as at 31 December 2020
Internal rating	Stage 1	Stage 2	Stage 3	Total
Rating from 1 to 13	3,339	0	0	3,339
Rating 18 and below	9,955	0	0	9,955
Total carrying amount	13,294	0	0	13,294

Gross carrying amount of financial instruments for which the parent entity has not recognised a loss allowance because of the collateral as at 31 December 2019
Internal rating	Stage 1	Stage 2	Stage 3	Total
Rating from 1 to 13	4,228	0	0	4,228
Rating 18 and below	8,506	0	0	8,506
Total carrying amount	12,734	0	0	12,734

44.13. Forbearance practices

The Bank applies the definition of forbearance to credit exposure which has been addressed with forbearance measures. The restructuring measures comprise concessions offered by the Bank to the borrower who experiences or will soon begin to experience difficulties with repayment of financial liabilities (financial distress).

In connection with the COVID-19 pandemic, the Bank did not change its approach to existing exposures classified as forborne. Similarly, in the case of concessions granted in connection with COVID-19 to clients who do not have forborne exposures, such concessions are not treated as forbearance.

Forbearance measures comprise the following:

§ change in the terms and conditions of a contract underlying the credit exposure which has been classified as “non-performing” before the change or which would have been classified as “non-performing”, if it had not been changed,

§ change in the terms and conditions of a contract underlying the credit exposure consisting in a full or partial write-off on the exposure,

§ the Bank approves the use of embedded forbearance clauses for a borrower who is non-performing or who would be considered as non-performing without the use of those clauses,

§ repayment of the principal amount or interest on another credit exposure at the Bank by the borrower, if the exposure was non-performing at the time or around the time when the Bank applied the facility in the form of additional funding or would have been classified as non-performing if the facility had not been applied,

§ change leading to repayments resulting from utilisation of the collateral, if such change qualifies as a concession.

It is considered that the exposures are no longer forborne, if all the conditions presented below have been met:

§ the credit exposure is considered as “performing”, including if it has been reclassified from the “non-performing” category after an analysis of the financial condition of the borrower showed it no longer met the conditions to be considered as “non-performing”,

§ a minimum 2 year probation period has passed from the date the forborne exposure was considered as “performing”,

§ regular payments of interest and principal amount were made for at least 12 out of 24 months of the quarantine period;

§ as at the end of the quarantine period, none of the exposures with respect to the customer was overdue by more than 30 days.

Forborne exposures as at 31 December 2020
Loans and advances to customers at amortised cost, including:	Stage 1	Stage 2	Stage 3	Total
Gross forborne exposures	4,286	2,000	323,580	329,866
- financial sector	0	0	10,126	10,126
- non-financial sector	0	2,000	283,865	285,865
- public sector	4,286	0	29,589	33,875
Impairment allowances	53	11	102,647	102,711
Net forborne exposures	4,233	1,989	220,933	227,155
Debt instruments at amortised cost
Debt instruments at amortised cost	0	0	120,532	120,532
Impairment allowances	0	0	84,854	84,854
Net forborne exposures	0	0	35,678	35,678

Forborne exposures as at 31 December 2019
Loans and advances to customers at amortised cost, including:	Stage 1	Stage 2	Stage 3	Total
Gross forborne exposures	1	0	440,765	440,766
- non-financial sector	1	0	377,597	377,598
- public sector	0	0	63,168	63,168
Impairment allowances	1	0	90,613	90,614
Net forborne exposures	0	0	350,152	350,152
Debt instruments at amortised cost
Debt instruments at amortised cost	0	0	213,379	213,379
Impairment allowances	0	0	63,794	63,794
Net forborne exposures	0	0	149,585	149,585

The largest group of forborne exposures comprises transactions with clients from the Enterprise segment. It should be noted that the ratio of receivables past due by more than 90 days to total forborne exposures was low, at 8% as at 31 December 2020.

44.14. Impact of the COVID-19 pandemic

In response to the COVID-19 crisis, in April 2020 BGK implemented guidelines on: assessment of risk of exposure (IFRS 9), procedure to be followed in the lending process and monitoring of credit exposures during a crisis.

The guidelines covered the following areas:

§ making lending decisions regarding unfulfilled conditions,

§ monitoring of credit exposures and other processes,

§ submission of visit reports and reports of Individual Technical Advisors/Project Engineers,

§ assessment of exposure risk (in accordance with IFRS 9) during a crisis,

§ application of guidelines of the PFSA on assessment of creditworthiness in terms of working capital facilities,

§ BGK’s existing clients (i.e. clients which currently have any exposure under loan products at the Bank).

Due to the prolonged COVID-19 pandemic, the Bank introduced new guidelines on assessment of creditworthiness for the purpose of granting or extending the validity of working capital facilities of BGK’s existing clients.

In accordance with the guidelines, a client:

§ whose full assessment of creditworthiness was completed with a positive outcome after 30 March 2019,

§ which due to the situation related to the COVID-19 pandemic was not creditworthy as a result of temporary risk of losing liquidity, in particular caused by the loss of the existing financing or impossibility of making a full assessment of creditworthiness,

§ which was not subject to specific statutory rules for micro, small and medium-sized enterprises as part of the Anti-Crisis Shield,

could renew the facility or increase the amount of financing on preferential terms, in which the Bank agreed on the following:

§ where it was impossible to draw up a full recovery plan – reliance on simplified forecast of recovery, and

§ in justified cases it was not necessary to provide a specific type of collateral,

§ facilities could be renewed on preferential terms for up to 12 months,

§ processing of applications that require an assessment of creditworthiness based on simplified liquidity forecast.

As part of activities taken to counteract the effects of the COVID-19 pandemic, the Bank has taken a pragmatic approach in terms of information and documents required from clients specified in the “Emergency procedure specifying the manner of submission of documents required in the lending process at Bank Gospodarstwa Krajowego during the COVID-19 crisis.”

The provisions of Art. 70 of the Banking Law were applied, with the proviso that:

§ where it was impossible to draw up a full recovery plan, it was permitted to rely on simplified forecast of recovery, and

§ in justified cases it was not necessary to provide a specific type of collateral,

§ facility renewal on preferential terms for up to 12 months,

§ applications that require an assessment of creditworthiness could be processed based on simplified liquidity forecast.

In addition, the rules of processing of applications for a change of the loan instalment schedule introduced by the Bank take into account a simplified procedure for application processing.

The guidelines were also a response to the measures presented by the Polish Financial Supervision Authority, which prepared a package of measures to further bolster the banking sector’s resilience and its capacity to finance the economy which was named the Supervisory Stimulus Package for Security and Development. The primary role of the measures is to maintain a balance between ensuring proper indicators of stability of the banking sector and maintaining and supporting economic activity, as well as to enable banks to provide rescue financing if an entity is subject to temporary risk of losing liquidity. The guidelines were effective until 30 September 2020 with an option of their extension and update depending on the developments related to the COVID-19 pandemic or until revoked by a Member of the Management Board in charge of risk management.

In connection with the second wave of the COVID-19 pandemic, the guidelines were extended and modified as described below. As at 31 December 2020, the guidelines applied to:

§ the PFSA’s position on assessment of creditworthiness in terms of working capital facilities of BGK’s existing clients,

§ procedure to be followed in the lending process – requirement for clients to present a liquidity plan,

§ classification of exposures to the relevant stage in accordance with IFRS 9.

The guidelines ceased to apply in the following areas:

§ making lending decisions regarding unfulfilled conditions,

§ monitoring of credit exposures and other processes,

§ submission of visit reports and reports of Individual Technical Advisors/Project Engineers.

The current guidelines apply until they are revoked by the Member of the Management Board in charge of risk management depending on the developments related to the COVID-19 pandemic.

In addition, the rules and procedure of monitoring credit exposures were updated by adding the rules of monitoring credit exposures to clients which are beneficiaries of COVID-19 aid measures, which introduced monthly monitoring for clients which are beneficiaries of aid measures and are required to present a recovery plan. The need for more frequent monitoring results from the PFSA’s position of 31 March 2020.

To support clients facing problems caused by the outbreak of the COVID-19 pandemic, the Bank granted, inter alia, the following concessions:

§ suspension of instalment repayment,

§ extension of the final repayment date,

§ extension of the financing validity date,

§ temporary decrease of the interest rate,

§ waiver of commission.

The provided moratoria did not trigger forbearance classification, provided that they were applied before 30 September 2020. The concessions granted after 30 September 2020 were reviewed individually in terms of their link to COVID-19 and the likelihood that the client’s situation will improve after the pandemic ends.

Also, the application of aid measures related to the COVID-19 pandemic does not result in automatic reclassification to Stage 2 or Stage 3. However, if it is found that the client’s financial difficulties are permanent, which means that its credit risk has increased, debt is reclassified to basket 2 (this is a separate indication). When determining whether the financial difficulties are permanent, the bank compares the risk from before the pandemic with the present one, taking into account, among other things, the additional aid measures granted.

In accordance with IFRS 9, the Bank recognises any amendments to agreements resulting from the granted concessions as non-substantial modifications.

The tables below present the moratoria granted by the Bank by type and phase.

Exposures subject to non-legislative moratoria by type based on EBA guidelines, as at 31 December 2020

Moratoria	Stage	Active*			Total granted*
Moratoria	Stage	Gross loans	Impairment losses	Number of clients	Gross loans	Impairment losses	Number of clients
Payment holiday	Stage 1	836,880	12,591	37	1,878,785	12,591	103
Forbearance	Stage 1	141,647	2,750	6	141,647	2,750	11
Payment extension	Stage 1	9,797	40	4	9,797	40	6
Payment holiday	Stage 2	251,239	10,834	25	611,020	10,834	52
Forbearance	Stage 2	140,381	2,254	4	140,381	2,254	12
Payment extension	Stage 2	3,425	8	3	3,425	8	3
Payment holiday	Stage 3	353,272	66,973	23	542,826	66,973	40
Forbearance	Stage 3	9,405	1,959	9	9,573	1,959	3
Payment extension	Stage 3	934	58	2	934	58	2
Total		1,746,980	97,467	113	3,338,388	97,467	232
* Active moratoria are moratoria that are still in effect, while total granted cover all moratoria granted during the pandemic, including those which had expired as at the date of the financial statements.

