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Alior Bank S A : Financial document (Capital Adequacy Alior Bank Capital Group 31122025)

Alior Bank S A : Financial document (Capital Adequacy Alior Bank Capital Group

Alior Bank SaFebruary 23, 20264
Alior Bank S A : Financial document (Capital Adequacy Alior Bank Capital Group 31122025)

About this update from Alior Bank Sa

Capital Adequacy and Other Information Subject to Disclosure of the Alior Bank Spółka Akcyjna Capital Group as at 31 December 2025 List of Tables Introduction 5 EU OV1 - Overview of total risk exposure amounts 6 EU KM1 - Key metrics template 7 EU KM2 - Key metrics - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities 9 EU TLAC1 - Composition - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities 10 EU TLAC3b - Creditor ranking - resolution entity 12 EU INS1 - Insurance participations 13 EU INS2 - Financial conglomerates information on own funds and capital adequacy ratio 13 EU OVA - Institution risk management approach 13 EU OVB - Disclosure on governance arrangements 19 EU OVC - ICAAP information 21 EU LI1 - Differences between the accounting scope and the scope of prudential consolidation and mapping of financial statement categories with regulatory risk categories 22 EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statements 24 EU LI3 - Outline of the differences in the scopes of consolidation (entity by entity) 25 EU LIA - Explanations of differences between accounting and regulatory exposure amounts 27 EU LIB - Other qualitative information on the scope of application 27 EU PV1 - Prudent valuation adjustments (PVA) 28 EU CC1 - Composition of regulatory own funds 29 EU CC2 - Reconciliation of regulatory own funds to balance sheet in the audited financial statements 33 EU CCA - Main features of regulatory own funds instruments and eligible liabilities instruments 35 IFRS 9-FL - Comparison of institutions' own funds and capital and leverage ratios with and without the application of transitional arrangements for IFRS 9 or analogous ECLs 38 EU CCyB1 - Geographical distribution of credit exposures relevant for the calculation of the countercyclical buffer 39 EU CCyB2 - Amount of institution-specific countercyclical capital buffer 40 EU LR1 - LRSum: Summary reconciliation of accounting assets and leverage ratio exposures 40 EU LR2 - LRCom: Leverage ratio common disclosure 41 EU LR3 - LRSpl: Split-up of on balance sheet exposures (excluding derivatives, SFTs and exempted exposures) 44 EU LRA - Disclosure of LR qualitative information 45 EU LIQA - Liquidity risk management 45 Recommendation P - regarding the management of banks' financial liquidity risk 50 Analysis of maturity / payment of assets and liabilities for the Alior Bank Group, according to contractual deadlines at the end of 2025 51 Analysis of maturity / payment of assets and liabilities for the Alior Bank Group, according to the dates real to the end of 2025 . 52 EU LIQ1 - Quantitative information of LCR 53 EU LIQB on qualitative information on LCR, which complements template EU LIQ1 54 EU LIQ2 - Net Stable Funding Ratio 56 Disclosure period - 31.12.2025 56 Disclosure period - 30.06.2025 58 EU CRA - General qualitative information about credit risk 60 EU CRB - Additional disclosure related to the credit quality of assets 63 Recommendation R - regarding the rules for classifying credit exposures, estimating and recognizing expected credit losses and credit risk management 65 Business Client exposure portfolio 31.12.2025 67 Retail Client exposure portfolio - Mortgage 31.12.2025 69 Retail client exposure portfolio - Other 31.12.2025 71 Portfolio of exposures from the Leasing Activity 31.12.2025 73 EU CR1 - Performing and non-performing exposures and related provisions 75 EU CR1-A - Maturity of exposures 76 EU CR2 - Changes in the stock of non-performing loans and advances 76 EU CR2a - Changes in the stock of non-performing loans and advances and related net accumulated recoveries 76 EU CQ1 - Credit quality of forborne exposures 77 EU CQ2 - Quality of forbearance 77 EU CQ3 - Credit quality of performing and non-performing exposures by past due days 78 EU CQ4 - Quality of non-performing exposures by geography 79 EU CQ5 - Credit quality of loans and advances to non-financial corporations by industry 80 EU CQ6 - Collateral