Exposures subject to remedial action aimed at counteracting the effects of the COVID-19 pandemic by type, including non-legislative moratoria, as at 31 December 2020

Moratoria	Stage	Active*			Total granted*
Moratoria	Stage	Gross loans	Impairment losses	Number of clients	Gross loans	Impairment losses	Number of clients
Payment holiday	Stage 1	836,880	12,591	37	1,820,383	17,036	103
Other moratoria**	Stage 1	610,849	7,076	34	662,881	7,513	39
New transaction***	Stage 1	597,246	8,113	6	597,246	8,113	4
Payment extension	Stage 1	9,797	40	4	16,167	95	6
Payment holiday	Stage 2	251,239	10,834	25	312,422	16,870	52
Other moratoria**	Stage 2	606,825	20,764	18	905,422	29,847	26
New transaction***	Stage 2	17,802	129	1	17,802	129	1
Payment extension	Stage 2	3,425	8	3	3,425	8	3
Payment holiday	Stage 3	353,272	66,973	23	486,143	84,248	40
Other moratoria**	Stage 3	406,116	55,982	13	462,967	59,429	7
Payment extension	Stage 3	934	58	2	934	58	2
Total		3,694,385	182,568	166	5,285,792	223,346	283
* Active moratoria represent exposures for which remedial actions to counter the effects of the pandemic have been taken and are still in effect, while total granted cover all exposures for which remedial actions to counter the effects of the pandemic have been taken, including those which had expired as at the date of the financial statements.
**Other: § Forbearance § Change of terms of a loan agreement § Revision of payment dates and amounts of loan tranches § Change of the disbursement date of the first tranche of a loan § Change of the time limit for loan utilisation § Change of deadlines for investment completion § Change of the frequency of submitting valuation reports § Change of the frequency of submitting the auditor’s opinions and reports
*** To counteract the effects of the COVID-19 pandemic, the Bank supported businesses with dedicated new financing.

The increase in credit risk is assessed for individual clients, both as a result of the COVID-19 pandemic, and for other reasons. The Bank does not identify a significant rise in credit risk due to the COVID-19 pandemic at the level of the loan portfolio, both based on NPL (down by 0.2 pp over 2020) and weighted average PD for both the entire portfolio and individual sub-portfolios. The Bank expects that credit risk increase triggered by the COVID-19 pandemic may materialise in 2021.

In connection with the COVID-19 pandemic, BGK did not make any changes in the rules of calculation of expected credit losses, rules of identification of a significant increase in credit risk and basket allocation. The deterioration of the

macroeconomic conditions following the pandemic was taken into account in scenarios of development of the macroeconomic situation and comprehensive stress tests.

45. Liquidity risk management

Definition

Liquidity risk is a defined threat of losing the ability to pay liabilities in a timely manner as a result of unfavourable changes in assets and liabilities and equity, off-balance-sheet transactions, maturity mismatch of current cash flows, and possible losses resulting from the foregoing.

The liquidity risk is also dealt with in the context of:

§ market (product) liquidity risk understood as a threat of losing the ability to exchange specific products on the market for cash, resulting in the need to incur financial losses on these products,

§ funding risk understood as a threat of shortage of stable funding sources in mid- and long-term, resulting in actual or potential risk of default by the Bank in regard to financial liabilities such as payments and collaterals at their maturity in mid- and long-term, either in whole or involving unacceptable funding costs to be incurred,

§ liquidity concentration risk understood as a threat of default in current liabilities due to dependence (lack of diversification) or overexposure to one entity or associate entities,

§ liquidity risk in individual currencies in which the Bank carries out its activities, understood as inability to fulfil the Bank’s liabilities in a given currency due to limitations in convertibility of currencies.

Management purposes

The purpose of liquidity risk management is to:

§ ensure and maintain the Bank’s ability to meet obligations related to both current and planned future liabilities, including costs of liquidity and return on equity,

§ prevent stress conditions,

§ define solutions which will enable the Bank to survive a potential crisis (contingency planning).

Identification and measurement

The Bank identifies internal and external sources of liquidity risk.

The adopted Bank’s liquidity risk measurement system includes the following methods:

§ liquidity ratios (both regulatory and internal), contractual and market-based liquidity gap analysis, fund stability analyses, daily monitoring of the deposit base,

§ liquidity stress tests covering scenario analyses, sensitivity analyses, and reversed tests.

Control

In order to reduce risk and secure liquidity, the Bank applies the following measures:

§ transactions on the money market, including deposit transactions, reverse repo, repo, NBP money market bills, Treasury bills, bonds, and other instruments,

§ maintaining a portfolio of liquid securities,

§ daily monitoring of the money balance and ensuring financing possibilities from the NBP,

§ financing lines securing liquidity of the Bank,

§ own bond issuances and deposit level management to optimise the structure of the sources of funding,

§ emergency plans in case of emergency situations of reduced or endangered liquidity.

Liquidity risk management involves the operation of a system of liquidity risk limits adjusted to the scale and complexity of the Bank’s operations (external and internal limits, in particular an acceptable level of liquidity risk). Apart from the system of limits, threshold values and analysis thresholds are applied, i.e. a group of early warning indicators which make it possible to identify adverse trends that may affect the Bank’s liquidity in a timely manner.

Additionally, in accordance with Article 3.3 of the Act on Bank Gospodarstwa Krajowego, the minister competent for public finance provides funds to meet liquidity standards.

Monitoring

The risk monitoring process involves a cyclical review of the values of limited parameters and analysis of the limit usage. Moreover, concentration of financing sources and impact of any increase in deposits on the Bank’s liquidity are also analysed.

In the area of liquidity risk, cyclical forecasts of liquidity risk level are also made. The forecasts take into account primarily the levels of selected liquidity risk measures in normal conditions of the Bank’s operations and in selected stress test scenarios.

Reporting

The Bank prepares current reports on liquidity risk presenting utilisation of regulatory liquidity limits and internal liquidity limits, balance of deposit at the Bank, external funds stability analysis, results of stress tests, and periodic simulations of liquidity measures and long-term liquidity analysis.

Quantitative information

In 2020, regulatory liquidity measurements defined in the PFSA’s resolution No. 386/2008 of 17 December 2008 on defining liquidity norms binding for banks (Official Journal of the PFSA No. 8, item 40, as amended) and in Commission Delegated Regulation No. 2015/61 (EU) of 10 October 2014 to supplement Regulation (EU)No. 575/2013 of the European Parliament and the Council with regard to liquidity coverage requirement for Credit Institutions (OJ L 11, 17.01.2015, p. 1, as amended) and internal liquidity standards were not breached.

Regulatory liquidity measures

Regulatory liquidity measures are presented in the table below.

Item	Limit	Including flow funds		Additional information – excluding flow funds
Item	Limit	31 Dec 2020	31 Dec 2019	31 Dec 2020	31 Dec 2019
M3 – own funds to non-liquid assets	1.00	2.93	2.52	2.93	2.52
M4 – own funds and stable external funds to non-liquid and limited-liquidity assets	1.00	1.27	1.25	1.95	1.51
LCR – liquidity coverage ratio	100%*	176%	193%	210%	228%

* the indicators are specified on an individual basis as the CRR does not require prudential consolidation.

The change in the liquidity measures was mainly driven by the capital injection to the Bank by the State Treasury, an increase in long-term funding sources, the Bank’s lending activities and equity investments.

Liquidity gap

The Bank’s market-based liquidity gap is presented below. In particular, the following are adjusted to their market values: deposit values (on the basis of estimated core deposits), liquid securities (presented in recovery values achievable in specific time periods), and financial and guarantee off-balance-sheet liabilities granted (in the scope of estimated amounts and deadlines).

The Group’s market-based liquidity gap
		up to 1 m	1 m - 3 m	3 m - 6 m	6 months to 1 year	1 – 5 years	more than 5 years
31 Dec 2020	Gap	44,355,034	-5,485,438	-1,567,089	-236,946	-46,264,439	-4,445,029
31 Dec 2020	Aggregate gap	44,355,034	38,869,596	37,302,507	37,065,561	-9,198,878	-13,643,907
31 Dec 2019	Gap	26,244,094	-6,925,359	-3,020,347	-2,074,963	-27,672,658	3,040,732
31 Dec 2019	Aggregate gap	26,244,094	19,318,735	16,298,388	14,223,425	-13,449,233	-10,408,501

Sources of funding

The Bank has diversified sources of funding, including deposits from customers, funds from issues of own bonds, and loans granted by international financial institutions.

Liabilities structure by contractual maturity is presented below. The amounts include cash flows from the principal amount and interest (if applicable) for the entire financing period. For off-balance-sheet liabilities, exposures are presented by contractual maturity.