valuation - loans and advances 81 EU CQ7 - Collateral obtained by taking possession and execution processes 82 EU CQ8 - Collateral obtained by taking possession and execution processes - vintage breakdown 83 EU CRC - Qualitative disclosure requirements related to CRM techniques 84 EU CR3 - CRM techniques overview: Disclosure of the use of credit risk mitigation techniques 85 EU CRD - Qualitative disclosure requirements related to standardised approach 85 EU CR4 - Standardised approach - Credit risk exposure and CRM effects 86 EU CR5 - Standardised approach 87 EU CCRA - Qualitative disclosure related to CCR 89 EU CCR1 - Analysis of CCR exposure by approach 90 EU CCR3 - Standardised approach - CCR exposures by regulatory exposure class and risk weights 91 EU CCR5 - Composition of collateral for CCR exposures 92 EU CCR6 - Credit derivatives exposures 93 EU CCR8 - Exposures to CCPs 93 EU SECA - Qualitative disclosure requirements related to securitisation exposures 94 EU MRA - Qualitative disclosure requirements related to market risk 94 EU MR1 - Market risk under the standardised approach (ASA) 97 EU CVAA - Qualitative disclosure requirements related to credit valuation adjustment risk 98 EU CVA 1 - Credit valuation adjustment risk under the Reduced Basic Approach 98 EU CVAB - Qualitative disclosure requirements related to CVA risk for institutions using the Standardised Approach 99 EU IRRBBA - Qualitative information on interest rate risks of non-trading book activities 99 EU IRRBB1 - Interest rate risks of non-trading book activities 100 EU ORA - Qualitative information on operational risk 100 Recommendation M - concerning operational risk management in banks 102 Operating risk costs in the Alior Bank SA Group in 2025 by category 102 EU OR1 - Operational risk own funds requirements and risk-weighted exposure amounts 103 EU OR2 - Business Indicator, components and subcomponents 104 EU OR3 - Operational risk own funds requirements and risk exposure amounts 105 EU REMA - Remuneration policy 105 Guidelines EBA/GL/2022/06 and EBA/GL/2021/04 109 Table 1 - Representation of staff of different genders per quartile of remuneration level 109 Table 2 - Gender pay pap based on the total gross remuneration 110 Recommendation Z - concerning the rules of internal governance in banks 111 EU REM1 - Remuneration awarded for the financial year 112 EU REM2 - Special payments to staff whose professional activities have a material impact on institutions' risk profile (identified staff) 113 EU REM3 - Deferred remuneration 114 EU REM4 - Remuneration of 1 million EUR or more per year 116 EU REM5 - Information on remuneration of staff whose professional activities have a material impact on institutions' risk profile (identified staff) 117 EU AE1 - Encumbered and unencumbered assets 118 EU AE2 - Collateral received and own debt securities issued 119 EU AE3 - Sources of encumbrance 119 EU AE4 - Accompanying narrative information 120 ESG - Environmental, Social and Corporate Governance 120 Management Board's statement 121 ‌ Introduction Alior Bank Spółka Akcyjna with its registered office in Warsaw (hereinafter referred to as the "Bank") is obliged, under Part Eight of 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, as amended (hereinafter referred to as the "CRR Regulation") and the Banking Law Act of 29 August 1997, as amended (hereinafter referred to as the "Banking Law"), to publish quantitative and qualitative information within the scope of Pillar III in a generally accessible manner, excluding insignificant, proprietary or confidential information. The information is published in accordance with Commission Implementing Regulation (EU) 2024/3172 of 29 November 2024 laying down implementing technical standards for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to public disclosure by institutions of information referred to in Titles II and III of Part Eight of that Regulation and repealing Commission Implementing Regulation (EU) 2021/637, as amended (hereinafter "Regulation 2024/3172"), and is also published in accordance with Guidelines EBA/GL/2020/12 amending Guidelines EBA/GL/2018/01 and Guidelines EBA/GL/2021/04, EBA/GL/2022/08 and EBA/GL/2022/06 on remuneration policy, as well as supplemented with the provisions resulting from Recommendations M, P, R and Z of the Polish Financial