Liabilities of the Group as at 31 December 2020
		up to 1 m	1 m - 3 m	3 m - 6 m	6 months to 1 year	1 – 5 years	more than 5 years	Total
Balance sheet liabilities	Amounts due to banks	4,073,530	234,436	140,848	249,098	1,462,568	1,472,640	7,633,120
	Liabilities to customers	101,541,294	12,036,891	4,330,891	554,741	15,717	144	118,479,678
	Own issues	501,310	7,260	7,689	513,619	3,900,815	0	4,930,693
	Lease liabilities	0	5,175	4,761	13,672	80,812	8,742	113,162
	Total	106,116,134	12,283,762	4,484,189	1,331,130	5,459,912	1,481,526	131,156,653
Off-balance-sheet liabilities granted	Financing commitments	45,409,310	555,736	210,014	1,102,125	3,449,268	5,112,575	55,839,028
	Guarantee liabilities	5,620,644	1,220,794	1,953,417	3,580,715	5,057,260	624,954	18,057,784
	Total	51,029,954	1,776,530	2,163,431	4,682,840	8,506,528	5,737,529	73,896,812

Liabilities of the Group as at 31 December 2019
		up to 1 m	1 m - 3 m	3 m - 6 m	6 months to 1 year	1 – 5 years	more than 5 years	Total
Balance sheet liabilities	Amounts due to banks	2,459,889	90,241	148,388	242,525	1,730,145	1,361,419	6,032,607
	Liabilities to customers	58,686,823	5,770,661	1,879,939	874,566	119,796	0	67,331,785
	Own issues	5,115	1,193,971	1,239,137	52,997	5,094,496	0	7,585,716
	Lease liabilities	2,814	2,709	3,518	5,954	22,166	5938	43,099
	Total	61,151,827	7,054,873	3,267,464	1,170,088	6,944,437	1,361,419	80,950,108
Off-balance-sheet liabilities granted	Financing commitments	40,198,902	1,089,018	195,281	967,339	4,027,507	3,211,164	49,689,211
	Guarantee liabilities	5,415,340	696,911	337,540	3,514,274	4,567,029	708,188	15,239,282
	Total	45,614,242	1,785,929	532,821	4,481,613	8,594,536	3,919,352	64,928,493

Cash flows from derivatives

Derivatives used by the Bank include IRSs, FRAs, FX Swaps, FX Forwards, CIRSs and options.

Undiscounted cash flows under derivative contracts as at 31 December 2020 and 31 December 2019 are presented below.

Cash flows from derivatives
		up to 1 m	1 m - 3 m	3 m - 6 m	6 months to 1 year	1 – 5 years	more than 5 years	Total
31 Dec 2020	Inflows	12,760,672	5,544,866	4,248,382	2,021,863	10,404,188	13,935,777	48,915,748
31 Dec 2020	Outflows	-12,775,301	-5,692,045	-4,262,807	-2,158,931	-10,432,163	-13,943,066	-49,264,313
31 Dec 2019	Inflows	4,149,908	2,606,435	6,915,689	2,309,076	10,367,391	13,827,338	40,175,837
31 Dec 2019	Outflows	-4,105,891	-2,597,553	-6,931,610	-2,332,288	-10,365,679	-13,833,009	-40,166,030

45.1. Impact of the COVID-19 pandemic

In 2020, the COVID-19 pandemic affected the dynamics of global financial markets, causing the depreciation of the złoty, lower confidence of market participants due to limited availability of financing, as well as a sharp decline in activity in the treasury securities market. The adverse impact of the pandemic was curbed by rapid and globally universal easing of the policy mix.

The Bank did not observe any threat to its liquidity position due to the spread of the pandemic. As of 15 March 2020, the Bank cyclically reports on its liquidity situation to the PFSA, highlighting that it does not have any liquidity concerns. Liquidity ratios remained safe amid a strong capital base, which demonstrates that the Bank is well prepared for crisis situations.

In 2020, the Bank conducted holistic stress tests for three scenarios of development of the Bank’s situation alternative to its Financial Plan. The expected trajectory of the COVID-19 pandemic accounted for the main differences between macroeconomic conditions. The stress tests helped determine the impact of individual scenarios on liquidity risk, among other things. The outcome indicates the Bank’s strong resilience to stress conditions.

46. Market risk management

46.1. Interest rate risk management

Definition

Interest rate risk is defined as a threat of possible deterioration in the value of the Bank’s financial instruments portfolio or Bank’s financial result due to adverse interest rate fluctuations.

Management purpose

Interest rate risk management aims to reduce the risk of losing part of the interest income as a result of a change in market interest rates and the risk of an unfavourable change in the market value of the interest-bearing financial instruments held by proper management of portfolio structure.

Identification and measurement

The Bank identifies internal and external sources of interest rate risk.

The measurement of interest rate risk at BGK includes, among other things: net present value (NPV), duration, sensitivity measures of financial instruments present value to changes in interest rates (basis point value – BPV, economic value of equity – EVE), net interest income sensitivity to changes in interest rates (NII), repricing gap, value at risk (VaR), and stress tests measures. The Bank also prepares lists of financial instruments using a given reference rate as a benchmark (basis risk) and sets levels of termination of term deposits and loan prepayments (customer option risk).

VaR is calculated for the assumed 99% confidence level and for 250 observations time series. The model is back-tested by comparing the model results with revaluation and actual results.

Control

An important element of interest rate risk management is the Bank’s system of limits, which are subject to risk appetite determined by the Supervisory Board. The following limits apply: BPV limit for banking and trading book, limits and threshold values for interest income risk for the banking book, and loss limits. The Bank applies interest rate risk management procedures.

Monitoring

Risk monitoring process primarily involves regular review of risk measure levels and analysis of the utilization of limits and threshold values.

Reporting

Reports are submitted on a daily, monthly, quarterly, semi-annual and annual basis – each report is addressed to recipients at an appropriate level.

Quantitative information

Key market risk measures are presented below. The measures do not include flow funds.

The table below presents BPV results of the Bank’s banking and trading book as well as on the sensitivity of net interest income and economic value of the banking book to interest rate change by 2 p.p.

Selected measures of interest rate risk		31 Dec 2020	31 Dec 2019
BPV	banking book	-551	-1,432
BPV	trading book	-27	-22
Net interest income sensitivity to changes in interest rates by:	-2 p.p.	-180,121	-72,752
	+2 p.p.	180,121	63,481
Sensitivity of economic value of the banking book to interest rate change by:	-2 p.p.	278,225	416,938
	+2 p.p.	-278,225	-416,938

Relative to the end of the previous year, the net interest income sensitivity to interest rate change grew by PLN 107 million as a result of shortening of repricing dates for debt securities (increase in the portfolio of money bills). Relative to the end of the previous year, BPV and sensitivity of economic value of the banking book to interest rate change decreased as a result of a smaller PLN-denominated T-bond portfolio.

The table below presents the repricing gap for the Group.

Repricing gap for the Group
		up to 1 m	1 m - 3 m	3 m - 6 m	6 months to 1 year	1 – 5 years	more than 5 years	Total
31 Dec 2020	Gap	9,831,236	-4,833,627	7,026,628	3,028,583	3,308,939	613,147	18,974,906
31 Dec 2020	Cumulative gap	9,831,236	4,997,609	12,024,237	15,052,820	18,361,759	18,974,906
31 Dec 2019	Gap	1,468,181	-2,017,182	9,188,044	-565,539	7,273,786	368,407	15,715,698
31 Dec 2019	Cumulative gap	1,468,181	-549,000	8,639,044	8,073,505	15,347,291	15,715,698

Higher cumulative gap up to 1 month compared to the end of the previous year was caused by an increase in the portfolio of money bills.

The table below presents VaR for interest rate risk of the trading book at 99% confidence level and 1 business day time horizon.

VaR for interest rate risk of the trading book	Date	As at	Average value*	Minimum value*	Maximum value*
VaR 1D 99%	31 Dec 2020	3,740	4,047	2,555	5,090
VaR 1D 99%	31 Dec 2019	4,679	3,331	2,471	4,966

* Average, minimum and maximum value in the reporting period ending at the date specified.

Relative to the previous year, in 2020 the average VaR increased due to higher volatility of interest rates.

46.2. Foreign exchange risk management

Definition

Foreign exchange risk is defined as a threat of possible deterioration in the value of the Bank’s financial instruments portfolio or Bank’s financial result due to adverse changes in currency exchange rates.

Management purposes

The purpose of foreign exchange risk management is to reduce the risk of losses as a result of changes in market exchange rates by management of the Bank’s currency position.

Identification and measurement

The Bank identifies internal and external sources of foreign exchange risk.

The measurement of foreign exchange risk at BGK covers, among other things: currency positions, value at risk (VaR), and stress tests.

VaR is calculated for the assumed 99% confidence level and using a range of market data from 251 business days. The model is back-tested by comparing the sensitivity values against remeasurement and actual results.

Control

The Bank applies the following currency position limits: the Bank’s total currency position limit and a currency position limit for the trading book – both are subject to risk appetite determined by the Supervisory Board. Loss limits are also applied. The Bank applies foreign exchange risk management procedures.

Monitoring

Risk monitoring process involves, inter alia, cyclical review of risk measure levels and analysis of the limit usage.

Reporting

Reports are submitted on a daily, monthly, quarterly, semi-annual and annual basis – each report is addressed to recipients at an appropriate level.

Quantitative information

The table below presents the Bank’s total currency position and sensitivity of securities at fair value through other comprehensive income (FVOCI) to exchange rates change by 20%.

Selected foreign exchange risk measures of the Group	31 Dec 2020	31 Dec 2019
Total foreign currency position	182,973	26,724
Sensitivity of securities at FVOCI to exchange rates change by 20%	-583,962	-227,433

The table below presents VaR for foreign exchange risk at 99% confidence level in a horizon of 1 business day.

VaR for foreign exchange risk of the Group	Date	As at	Average value*	Minimum value*	Maximum value*
VaR 1D 99%	31 Dec 2020	1,227	439	115	1,371
VaR 1D 99%	31 Dec 2019	156	719	65	1,425

* Average, minimum and maximum value in the reporting period ending at the date specified.

Compared to the previous year, as at the end of 2020 VaR increased as a result of an increase in total currency position.

The tables below present the Group’s exposure to foreign exchange risk as at 31 December 2020 and 31 December 2019. The tables below present the Bank’s assets and liabilities by carrying amount and by currency.

Currency structure of assets	Currency translation to PLN as at 31 December 2020
Currency structure of assets	PLN	EUR	USD	CHF	Other	Total
Cash and balances with the Central Bank	32,256,736	5,521	0	0	0	32,262,257
Amounts due from banks	3,352,072	2,049,138	158,646	1,611	44,916	5,606,383
Derivative financial instruments	997,397	0	0	0	0	997,397
Securities	72,518,937	3,064,982	1,298,866	0	19,395	76,902,180
Reverse repurchase agreements	4,207,234	0	0	0	0	4,207,234
Loans and advances to customers	27,262,470	3,555,125	2,564,878	28,569	40,633	33,451,675
Investments in associates	4,265,635	100,263	12,873	0	0	4,378,771
Intangible assets	69,424	0	0	0	0	69,424
Property, plant and equipment	129,763	0	0	0	0	129,763
Right-of-use assets	104,779	0	0	0	0	104,779
Investment property	1,711,266	0	0	0	0	1,711,266
Current tax receivables	513	0	0	0	0	513
Deferred tax assets	325,237	0	0	0	0	325,237
Other assets	177,805	347	433	1	74	178,660
Total assets	147,379,268	8,775,376	4,035,696	30,181	105,018	160,325,539

Currency structure of liabilities	Currency translation to PLN as at 31 December 2020
Currency structure of liabilities	PLN	EUR	USD	CHF	Other	Total
Amounts due to banks	3,429,574	470,357	7,966	0	0	3,907,897
Derivative financial instruments	1,311,836	10,027	1,908	0	1,029	1,324,800
Liabilities to customers	113,740,712	1,864,716	517,515	8,417	6,726	116,138,086
Repurchase agreements	5,817,989	0	0	0	0	5,817,989
Debt securities issued	4,859,446	0	0	0	0	4,859,446
Lease liabilities	35,417	76,826	28	0	891	113,162
Other liabilities	3,639,648	1,886	35	6	121	3,641,696
Current tax liabilities	47,088	0	0	0	0	47,088
Deferred tax liabilities	31,342	0	0	0	0	31,342
Provisions	488,628	13,707	14,426	0	3,301	520,062
Total liabilities	133,401,680	2,437,519	541,878	8,423	12,068	136,401,568

Currency structure of assets	Currency translation to PLN as at 31 December 2019
Currency structure of assets	PLN	EUR	USD	CHF	Other	Total
Cash and balances with the Central Bank	22,725,116	4,260	0	0	0	22,729,376
Amounts due from banks	1,099,475	4,800,316	997,875	6,828	34,199	6,938,693
Other derivatives	564,868	5,907	133	0	3,999	574,907
Securities	24,891,208	3,011,241	219,958	188,822	0	28,311,229
Reverse repurchase agreements	5,301,537	0	0	0	0	5,301,537
Loans and advances to customers	25,685,991	3,032,881	2,003,220	30,213	160,024	30,912,329
Investments in associates	3,568,874	72,080	11,879	0	0	3,652,833
Intangible assets	54,982	0	0	0	0	54,982
Property, plant and equipment	132,360	0	0	0	0	132,360
Right-of-use assets	45,843	0	0	0	0	45,843
Investment property	1,501,811	0	0	0	0	1,501,811
Deferred tax assets	247,376	0	0	0	0	247,376
Other assets	83,593	34,224	38	1	108	117,964
Total assets	85,903,034	10,960,909	3,233,103	225,864	198,330	100,521,240

Currency structure of liabilities	Currency translation to PLN as at 31 December 2019
Currency structure of liabilities	PLN	EUR	USD	CHF	Other	Total
Amounts due to banks	2,897,487	1,143,755	78,339	0	65	4,119,646
Derivative financial instruments	601,969	6,235	1,260	0	1,866	611,330
Liabilities to customers	55,629,732	3,797,481	259,789	7,806	6,566	59,701,374
Repurchase agreements	9,020,088	93,300	0	0	0	9,113,388
Debt securities issued	7,251,523	0	0	0	0	7,251,523
Lease liabilities	38,497	4,582	20	0	0	43,099
Other liabilities	440,985	37,812	59	19	108	478,983
Current tax liabilities	80,208	0	0	0	0	80,208
Deferred tax liabilities	25,982	0	0	0	0	25,982
Provisions	415,019	12,842	11,196	0	2,733	441,790
Total liabilities	76,401,490	5,096,007	350,663	7,825	11,338	81,867,323

46.3. Equity price risk management

Definition

The equity price risk is defined as a threat of possible deterioration in the value of the Bank’s portfolio or financial result due to adverse changes in equity prices, in particular investment certificates of funds and shares.

Management purpose

The purpose of equity price risk management is to reduce the risk of losses as a result of changes in equity prices by conducting proper equity investment management.

Identification and measurement

The Bank identifies internal and external sources of equity price risk.

The measurement of equity price risk at BGK includes: share and investment certificate positions, value at risk (VaR), and stress tests.

VaR is calculated for the assumed 99% confidence level and using a range of 251 observations. The model is back-tested by comparing the sensitivity values against remeasurement and actual results.

Control

The Bank’s equity investments are subject to limits. The Bank applies equity price risk management procedures.

Monitoring

Risk monitoring process primarily involves regular review of risk measure levels and analysis of the limit utilisation.

Reporting

Reports are submitted on a daily, monthly, quarterly, semi-annual and annual basis – each report is addressed to recipients at an appropriate level.

Quantitative information

The table below presents VaR at 99% confidence level in a horizon of 10 business days calculated for prices of listed shares.

VaR for equity price risk of the Group	Date	As at	Average value*	Minimum value*	Maximum value*
VaR 10D 99%	31 Dec 2020	218,600	163,458	105,837	226,745
VaR 10D 99%	31 Dec 2019	111,459	139,497	108,398	167,689

* Average, minimum and maximum value in the reporting period ending at the date specified.

2020 saw an increase in VaR due to higher volatility of share prices – mainly of PKO BP S.A. and PZU S.A.

46.4. Impact of the COVID-19 pandemic

In 2020, the COVID-19 pandemic caused higher variability of market risk factors, in particular interest rates, exchange rates and share prices.

The drop in share prices and valuation of unlisted companies resulted in temporary decrease in the market value of the portfolio of shares held by the Bank, mainly in PKO BP S.A. and PZU S.A., as well as lower valuation of closed-end investment funds in which the Bank invested. Higher volatility of interest rates and exchange rates inflated VaR measures for those risk factors, although it did not pose a significant threat to the Bank’s financial standing.

In general, the outbreak of the COVID-19 epidemic did not affect the way in which interest rate risk in the banking book is managed. The Bank’s efforts in the area of interest rate risk management in 2020 focused on, inter alia, ensuring that

clients and funds managed by the Bank have unrestricted access to market liquidity and investment instruments, as well as on optimising the securities portfolio in response to the market situation.

Moreover, the Bank focused on efficient client service and the availability of treasury products. Measures were taken to reduce the interest rate position generated from transactions hedging clients’ market risk. Activity in the foreign exchange market was focused solely on execution of orders of the Bank’s clients.

For information on the impact of COVID-19 on interest rates and their impact on the Bank’s financial performance see Note 53.

47. Operational risk management

Definition

The operational risk is defined as the risk of losses the Bank can incur as a result of misalignment or unreliability of internal processes, people, or systems or as a result of external events. This definition includes legal risk but excludes reputational risk understood as the risk of negative perception of the Bank’s brand and strategic risk, defined as the risk related to disadvantageous or wrong strategic decisions, inadequate strategy implementation or a failure to carry out such strategy and changes in the external environment and inappropriate relation to such developments, although it applies to the relevant control processes.

Operational risk is inherent in all major areas of the Bank’s operations, including any new, existing and modified products, processes and systems, and it takes into account of internal factors (such as the organisational structure, business profile, IT systems used, client profile, client complaints, HR quality, organisational changes and employee turnover) and external factors (external environment of the Bank).

Management purposes

The purpose of operational risk management is to increase security of business by improving efficient mechanisms adjusted to the profile and scale of operations for the identification, measurement, control, monitoring, mitigation and reporting of operating risk.

The Bank manages operational risk through:

§ the function of Operational Risk Coordinator;

§ operational risk ratios,

§ methods for operational risk self-assessment and mapping,

§ rules of assessment of financial intermediaries.

Operational risk management covers all Regions and organisational units of the head office of the Bank and subsidiaries supervised by appropriate organisational units of the Bank’s head office in line with the Head Office Organisational Regulations and their responsibilities.

Risk identification and measurement

Operational risk is identified by collecting information on operational risk data sources, which can be either: internal (including operational events, incidents reported, customer complaints); or external (operational risk events databases of the Polish Banks Association and external analysis).

Potential risk is assessed using the method of operational risk self-assessment and inherent and residual operational risk mapping based on workshops with units of the second line of defence, tactical process owners and tactical process experts.

Actual risks are assessed using operational risk ratios and limits and through the analysis of operational events, including estimations of the probability of loss entailing the need to recognise provisions for future losses.

The purpose of operational risk measurement is to evaluate threats resulting from operational risks using pre-determined risk measurements. Operational risk assessment includes: calculation of KRIs, calculation of the capital requirement using BIA, stress tests, and determination of the internal capital.

Risk control

The Bank regularly monitors the level of operational risk and efficiency as well as timeliness of activities aimed at reducing or transferring operational risk. Operational risk control involves setting operational risk limits adjusted to the Bank’s scale and its operations, mainly in terms of the accepted level of operational risk, loss limits, operational risk indicators (KRI) and threshold values.

To reduce the impact of operational events, the Bank applies risk mitigants and implements various kinds of preventive actions, such as:

§ training for employees,

§ BCP emergency plans,

§ risk transfer, including outsourcing and insurance coverage,

§ other safeguards (legal, organisational and technical).

Risk monitoring

The Bank regularly monitors:

§ operational events and their effects,

§ use of the accepted level of operational risk and loss limits,

§ indicators of operational risk (KRI) for warning and critical values,

§ outcome of operational risk self-assessment,

§ operational risk own funds requirement under the BIA,

§ stress test results,

§ efficiency and timeliness of activities aimed at reducing operational risk.

Risk reporting

Information on operational risk for the Bank and its subsidiaries is reported on a regular basis to executive management, the Bank’s Operational Risk and Internal Control Committee, the Bank’s Management Board, the Bank’s Supervisory Board and the Risk Committee. The process includes information on the risk profile, identification of possible threats, and information on the measures adopted. The frequency of reports is as follows: ad hoc reports presenting material operational events, quarterly, semi-annual and annual reports to the same effect and annual reports presenting an operational risk map.