Supervision Authority. The report is an implementation of the adopted "Information Policy regarding capital adequacy and other information to be published at Alior Bank S.A." (hereinafter "Information Policy"). The information policy was implemented by a resolution of the Bank's Management Board and approved by the Bank's Supervisory Board, and is published on the Bank's website. The presented scope of information is consistent with the requirements of Art. 433 and 433c of the CRR Regulation. Taking into account the scale of its operations, the bank does not meet the conditions described in Art. 4 points 145 and 146 of the CRR Regulation. The published scope of information is intended to provide market participants with a comprehensive picture of the risk profile of Alior Bank SA and the Alior Bank SA Capital Group. As at December 31, 2025, the Alior Bank SA Capital Group consists of: Alior Bank SA, as the parent company, and subsidiaries in which the Bank holds majority shares. For the purposes of calculations in the area of capital adequacy, prudential consolidation was used - in accordance with Article 19 of the CRR Regulation - therefore, the consolidation included Alior Bank SA and Alior Leasing Sp. z o. o. Unless otherwise stated, the information disclosed in this document is based on data from the consolidated financial statements of the Alior Bank S.A. Capital Group for the year ended December 31, 2025. The risk profile of the Bank's Capital Group is primarily influenced by Alior Bank S.A., therefore, some of the information contained in the report relates to individual data of Alior Bank S.A. Figures are drawn up in Polish zlotys (PLN) and are rounded up to one million zlotys (M). This version of our report is a translation from the original, which was prepared in Polish language. All possible care has been taken to ensure that the translation is an accurate representation of the original. However, in all matters of interpretation of information, views or opinions, the original language version of our report takes precedence over this translation. ‌ EU OV1 - Overview of total risk exposure amounts PLN m Total risk exposure amounts (TREA) Total own funds requirements 31.12.2025 31.12.2024 31.12.2025 a b c 0010 0020 0030 1 Credit risk (excluding CCR) 0010 52 603 45 451 4 208 2 Of which the standardised approach 0020 52 603 45 451 4 208 3 Of which the Foundation IRB (F-IRB) approach 0030 4 Of which slotting approach 0040 EU-4a Of which equities under the simple risk weighted approach 0050 5 Of which the Advanced IRB (A-IRB) approach 0060 6 Counterparty credit risk - CCR 0070 810 627 65 7 Of which the standardised approach 0080 237 142 19 8 Of which internal model method (IMM) 0090 EU-8a Of which exposures to a CCP 0100 567 483 45 9 Of which other CCR 0110 6 2 10 Credit valuation adjustments risk - CVA risk 0120 30 21 2 EU-10a Of which the standardised approach (SA) 0130 EU 10b Of which the basic approach (F-BA and R-BA) 0140 30 21 2 EU 10c Of which the simplified approach 0150 11 not applicable 0160 12 not applicable 0170 13 not applicable 0180 14 not applicable 0190 15 Settlement risk 0200 16 Securitisation exposures in the non-trading book (after the cap) 0210 17 Of which SEC-IRBA approach 0220 18 Of which SEC-ERBA (including IAA) 0230 19 Of which SEC-SA approach 0240 EU-19a Of which 1250% / deduction 0250 20 Position, foreign exchange and commodities risks (Market risk) 0260 357 217 29 21 Of which the Alternative standardised approach (A-SA) 0270 EU 21a Of which the Simplified standardised approach (S-SA) 0280 357 217 29 22 Of which Alternative Internal Model Approach (A-IMA) 0290 EU-22a Large exposures 0300 23 Reclassifications between the trading and non-trading books 0310 24 Operational risk 0320 5 843 4 895 467 EU 24a Exposures to crypto-assets 0330 25 Amounts below the thresholds for deduction (subject to 250% risk weight) 0340 26 Output floor applied (%) 0350 27 Floor adjustment (before application of transitional cap) 0360 28 Floor adjustment (after application of transitional cap) 0370 29 Total 0380 59 643 51 211 4 772 ‌ EU KM1 - Key metrics template PLN m 31.12.2025 30.06.2025* 31.12.2024** a. c. e. 0010 0030 0050 Available own funds (amounts) 0005 1 Common Equity Tier 1 (CET1) capital 0010 10 515 10 499 9 742 2 Tier 1 capital 0020 10 515 10 499 9 742 3 