47.1. Impact of the COVID-19 pandemic

To mitigate the operational risk related to the COVID-19 epidemic, the Bank performed digitisation of documents based on verified processes/tasks, which identified circulation of paper documents. All employees were given the opportunity to work remotely. The Bank developed rules of remote work, particularly accounting for manager – employee and manager – team relations. The Bank provided up-to-date communication on best practices in remote working, rules of working safely at the office, clean desk policy, OHS procedures and rules of rotational work. It was made possible to provide training via an e-learning platform. The Business Continuity Management System (PCD) was updated – the definitions of critical process and essential process/activity in the context of long-term threats were revised. The Bank streamlined its business and other processes. The efficiency of reporting and decision-making was improved.

In 2020, the operational risk did not increase, the Bank holds the operational risk profile constant, the operational risk appetite is below the set limit.

48. Other risks

48.1. Reputational risk management

Reputational risk is defined as the risk of negative perception of the Bank by its clients, counterparties, supervisors, regulators, opinion-makers, government institutions, public benefit organisations, associations, foundations and public opinion, which can adversely affect the performance of the Bank.

Reputational risk is managed to protect the Bank’s brand image and reduce losses resulting from any damage to the Bank’s reputation and the probability of occurrence of such a risk.

Reputational risk is managed through classification of reputational risk events with ex ante and ex post risk assessment carried out.

Reporting information on compliance risk is carried out on a regular basis as part of compliance risk reporting.

48.1.1. Impact of the COVID-19 pandemic

In connection with the spread of the pandemic in Poland and the Bank’s involvement in multiple initiatives supporting the fight with COVID-19, no material events that would cause a rise in reputation risk occurred in 2020 (assessed together with compliance risk). When adjusting its products to the current market situation and restrictions imposed due to COVID-19, the Bank assessed the reputation risk for each change in the product offer and internal processes. The Bank monitors its media coverage on an ongoing basis in particular to identify information that may adversely affect reputation risk.

48.2. Business risk management

Business risk is defined as the risk of failure to achieve key business goals, in particular financial result, due to changes in economic, social, legal, business and market environment or failure to achieve the business and social goals implemented by the Bank as part of missions and tasks defined by the owner. Business risk involves strategic risk.

The objective of business risk management is to mitigate a negative financial impact of adverse changes in business environment, inappropriate decisions, inadequate implementation of decisions or inadequate response to changes in the business environment.

Business risk measurement

Business risk identification consists in identifying and determining actual and potential risks related to the existing and planned activities of the Bank which can considerably affect its financial condition, originate or change its revenue and expenses. Business risk is identified based on the analysis of selected revenue and cost items of the statement of profit or loss and significant interest-bearing balance sheet and off-balance-sheet items. Business risk as regards financial result is carried out by the Bank through a prospective assessment of business risk to the implementation of the Bank’s Strategy and the schedule of works for the next year, as well as through the analysis of deviations from the Bank’s Strategy and the schedule of works of the Bank, including trends in the implementation of main items and expected results in the periods to follow. Key parameters of the schedule of works and expenditures of the Bank which are assessed and analysed include key items of statement of financial position, profitability, portfolio quality, margin, and capital adequacy ratio.

Along with updating the Strategy, the Bank analyses Strategy performance and deviations from the financial projections. Performance of business and financial goals is assessed together with changes in the macroeconomic environment.

As part of risk management process, the Bank carries out stress tests based on the schedule of works and expenditures of the Bank and its Strategy to determine the impact of the assumptions made on the risk measures, in particular capital adequacy and liquidity ratios. Stress testing of risk measures is carried out in line with the applicable risk management principles.

Projecting and monitoring business risk

Business risk is monitored by way of a monthly analysis of the Bank’s performance, a semi-annual profitability analysis of selected bank products presented at the BFC that includes a detailed list of product profitability factors, such as interest margin, net fee and commission income and liquidity margin as well as factors related to covering estimated cost of risk and operating expenses. The annual review is carried out for regulatory risk, market risk and business risk.

Apart from preparing annual and long-term plans in the process of the Bank’s Strategy review, when the Management Board of the Bank is presented with key factors affecting the Bank’s performance and financial condition and key risks for the schedule of works and expenditures, which are tantamount to its business risks, the Bank regularly reviews its performance and balance sheet projections. The projections are aimed at assessing the probability of meeting the objectives determined in the schedule and include action plans supporting achievement of such business and financial goals.

Business risk reporting

Business risk reports are prepared on a monthly, quarterly and annual basis. Monthly and quarterly reports cover key indicators of the Bank, statement of financial position, deposit, credit and performance data. The annual report is prepared for the Management Board, Risk Committee, Audit Committee, and Supervisory Board. The report presents performance details of the schedule of works and expenditures, Strategy of the Bank and also contains information on the factors of risk from the business environment, such as macroeconomic risk factors, changes in legal regulations for banking activity, as well as market trends and changes in the banking sector, along with the domain of offered services and banking technologies.

48.3. Compliance risk management

Compliance risk includes the risk of negative effects resulting from non-compliance with the provisions of applicable law, internal regulations or market standards in the Bank’s processes.

Compliance risk management includes risk identification, measurement, assessment, monitoring, and reporting and is carried out in line with written policies and procedures determining the code of conduct of the Bank.

The Bank’s unit responsible for coordination of the compliance risk management process is the compliance unit which develops and implements compliance risk management principles and methods for investigation procedures and compliance tests. To reduce the compliance risk, a compliance risk coordinator was appointed in the Bank’s organisational units that supports the compliance unit.

Reporting information on compliance risk is carried out on a regular basis.

48.4. Reporting changes in macroeconomic conditions

Macroeconomic risk is defined as the risk of changes in macroeconomic environment, which may adversely affect the Bank and minimum capital requirements in the future.

The objective of macroeconomic risk management is to identify macroeconomic factors that significantly affect the operations of the Bank and to reduce the adverse impact of such macroeconomic changes on the financial condition of the Bank.

Macroeconomic risk management process involves identifying those macroeconomic factors that significantly affect the operations of the Bank and determining potential scenarios for individual factors.

When designing the Bank’s Strategy, the Schedule of works and expenditures, the Credit Policy, and other documents important for the activities of the Bank, the Bank takes into account its macroeconomic environment and potential changes therein.

Macroeconomic risk is measured based on stress tests of macroeconomic factors (interest rates, exchange rates, changes in real estate prices, changes of prices of selected assets on goods markets, e.g. changes in energy commodity prices), ESG tests, accounting for, inter alia, environmental factors, as well as aggregate stress tests of capital adequacy analysing the impact of given assumptions, including macroeconomic factors, on capital requirements and internal capital.

In the previous year, in connection with the COVID-19 pandemic, for the purposes of performing aggregate stress tests, in individual test scenarios the Bank took into account the impact of the pandemic on risk factors.

Macroeconomic risk is also measured based on the Bank’s exposure in individual industries, clients or products. Internal limits are determined in line with the expected sector risk.

Macroeconomic risk is reported in monthly, quarterly and annual credit risk reports which present the impact of macroeconomic environment on the Bank’s lending activity and in individual stress test reports. The reports are drawn up for the Bank’s Credit Committee, the Asset and Liability Committee, the Management Board, the Risk Committee, and the Supervisory Board.

For information on stress tests accounting for different scenarios of COVID-19 pandemic development see Note 45.1.

48.5. Model risk management

Definition

Model risk means the potential loss the Bank may incur as a consequence of decisions that could be significantly based on the output of internal models used by the Bank, due to errors in the development, implementation or use of such models.

Management purposes

The risk of incurring losses as a result of wrong business decisions made based on the existing models is mitigated by operating a properly defined and implemented process for model management. One of the elements of the model management process is regular and independent validation of all material models.

Risk identification, measurement and assessment

Identification of model risk involves in particular collection of information on the models used or planned to be implemented and cyclical determination of materiality of individual models. Model risk assessment consists in an assessment of the risk for a single model and aggregate risk for all models and specification of the acceptable risk level.

Risk control

The purpose of model risk control is to obtain an aggregate assessment of the model risk at a level acceptable by the Bank. Model risk control consists in specification of mechanisms used for diagnosing the level of model risk as well as tools for reducing that risk.

Risk monitoring

All significant models subject to the process of independent periodical validation in line with the annual schedule of works approved by the Bank and prepared by an independent validation unit. An independent validation unit (independent in relation to the organisational units of the Bank that act as model owners or users) answers directly to the Member of the Management Board supervising the risk division. The results of model validation and recommendations are presented by an independent validation unit to the Model Management Committee.

Risk reporting

A quarterly model report (submitted to the Bank’s Model Management Committee – MMC) and semi-annual model report (submitted to the Bank’s Model Management Committee and the Management Board) contains in particular

information on: models register, models logbooks, changes in the number of models in use, the scope of their application and reasons for such changes, schedule of tasks for a given period with the evaluation of its implementation, reasons for delay (if any), and key findings of monitoring activities, model validation, and internal audits (if any), along with model risk level assessment.

As for the annual report presented to the Supervisory Board of the Bank, the Risk Committee, the Management Board of the Bank, and the Model Management Committee, contains information analogical to the quarterly and mid-year reports and in addition information on the system of model risk management with the list of scheduled activities associated with the management of models and their risks and efficiency assessment.

As part of credit risk management, in connection with the COVID-19 pandemic, management reports and monitoring systems were expanded by adding elements related to concessions granted to clients. Information on volumes and number of concessions granted in connection with difficulties resulting from the COVID-19 pandemic are cyclically reported to the Bank’s Management Board and, on a semi-annual basis, to the Risk Committee and the Bank’s Supervisory Board.

Impact of the COVID-19 pandemic

The COVID-19 pandemic is not reflected directly in the model risk.

49. Capital adequacy

Capital adequacy is monitored with the use of capital adequacy ratios:

§ capital ratios determined in accordance with Regulation (EU) No. 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No. 648/2012 (OJ L 176, 27.6.2013, p. 1, as amended), (CRR):

- Common Equity Tier 1 capital ratio;

- Tier 1 capital ratio;

- Total capital ratio.

§ internal capital ratio referred to in Article 128.1.2 of the Banking Law.

The above ratios are specified on an individual basis as the CRR does not require prudential consolidation.

In 2020, the Bank met the capital adequacy standards specified in the CRR and the Banking Law.

Capital adequacy management includes:

§ setting and monitoring capital adequacy ratios,

§ setting and monitoring the use of capital limits for individual activity areas, based on the internal capital,

§ aggregate stress testing,

§ reporting capital adequacy levels,

§ capital planning,

§ developing a capital contingency plan.

As part of capital adequacy management process, the Bank prepares regular reports on capital adequacy ratios, total capital requirement, internal capital and own funds, utilisation of capital limits, and stress tests results.

The Bank manages excessive leverage risk. Excessive leverage risk management is integrated with capital adequacy management and includes, inter alia, determining leverage ratio in line with Commission Delegated Regulation No. 2015/62 (EU) of 10 October 2014 to supplement Regulation (EU) No. 575/2013 of the European Parliament and of the Council with regard to leverage ratio (OJ L 11, 17.1.2015, p. 37) as Tier 1 capital measure divided by total exposure measure.

Dynamics of capital adequacy ratios and their components and the leverage ratio are presented in the tables below.


Capital adequacy ratios including flow funds
No.	Ratio	31 Dec 2020	31 Dec 2019
I	CET1 capital ratio	33.04%	27.54%
II	T1 capital ratio	33.04%	27.54%
III	Total capital ratio	33.04%	27.54%
IV	Internal capital ratio	30.73%	37.22%
V	Own funds	23,460,630	17,869,910
V.1	Tier1 capital	23,460,630	17,869,910
V.1.1	CET1	23,460,630	17,869,910
V.1.2	AT1	0	0
V.2	Tier2 capital	0	0
VI	Total capital requirement	5,680,681	5,190,120
VII	Internal capital	7,208,536	6,651,238
VIII	Leverage ratio	6.62%	10.29%

§ Additional information


Capital adequacy ratios excluding flow funds
No.	Ratio	31 Dec 2020	31 Dec 2019
I	CET1 capital ratio	33.06%	28.71%
II	T1 capital ratio	33.06%	28.71%
III	Total capital ratio	33.06%	28.71%
IV	Internal capital ratio	30.71%	36.04%
V	Own funds	23,460,630	17,869,910
V.1	Tier1 capital	23,460,630	17,869,910
V.1.1	CET1	23,460,630	17,869,910
V.1.2	AT1	0	0
V.2	Tier2 capital	0	0
VI	Total capital requirement	5,677,934	4,979,544
VII	Internal capital	7,205,789	6,440,662
VIII	Leverage ratio	12.70%	15.08%

Changes in the capital ratios and the internal capital ratio mainly resulted from:

§ an increase in own funds as a result of a capital injection to the Bank from the State Treasury in the form of a free transfer of treasury bonds with a nominal value of PLN 5,000,000 thousand made by the Minister of Finance and an increase in BGK’s statutory capital and supplementary capital attributable to accounting for the 2019 profit and retained earnings,

§ an increase in the total capital requirement caused mainly by an increase in capital requirement for credit risk in connection with, inter alia, a rise in equity exposures and exposure to corporates.

49.1. Own funds for capital adequacy ratio purposes

Own funds for capital adequacy ratio purposes are determined in accordance with Regulation (EU) No. 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms.

For capital adequacy purposes, own funds are determined on a separate basis, as no prudential consolidation is required under the CRR.

BGK’s own funds, determined in accordance with the CRR, include:

1) Tier 1:

§ Tier 1 (CET1, Common Equity Tier 1 capital):

- statutory fund that constitutes – pursuant to Article 3.3c of the Act on BGK – an equity instrument within the meaning of Articles 26(1)(a) and 28 of the CRR;

The statutory capital is created from monies and other assets contributed by the State Treasury (including Treasury securities provided by the minister competent for public finance) as well as annual contributions from the Bank’s net profit, in accordance with the principles specified in BGK’s Articles of Association.

- reserve capitals, including supplementary capital and reserve fund.

The supplementary capital and the reserve fund are established from the distribution of the annual net profit, in line with the principles defined in BGK’s Articles of Association.

- general banking risk reserve.

The general banking risk reserve is established from the distribution of the annual net profit, in line with the principles defined in BGK’s Articles of Association.

- accumulated other comprehensive income;

- deductions under intangible assets, except for software assets estimated on a conservative basis.

The amount deduction under intangible assets is decreased by deferred tax liabilities related to the intangible assets.

- deductions of deferred tax assets depending on future profitability and not resulting from temporary differences;

- Additional Valuation Adjustments AVA is a simplified approach pursuant to Commission Delegated Regulation (EU) No. 2016/101 of 26 October 2015 supplementing Regulation (EU) No. 575/2013 of the European Parliament and of the Council with regard to regulatory technical standards for prudent valuation under Article 105 (14) (OJ L 21, 28.1.2016, p. 54);

- Direct and indirect capital involvement of the Bank in financial sector entities, if the institution did not make a significant investment in those entities in the form of stock or shares held or of other instruments of the share capital or instruments of Tier 2 of those entities, as long as their aggregate amount exceeds 10% of Common Equity Tier 1 capital of the Bank.

If the amount of decreases lowers Tier 2 capital below zero, the surplus of those decreases over the Tier 2 capital is deducted from Tier 1 basic funds.

§ AT1, i.e. Additional Tier 1 Capital – as at 31 December 2020 and 31 December 2019, the Bank did not hold any positions in Additional Tier 1.

Own funds	31 Dec 2020	31 Dec 2019
Basic funds (Tier 1 capital)	23,460,630	17,869,910
Statutory capital	21,692,215	16,646,945
Supplementary capital	1,525,644	1,125,577
Other capital reserves	76,830	76,830
General banking risk reserve	155,500	155,500
Other comprehensive income	106,404	159,102
Intangible assets	-41,799	-54,962
Deferred tax liabilities related to intangible assets	3,805	3,575
Tier 1 adjustments resulting from prudential filters	-57,969	-21,070
Capital involvement decreasing own funds	0	-221,587
Supplementary funds (Tier 2 capital)	0	0
Total own funds	23,460,630	17,869,910

49.2. Capital requirements (Pillar I)

In order to define minimum capital requirements under individual risk types (Pillar I), the Bank applies methods described in the table below.


Capital requirement under:	Method
credit risk and counterparty credit risk	– standardised approach (Articles 111 to 141 of the CRR) – financial collateral comprehensive method (Articles 223 to 224 of the CRR) – balance sheet equivalent of derivative transactions in line with the mark-to-market method (Article 274 of the CRR) – alternative calculation of own funds requirement for exposures to a QCCP (Article 310 of the CRR)
foreign exchange risk	basic approach (Article 351 of the CRR)
commodities risk	simplified approach (Article 360 of the CRR)
position risk related to:
- specific risk of equity instruments in the trading book	pursuant to Article 342 of the CRR
- general risk of equity instruments in the trading book	pursuant to Article 343 of the CRR
- specific risk of debt instruments in the trading book	pursuant to Article 336 of the CRR
- general risk of debt instruments in the trading book	maturity-based approach (Article 339 of the CRR)
settlement risk	pursuant to Articles 378 to 380 of the CRR
large exposures in the trading book	pursuant to Article 397 of the CRR
operational risk	basic indicator approach (Articles 315 to 316 of the CRR)
credit valuation adjustment (CVA) risk	standardised method (Article 384 of the CRR)

Capital requirements structure in BGK – including flow funds:


NO.	Capital requirement under:	31 Dec 2020	31 Dec 2019
I.	credit risk and counterparty credit risk	5,367,823	4,913,713
II.	foreign exchange risk	0	0
III.	commodities risk	0	0
IV.	risk of positions in the trading book, including:	85,149	91,671
1	- specific and general risk of equity instruments	0	0
2	- specific risk of debt instruments	0	0
3	- general risk of debt instruments	85,149	91,671
V.	credit valuation adjustment (CVA) risk	32,018	37,049
VI.	settlement risk	1	0
VII.	large exposures in the trading book	0	0
VIII.	operational risk	195,690	147,687
Total		5,680,681	5,190,120

49.3. Internal capital (Pillar II)

Internal capital (Pillar II) is an amount estimated by the Bank which is necessary to cover all identified material risks occurring in the Bank’s operations as well as changes in the economic environment, which takes account of the expected risk level. The amount of internal capital is estimated to cover unexpected loss.

The internal capital is estimated to cover risks identified as material. For immaterial risks, the Bank does not establish internal capital to cover them. The total amount of internal capital is determined as the total of internal capital allocated to individual risks.

In order to estimate the internal capital allocated to individual risks, the Bank applies the approaches used to determine capital requirements or internal methods developed by the Bank.

As at 31 December 2020, internal capital totalled PLN 7,208,536 thousand and the internal capital ratio – 30.73%. The percentage structure of internal capital (including flow funds) is presented below.

ImageAlt5 A

49.4. Impact of the COVID-19 pandemic

To ensure that institutions are able to channel funds to businesses and households effectively and to mitigate the economic shock caused by the COVID-19 pandemic, Regulation (EU) 2020/873 of the European Parliament and of the Council of 24 June 2020 amending Regulations (EU) No 575/2013 and (EU) 2019/876 as regards certain adjustments in response to the COVID-19 pandemic was adopted in the EU. The regulation had a positive effect on the Bank’s capital adequacy ratios as the capital requirement for credit risk was reduced, mainly due to a temporary reduction of the risk weight for exposures to the central governments and central banks of Member States, where those exposures are denominated and funded in the domestic currency of another Member State, to 0%.A

Other supplementary information

50. Information on the entity authorised to audit the financial statements

On 15 December 2020, the Bank entered into an agreement for the statutory audit of the financial statements with Mazars Audyt Spółka z ograniczoną odpowiedzialnością for a definite term of three years (starting from the financial statements for 2020), with an option to extend it for another two years.