Total capital 0030 10 515 10 499 9 742 Risk-weighted exposure amounts 0035 4 Total risk exposure amount 0040 59 643 57 961 51 211 4a Total risk exposure pre-floor 0041 59 643 57 961 Capital ratios (as a percentage of risk-weighted exposure amount) 0045 5 Common Equity Tier 1 ratio (%) 0050 17.63% 18.11% 19.02% 5b Common Equity Tier 1 ratio considering unfloored TREA (%) 0051 6 Tier 1 ratio (%) 0060 17.63% 18.11% 19.02% 6b Common Equity Tier 1 ratio considering unfloored TREA (%) 0061 7 Total capital ratio (%) 0070 17.63% 18.11% 19.02% 7b Total capital ratio considering unfloored TREA (%) 0081 Additional own funds requirements to address risks other than the risk of excessive leverage (as a percentage of risk-weighted exposure amount) 0075 EU 7d Additional own funds requirements to address risks other than the risk of excessive leverage (%) 0080 EU 7e of which: to be made up of CET1 capital (percentage points) 0090 EU 7f of which: to be made up of Tier 1 capital (percentage points) 0100 EU 7g Total SREP own funds requirements (%) 0110 8.00% 8.00% 8.00% Combined buffer and overall capital requirement (as a percentage of risk-weighted exposure amount) 0115 8 Capital conservation buffer (%) 0120 2.50% 2.50% 2.50% EU-8a Conservation buffer due to macro-prudential or systemic risk identified at the level of a Member State (%) 0130 9 Institution specific countercyclical capital buffer (%) 0140 1.00% 0.01% 0.01% EU-9a Systemic risk buffer (%) 0150 10 Global Systemically Important Institution buffer (%) 0160 EU-10a Other Systemically Important Institution buffer (%) 0170 11 Combined buffer requirement (%) 0180 3.50% 2.51% 2.51% EU-11a Overall capital requirements (%) 0190 11.50% 10.51% 10.51% 12 CET1 available after meeting the total SREP own funds requirements (%) 0200 9.63% 10.11% 11.02% Leverage ratio 0205 13 Total exposure measure 0210 111 444 108 989 99 220 14 Leverage ratio (%) 0220 9.44% 9.63% 9.82% Additional own funds requirements to address the risk of excessive leverage (as a percentage of total exposure measure) 0225 EU-14a Additional own funds requirements to address the risk of excessive leverage 0230 EU-14b of which: to be made up of CET1 capital (percentage points) 0240 EU-14c Total SREP leverage ratio requirements (%) 0250 3.00% 3.00% 3.00% Leverage ratio buffer and overall leverage ratio requirement (as a percentage of 0255 EU-14d Leverage ratio buffer requirement (%) 0260 EU-14e Overall leverage ratio requirement (%) 0270 3.00% 3.00% 3.00% Liquidity Coverage Ratio 0275 15 Total high-quality liquid assets (HQLA) (Weighted value -average) 0280 26 192 24 173 22 632 EU-16a Cash outflows - Total weighted value 0290 13 406 13 684 14 191 EU-16b Cash inflows - Total weighted value 0300 1 623 2 081 2 081 31.12.2025 30.06.2025* 31.12.2024** a. c. e. 0010 0030 0050 16 Total net cash outflows (adjusted value) 0310 11 783 11 603 12 110 17 Liquidity coverage ratio (%) 0320 222% 208% 187% Net Stable Funding Ratio 0325 18 Total available stable funding 0330 82 570 78 943 76 180 19 Total required stable funding 0340 55 473 53 585 51 518 20 NSFR ratio (%) 0350 149% 147% 148% * On September 18, 2025, the Polish Financial Supervision Authority (KNF) approved the inclusion of part of the net profit of the prudentially consolidated Alior Bank S.A. Capital Group for the first half of 2025 in the consolidated Common Equity Tier 1 capital of the Alior Bank S.A. Capital Group. Data as at June 30, 2025 were recalculated to include in own funds the net profit generated for the first half of 2025, for which the KNF approved it. Therefore, the table above presents changed data compared to the information published for 2025 in the report "Interim Disclosures in Respect of Pillar III of the Alior Bank Spółka Akcyjna Capital Group for the half-year ended June 30, 2025". *On April 11, 2025, the Polish Financial Supervision Authority (KNF) approved the inclusion of a portion of the prudentially consolidated net profit of the Alior Bank SA Capital Group for 2024 in the prudentially consolidated Common Equity Tier 1 capital of the Alior Bank SA Capital Group. Data as at December 31, 2024, were recalculated to include the net profit generated for 2024 in own funds, for which the KNF approved it. Therefore, the table above presents changed data compared to the information published for 2024 in the report "Capital Adequacy and Other Information Subject to Disclosure of the Alior Bank Spółka Akcyjna Capital Group for the year ended December 31, 2024". On 16 June 2025, the Annual General Meeting of the Bank adopted resolution No. 7/2025 on the method of distributing the Bank's profit for the financial year 2024 . ‌ EU KM2 - Key metrics - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities PLN m Minimum requirement for own funds and eligible liabilities MREL G-SII Requirement for own funds and eligible liabilities TLAC a. 31.12.2025 b. 31.12.2025 c. 30.09.2025 d. 30.06.2025 e. 31.03.2025 f. 31.12.2024 0010 0020 0030 0040 0050 0060 Own funds and eligible liabilities, ratios and components 0009 1 Own funds and eligible liabilities 0010 12 784 N/A N/A N/A N/A N/A EU-1a Of which own funds and subordinated liabilities 0020 11 778 2 Total risk exposure amount of the resolution group TREA 0030 59 643 N/A N/A N/A N/A N/A 3 Own funds and eligible liabilities as a percentage of the TREA 0040 21,43% N/A N/A N/A N/A N/A EU-3a Of which own funds and subordinated liabilities 0050 19.75% 4 Total exposure measure TEM of the resolution group 0060 111 444 N/A N/A N/A N/A N/A 5 Own funds and eligible liabilities as percentage of the TEM 0070 11.47% N/A N/A N/A N/A N/A EU-5a Of which own funds or subordinated liabilities 0080 10.57% 6a Does the subordination exemption in Article 72b 4 of Regulation EU No 575/2013 apply? 5% exemption 0090 N/A N/A N/A N/A N/A 6b Aggregate amount of permitted non-subordinated eligible liabilities instruments if the subordination discretion in accordance with Article 72b 3 of Regulation EU No 575/2013 is applied max 3.5% exemption 0100 N/A N/A N/A N/A N/A 6c If a capped subordination exemption applies in accordance with Article 72b 3 of Regulation EU No 575/2013, the amount of funding issued that ranks pari passu with excluded liabilities and that is recognised under row 1, divided by funding issued that ranks pari passu with excluded liabilities and that would be recognised under row 1 if no cap was applied % 0110 N/A N/A N/A N/A N/A Minimum requirement for own funds and eligible liabilities MREL 0119 EU-7 MREL expressed as a percentage of the TREA 0120 15.36% EU-8 Of which to be met with own funds or subordinated liabilities 0130 15.36% EU-9 MREL expressed as a percentage of the TEM 0140 5.91% EU-10 Of which to be met with own funds or subordinated liabilities 0150 5.91% Alior Bank SA is not a global systemically important institution (G-SII), therefore it is obliged to meet the minimum requirement in terms of own funds and eligible liabilities MREL. ‌ EU TLAC1 - Composition - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities PLN m Minimum requirement for own funds and eligible liabilities MREL G-SII requirement for own funds and eligible liabilities TLAC Memo item: Amounts eligible for the purposes of MREL, but not of TLAC a b c 0010 0020 0030 Own funds and eligible liabilities, ratios and components 0009 1. Common Equity Tier 1 capital CET1 0010 10 515 N/A 2. Additional Tier 1 capital AT1 0020 N/A 3. Empty set in the EU 0030 4. Empty set in the EU 0040 5. Empty set in the EU 0050 6. Tier 2 capital T2 0060 N/A 7. Empty set in the EU 0070 8. Empty set in the EU 0080 11. Own funds for the purpose of Articles 92a of Regulation EU No 575/2013 and 45 of Directive 2014/59/EU 0090 10 515 N/A Own funds and eligible liabilities: Non-regulatory capital elements 0099 12. Eligible liabilities instruments issued directly by the resolution entity that are subordinated to excluded liabilities not grandfathered 0100 1 262 N/A EU-12a. Eligible liabilities instruments issued by other entities within the resolution group that are subordinated to excluded liabilities not grandfathered 0110 N/A EU-12b. Eligible liabilities instruments that are subordinated to excluded liabilities issued prior to 27 June 2019 subordinated grandfathered 0120 N/A EU-12c. Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items 0130 N/A 13. Eligible liabilities that are not subordinated to excluded liabilities not grandfathered pre-cap 0140 1 007 N/A EU-13a. Eligible liabilities that are not subordinated to excluded liabilities issued prior to 27 June 2019 pre-cap 0150 N/A 14. Amount of non subordinated eligible liabilities instruments, where applicable after application of Article 72b 3 CRR 0160 1 007 N/A 1 007 15. Empty set in the EU 0170 16. Empty set in the EU 0180 17. Eligible liabilities items before adjustments 0190 2 269 N/A EU-17a. Of which subordinated liabilities items 0200 1 262 N/A Own funds and eligible liabilities: Adjustments to non-regulatory capital elements 0209 18. Own funds and eligible liabilities items before adjustments 0210 12 784 N/A Minimum requirement for own funds and eligible liabilities MREL G-SII requirement for own funds and eligible liabilities TLAC Memo item: Amounts eligible for the purposes of MREL, but not of TLAC a b c 0010 0020 0030 19. Deduction of exposures between multiple point of entry (MPE) resolution groups 0220 N/A 20. (Deduction of investments in other eligible liabilities instruments) 0230 N/A 21. Empty set in the EU 0240 22. Own funds and eligible liabilities after adjustments 0250 12 784 N/A EU-22a. Of which: own funds and subordinated liabilities 0260 11 778 Risk-weighted exposure amount and leverage exposure measure of the resolution group 0269 23. Total risk exposure amount TREA 0270 59 643 N/A 59 643 24. Total exposure measure TEM 0280 111 444 N/A 111 444 Ratio of own funds and eligible liabilities 0289 25. Own funds and eligible liabilities as a percentage of TREA 0290 21,43% N/A 21.43% EU-25a. Of which own funds and subordinated liabilities 0300 19.75% 26. Own funds and eligible liabilities as a percentage of TEM 0310 11.47% N/A 11.47% EU-26a. Of which own funds and subordinated liabilities 0320 10.57% 27. CET1 as a percentage of the TREA available after meeting the resolution group's requirements 0330 9.63% N/A 28. Institution-specific combined buffer requirement 0340 N/A 29. of which capital conservation buffer requirement 0350 N/A 30. of which countercyclical buffer requirement 0360 N/A 31. of which systemic risk buffer requirement 0370 N/A EU-31a. of which Global Systemically Important Institution G-SII or Other Systemically Important Institution O-SII buffer 0380 N/A Memorandum items 0389 EU-32. Total amount of excluded liabilities referred to in Article 72a 2 of Regulation EU No 575/2013 0390 N/A Alior Bank SA is not a global systemically important institution (G-SII), therefore it is obliged to meet the minimum requirement in terms of own funds and eligible liabilities MREL. ‌ EU TLAC3b - Creditor ranking - resolution entity PLN m Insolvency ranking Insolvency ranking 1 2 3 4 5 6 7 8 9 10 Sum of 1 to 10 (most junior) (most senior) 1 Description of insolvency rank (free text) Receivables due to liabilities included in the bank's own funds, referred to in Art. 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013, as amended, including interest and enforcement costs Receivables due to liabilities included in the bank's own funds, referred to in Art. 51 of Regulation No. 575/2013, along with interest and enforcement costs Receivables due to liabilities included in the bank's own funds, referred to in Art. 62 of Regulation No. 575/2013, along with interest and enforcement costs Receivables from subordinated liabilities not included in the bank's own funds, along with interest and enforcement costs Receivables under bonds, together with interest and enforcement costs, excluding receivables in category 9, under other debt instruments that have the characteristics of negotiable receivables, or under instruments giving rise to the legal effects of debt financial instruments Receivables of partners or shareholders arising from a loan or other legal transaction with similar effects, in particular the delivery of goods with deferred payment date, together with interest, if they are not subject to satisfaction in lower categories Interest on receivables included in higher categories in the order in which the capital is satisfied, as well as judicial and administrative fines and receivables for donations and bequests Other liabilities, if they cannot be satisfied in other categories, in particular taxes and other public levies and other liabilities due to social security contributions Receivables from natural persons, micro-entrepreneurs, small and medium-sized enterprises in respect of funds covered by guarantee protection other than guaranteed funds within the meaning of Art. 2 point 65 of the Act of 10 June 2016 on the Bank Guarantee Fund Receivables referred to in Art. 39 section 1 of the Act of 