The Bank’s financial statements for 2019 were audited by Deloitte Audyt Spółka z ograniczoną odpowiedzialnością Sp.k. (until 19 March 2018: Deloitte Polska Spółka z ograniczoną odpowiedzialnością Sp.k.) under an agreement for the statutory audit of financial statements entered into on 20 December 2018 for a definite term of two years.

Fees paid or due for 2020:

§ audit of the full-year financial statements – PLN 483 thousand gross,

§ audit of the consolidated financial statements – PLN 251 thousand gross,

§ other attestation and related services – PLN 70 thousand gross.

Fees paid or due for 2019:

§ audit of the full-year financial statements – PLN 554 thousand gross,

§ audit of the consolidated financial statements – PLN 295 thousand gross,

§ other attestation services – PLN 53 thousand gross.

51. Proposed profit distribution of the parent entity

The parent entity intends to distribute the net profit for 2020 in the following way:

Item	Proposed distribution of net profit for 2020
Profit distribution	315,655
Statutory capital	290,403
Supplementary capital	25,252

In accordance with BGK’s Articles of Association, the Bank’s Management Board submits to the Supervisory Board a proposal of the distribution of the Bank’s profit or coverage of loss. The Supervisory Board adopts a final resolution to approve the profit distribution.

52. Assets pledged as collateral for the payment of liabilities

The Group’s assets include loans granted from the funds of the former National Housing Fund, which have been pledged as collateral for the repayment of a loan obtained from the Ministry of Finance (funds from the Council of Europe Development Bank) and for the State Treasury guarantees for loans obtained from International Financial Institutions (the European Investment Bank and the Council of Europe Development Bank).

The value of receivables transferred by BGK to the State Treasury in relation to loans granted and guaranteed by the Ministry of Finance to increase the National Housing Fund is presented below.

Lender	Loan amount	Loan amount guaranteed by the State Treasury	State Treasury guarantee amount	Loan amount transferred as collateral for the loan or guarantee
				31 Dec 2020	31 Dec 2019
European Investment Bank (EIB)	EUR 10,000	EUR 10,000	EUR 16,800	2,861	8,583
- Financial Contract No. 21.426
European Investment Bank (EIB)	EUR 200,000	EUR 200,000	EUR 296,000	391,675	457,111
- Financial Contract No. 21.607
Council of Europe Development Bank	PLN 700,000	PLN 700,000	PLN 1,260,000	287,760	371,760

*all data in the table above is indicated in PLN '000

The liabilities of the Group have been secured with the following assets:

Type of transaction	Collateral	31 Dec 2020		31 Dec 2019
Type of transaction	Collateral	Carrying amount of assets held as security against liabilities	Amount of liabilities secured	Carrying amount of assets held as security against liabilities	Amount of liabilities secured
Repurchase and reverse repurchase transactions	bonds	5,807,044	5,817,989	9,102,418	9,113,388
Other loans	loans	551,384	425,434	677,005	520,223
Derivative transactions	deposits	639,147	957,277	11,169	88,695

Basis for securities blocking:

§ for repo and sell-buy-back transactions – under standard procedures applicable to a given type of transactions in the money market,

§ for other loans, derivative transactions – under agreements concluded by the Bank.

Guaranteed Deposit Protection Fund

In line with the Act of 10 June 2016 on Bank Guarantee Fund, the system of deposit guarantee and mandatory restructuring, the Bank was excluded from the Act (Journal of Laws of 2017, item 1937) and, as a result, it does not contribute to the Guaranteed Deposit Protection Fund as of 1 January 2017.

53. Impact of the COVID-19 pandemic on the BGK Group’s operations

1) Financial situation

In 2020 and 2021, the Group has monitored its financial condition, including the impact of external factors related to the state of epidemic, on an ongoing basis. The Group takes active steps to adjust its functioning to the changing environment in the best possible way.

Decisions of the Monetary Policy Council

In March and May 2020, under the decisions of the Monetary Policy Council the key interest rates were reduced as follows:

Effective date	Reference rate	Lombard rate	Deposit rate	Rediscount rate	Discount rate
1 Jan 2020	1.50%	2.50%	0.50%	1.75%	4.00%
31 Dec 2020	0.10%	0.50%	0.00%	0.11%	0.12%

The parent entity estimates that the above decisions of the Monetary Policy Council, in particular to change the reference rate and deposit rate, had an adverse effect on its interest income in 2020. The parent entity’s interest margin dropped from 0.8% in 2019 to 0.6% in 2020, with a forecast of 0.5% for 2021.

Limitation of non-interest costs

Act on Specific Solutions Related to the Preventing, Counteracting and Combating COVID-19 and Other Infectious Diseases and Crises They Caused, dated of 2 March 2020, introduced limits on the maximum amount of non-interest costs of consumer credit. As the parent entity does not advance consumer loans, these limitations did not have any effect on the Group’s financial result.

Contribution to the State Budget and dividend received

On 26 March 2020, the parent entity received a letter from the Polish Financial Supervision Authority regarding dividend payment by banks. In its letter, the PFSA indicated that in view of the current situation related to the state of epidemic introduced in Poland and its potential further negative economic consequences, as well as its expected impact on the banking sector, the PFSA expected the banks – irrespective of the steps already taken – to retain the entire profit earned in previous years. In performance of the PFSA’s recommendations, the parent entity allocated the entire net profit for 2019 to increase its equity.

On 16 December 2020, the PFSA adopted a position on dividend policy of commercial banks, insurance and reinsurance undertakings in 2021.

The PFSA indicated that the immediate objective of its dividend policy is to ensure the stability of the Polish financial sector by adjusting the capital base of controlled entities to the level of risk they carry and protecting the recipients of financial services of these entities.

As regards commercial banks, given the considerable uncertainty surrounding the further development of the COVID-19 pandemic, the temporary nature of the solutions that banks use to improve capital during a pandemic, persistently cautious supervisory positions in the EU with regard to dividend restrictions and other forms of lowering capital resources and changing the EBA guidelines extending moratoria, the PFSA deemed it necessary for commercial banks to suspend dividends in the first half of 2021.

In compliance of the PFSA’s position, the parent entity intends to allocate the entire net profit for 2020 to increase its equity.

As the Group has a shareholding in PKO BP S.A. and PZU S.A., until 2019 it regularly received dividends from those investments (PLN 37 million in 2019). In 2020, PKO BP S.A. and PZU S.A. paid no dividend. The Group expects that in 2021 the received dividends will also be limited.

Administrative expenses of the parent entity

To organise the parent entity’s operation in the remote working environment resulting from the outbreak of the COVID-19 pandemic, in 2020 the parent entity incurred costs of approximately PLN 4,689 thousand on the purchase of the necessary hardware and software. Were it not for the COVID-19 pandemic, the costs would have likely been incurred in subsequent years.

In connection with the need to provide employees and clients with appropriate means of protection, e.g. antibacterial gels and face masks, in 2020 the parent entity incurred additional COVID-19-related costs of PLN 319 thousand.

In 2020, the parent entity’s expenditure on organisation of meetings and internal events, business trips, business meetings, training and office supplies amounted to approximately PLN 8,215 thousand. In 2019, about PLN 20,060 thousand was spent on that account. It is estimated that the drop in costs in 2020 in those areas was directly or indirectly related to COVID-19.

In cooperation with the John Paul II Mazowieckie Province Hospital, the parent entity created a temporary hospital in Siedlce for COVID-19 patients. The parent entity was responsible for the preparation of and providing equipment for the hospital and supporting the recruitment of personnel.

2) Risk management, supervisory stimulus and stress tests

For information on the impact of the COVID-19 pandemic on risk management, supervisory stimulus and stress tests see Section “Risk management objectives and principles”.

3) New funds, programmes and products related to the COVID-19 pandemic

The parent entity has taken an active part in development of systemic solutions that help entrepreneurs stay in the market in this difficult period of the COVID-19 pandemic. Under relevant acts, the parent entity established new flow funds and extended the scope of support provided through some others. New flow funds are as follows:

§ Liquidity Guarantee Fund – providing guarantees to medium and large companies hit by effects of the COVID-19 pandemic. As at 31 December 2020, guarantees worth approximately PLN 15,461.6 million were granted from the Fund,

§ COVID-19 Response Fund – mainly financing or co-financing tasks related to counteracting COVID-19. Till 31 December 2020, the parent entity had issued bonds with a total value of approximately PLN 100,843.2 million with the proceeds transferred to the COVID-19 Response Fund. All bonds issued for the benefit of the COVID-19 Response Fund are fully secured with a State Treasury guarantee,

§ Interest Subsidy Fund – the Fund’s objective is to provide subsidies to interest on working capital facilities granted to entrepreneurs and entities from the primary agricultural production sector, which experienced financial difficulties as a result of the COVID-19 pandemic. As at 31 December 2020, some PLN 1.1 million was paid out from the fund for interest subsidies,

§ Tourist Refund Fund – the Fund supports the tourism industry through payments to travellers who have not received a refund of the advance payment made or have not agreed to accept a voucher for a trip cancelled due to the pandemic. The Fund received PLN 300.0 million from the COVID-19 Response Fund. As at 31 December 2020, approximately PLN 200.0 million was paid out from the Fund.

The above new funds are presented in the financial statements of the Group in accordance with the same principles as for the flow funds described in Note 2.5.1 of these financial statements, i.e. their assets and liabilities and equity will not

be presented in the Group’s consolidated statement of financial position, as they are not assets and liabilities and equity within the meaning of IFRS.

The parent entity has relevant experience as an entity implementing financial instruments using EU and national funds. Apart from offering its existing instruments, such as de minimis guarantees, Biznesmax guarantees and loans from Regional Operational Programmes, the parent entity has launched new financial instruments designed to cushion the effects of the COVID-19 pandemic. In particular, these include:

§ Liquidity Support Loan Fund – LSLF SG OP,

§ Liquidity loan for Social Economy Entities.

Funds under these financial instruments were transferred to financial intermediaries to be used on advancing loans.

More detailed information on the parent entity’s aid package for entities hit by the effects of the COVID-19 pandemic is presented in the Report of the Management Board on the Activities of the Bank Gospodarstwa Krajowego Group in 2020.

The Polish Banks Association, the parent entity, commercial banks and associations of cooperative banks launched a number of initiatives, which combined with the above acts were related to many measures undertaken in the banking sector mainly involving offers of new liquidity products, deferral of payments of principal and interest or payments of principal by three to six months, extension by the same period of the final loan repayment deadline, and use of collaterals in the form of guarantees and sureties, made available to small, medium and large enterprises. Regarding loans advanced directly by the parent entity, an option was introduced to apply for a suspension of loan repayment for three months, and for working capital facilities it is possible to renew the existing facility for a period of up to six months (suspension may be applied several times up to a total suspension period of nine months). For more information on concessions for clients see Note 44.14.

The parent entity is engaged in supporting businesses suffering the effects of the pandemic, all the time intensively working on changes in products and programmes that would help its customers and partners maintain liquidity or the level of investment. The parent entity cooperates closely with the State authorities in the development of anti-crisis measures, and all legislative proposals are monitored and assessed by the Group on an ongoing basis.

4) Interim financing of Funds under the parent entity’s management

As part of management of the COVID-19 Response Fund, it may be necessary to provide interim financing to the Fund from the parent entity’s funds. As at 31 December 2020, the credit facilities provided to the COVID-19 Response Fund amounted to PLN 300 million.

The Act on Specific Solutions Related to the Preventing, Counteracting and Combating COVID-19 provides for bridge financing of the National Guarantee Fund and the Liquidity Guarantee Fund. The amount of the bridge financing was not specified. PLN 42 billion and PLN 100 billion of guarantees are planned to be provided from the National Guarantee Fund and the Liquidity Guarantee Fund, respectively.

5) Recapitalisation of the parent entity

The Ministry of Finance issued zero-coupon bonds (OB0722) with a nominal value of PLN 5,000 million maturing on 25 July 2022. On 24 April 2020, the bonds were transferred free-of-charge to Bank Gospodarstwa Krajowego to increase its statutory capital. The recapitalisation chiefly enables the parent entity to carry out activities focused on improving liquidity of businesses disrupted by the outbreak of the COVID-19 epidemic.

6) Recapitalisation of KUKE S.A.

In view of the situation related to the impact of the COVID-19 pandemic on the economy, including commercial insurers, on 10 April 2020 the General Meeting of KUKE S.A. resolved to recapitalise KUKE S.A. On 22 April 2020, the parent entity acquired 252,360 new shares in KUKE S.A. with a par value of PLN 100 per share, for PLN 50,000 thousand, in a private placement.

7) Impact of the COVID-19 pandemic on estimated impairment losses on investments in associates and other investments

When the Bank acquires investment certificates of closed-end investment funds it acts as a passive investor, for which one of the most important aspects is to monitor changes in the value of its investment. To mitigate risks related to the valuation and changes of the funds’ asset value, the Bank applies its own resources and tools to monitor and analyse the value of the assessed investments and, if needed, confronts its findings with the valuers of assets managed by closed-end private equity investment funds and revises their valuation. According to information provided to the Bank, the Fund

Manager closely monitors the situation and taking account of the extent of impact of the COVID-19 pandemic on funds it is looking for ways to mitigate its effect on the closed-end private equity investment funds.

As at 31 December 2020, taking account of the COVID-19 pandemic, the Bank assessed whether the current market conditions and the existing uncertainty regarding the macroeconomic situation caused by COVID-19 have an impact on the occurrence of impairment indicators, thus it assumed higher levels of uncertainty in its impairment tests.

8) Impact of the COVID-19 pandemic on the quality of the credit portfolio

The parent entity took a number of steps to facilitate the lending process during the epidemic, which involved the simplification of rules applied to changing the existing financing terms, including deferral of repayments. Also, it introduced a simplified approval path for deferral of repayments and renewal of financing for customers affected by the epidemic, while retaining the acceptable level of risk. In the lending process the parent entity has applied the guidelines of the Polish Financial Supervision Authority and the European Banking Authority regarding the classification and assessment of exposures in the light of the COVID-19 crisis. Details of the above activities and their effects are described in Section “Risk management objectives and principles”.

54. Major events subsequent to the reporting date

I. Major events related to the parent entity’s investment and financial activities:

§ 8 January 2021 – acquisition of Series K investment certificates issued by Fundusz Sektora Mieszkań dla Rozwoju FIZ AN with a value of PLN 150,000 thousand,

§ 13 January 2021 – distribution of funds from the Polish Growth Fund of Funds (PGFF) to BGK in the amount of EUR 2,200 thousand;

§ 18 February 2021 – acquisition of Series L investment certificates issued by Fundusz Sektora Mieszkań dla Rozwoju FIZ AN with a value of PLN 150,000 thousand,

§ 17 March 2021 – additional payment for Series B investment certificates of Fundusz Ekspansji Zagranicznej FIZ AN of EUR 6,752 thousand,

§ 22 March 2021 – redemption of part of Series T investment certificates of Fundusz Sektora Mieszkań na Wynajem FIZ AN with a value of PLN 47,770 thousand;

§ 26 March 2021 – establishment of Vinci S.A., an Alternative Investment Company Manager, with share capital of PLN 4,000 thousand,

§ 26 January 2021 – distribution of funds from the Three Seas Investment Fund SA SICAV RAIF (the Three Seas Initiative Investment Fund) to BGK in the amount of EUR 9,566 thousand.

II. Significant events at other Group entities

§ MDR Katowice 2 Sp. z o.o. – On 8 January 2021, the Extraordinary General Meeting passed a resolution to increase the share capital to PLN 9,479 thousand, i.e. by PLN 2,000 thousand, by way of issue of 20,000 equal shares with a par value of PLN 100 each, which were paid up on 21 January 2021. All shares in the increased share capital will be acquired by the existing shareholder of the company – FSMdR FIZ AN. Until the date of signing of these financial statements, the share capital increase had not been registered in the National Court Register.

§ MDR Mińsk Mazowiecki Sp. z o.o. – On 22 January 2021, the Extraordinary General Meeting passed a resolution to increase the share capital to PLN 10,864 thousand, i.e. by PLN 1,344 thousand, by way of issue of 13,440 equal shares with a par value of PLN 100 each; the shares issued as part of the share capital increase was paid for on 29 January 2021 with a cash contribution of PLN 1,680 thousand, of which PLN 336 thousand received as share premium was transferred to the supplementary capital. All shares in the increased share capital will be acquired by the existing shareholder of the company – FSMdR FIZ AN. Until the date of signing of these financial statements, the share capital increase had not been registered in the National Court Register.

§ MDR Inwestycje 15 Sp. z o.o. – on 25 January 2021, the company changed its name to MDR Lublin Krochmalna Sp. z o.o., which was entered in the National Court Register. On 25 January 2021, the share capital was increased by PLN 5,464 thousand to PLN 5,584 thousand, by way of issue of 54,640 new, equal and indivisible shares with a par value of PLN 100 each.

§ MDR Wrocław Białowieska Sp. z o.o. – on 26 January 2021, an increase in the company’s share capital to PLN 100 thousand, i.e. by PLN 50 thousand, through the issue of 500 equal shares with a par value of PLN 100 each, was entered in the National Court Register; the shares were paid for in cash.

§ MDR Toruń Sp. z o.o. – on 3 February 2021, the Extraordinary General Meeting passed a resolution to increase the share capital to PLN 20,975.2 thousand, i.e. by PLN 12,860 thousand, by way of issue of 128,600 new, equal and indivisible shares with a par value of PLN 100 per share; the shares were paid for in cash; all new shares were acquired by FSMdR FIZ AN. The Company has filed a request with the National Court Register to register the increase. As at the date of the financial statements, the share capital increase had not been entered into the National Court Register.

§ MDR Zamość Sp. z o.o. – On 9 November 2020, the Extraordinary General Meeting passed a resolution to increase the share capital to PLN 5,546 thousand, i.e. by PLN 3,090 thousand, by way of issue of 30,900 equal shares with a par value of PLN 100 each. All shares in the increased share capital were acquired by the existing shareholder of the company – FSMdR FIZ AN. The shares were partially paid up on 4 December 2020 in the amount of PLN 1,176.43 thousand. Shares amounting to PLN 1,914 thousand were paid up on 14 January 2021. As at the date of these financial statements, the increase had not been entered in the National Court Register.

§ On 15 January 2021, a preliminary agreement was concluded between MDR Zamość Sp. z o.o. and the Municipality of Zamość and TBS Sp. z o.o. of Zamość for the sale of all shares held by the Municipality and TBS for cancellation. The final agreement will be executed no later than on 30 April 2023. The Company is exclusively entitled to demand the execution of the final agreement before 30 April 2023. The shares will be purchased at arm’s length price.

These consolidated financial statements of the Bank Gospodarstwa Krajowego Group for the financial year from 1 January o 31 December 2020 consist of 130 pages numbered consecutively.

Warsaw, 15 April 2021

Prepared by:
Managing Director at the Financial Department
/-/
Rafał Szadurski

Signatures of the Members of the Management Board of Bank Gospodarstwa Krajowego:

President of the Management Board	First Vice-President of the Management Board	Vice-President of the Management Board
/-/	/-/	/-/
Beata Daszyńska-Muzyczka	Paweł Nierada	Włodzimierz Kocon

Member of the Management Board	Member of the Management Board	Member of the Management Board
/-/	/-/	/-/
Przemysław Cieszyński	Radosław Kwiecień	Tomasz Robaczyński