10 June 2016 on the Bank Guarantee Fund 2 Empty set in the EU 3 Empty set in the EU 4 Empty set in the EU 5 potentially eligible for 10 515 meeting MREL 1 262 7 1 053 33 12 870 6 of which residual maturity 451 53 32 536 7 of which residual maturity 811 7 1 000 1 1 819 Own funds and liabilities ≥ 1 year < 2 years ≥ 2 year < 5 years of which residual maturity ≥ 5 years < 10 years of which residual maturity ≥ 10 years, but excluding perpetual securities of which perpetual securities 10 515 10 515 ‌ EU INS1 - Insurance participations PLN m Exposure value Risk exposure amount a b 0010 0020 Own fund instruments held in insurance or re-insurance undertakings or insurance holding company not deducted from own funds 0010 Alior Bank SA does not hold equity interests in insurance companies. ‌ EU INS2 - Financial conglomerates information on own funds and capital adequacy ratio PLN m 31.12.2025 a 0010 1 Supplementary own fund requirements of the financial conglomerate (amount) 0010 2 Capital adequacy ratio of the financial conglomerate (%) 0020 Alior Bank SA is part of a financial conglomerate headed by PZU SA, the Bank itself does not calculate additional requirements for the financial conglomerate's own funds. ‌ EU OVA - Institution risk management approach Legal basis Row number Details Point (f) of Article 435(1) CRR As part of the risk appetite, the Bank's Management Board approved the expected levels of the Bank's key capital ratios for 2025 at the level of: total capital ratio - 12.00 % and Tier 1 capital ratio - 10.00%. The expected internal capital coverage ratio by own funds was approved at 1.5. Risk appetite levels for capital ratios remained at the same level as in 2024. The bank is still not identified as a systemically important institution, therefore there is no buffer of another systemically important institution (O-SII). In November 2025, the Polish Financial Supervision Authority (KNF) imposed an additional capital charge (P2G) on the Bank to absorb potential losses resulting from stress events. The total capital charges recommended under Pillar II (P2G) offset by the capital conservation buffer requirement are 2.73 percentage points at the individual level and 2.26 p.p. at the consolidated level. The structure of the assessed risk exposure measured by the capital requirement for individual types of risk throughout 2025 remained at a level consistent with the structure of the risk exposure in the entire banking sector in Poland. The structure of the assessed risk exposure confirms the dominance of credit risk exposure in the total risk exposure. In accordance with its policy, the Bank does not maintain significant exposure to market risk, therefore its share in the exposure structure is small. The share of operational risk exposure was close to the average for the Polish banking sector. Point (b) of Article 435(1) CRR In order to efficiently and effectively manage the risk system at Alior Bank SA, the supervision, control and responsibility for the operation of this system have been entrusted to: the Supervisory Board, the Risk Committee of the Supervisory Board, Legal basis Row number the Bank's Management Board, Details Committees (Capital, Assets and Liabilities Management Committee - CALCO, Operational Risk Committee, Credit Risk Committee and Business Initiatives Committee, Model Risk Committee, Bank Credit Committee), organizational units responsible for particular types of risk. The risk management system in place at the Bank is based on three independent lines of defense. Its framework is set by standards applicable in the banking sector and guidelines contained in regulations, including supervisory recommendations, which are reflected in the applicable internal regulations. The Supervisory Board oversees the Group's risk management system, the compliance of the Group's risk-taking policy with the Group's strategy and financial plan, and assesses the adequacy and effectiveness of this system, in particular through: approval of the risk appetite defined by the Bank's Management Board for a given year and monitoring of its compliance, approval of the risk management strategy adopted by the Bank's Management Board and monitoring of its compliance, supervision over the development, adoption and implementation of policies and procedures on the basis of which the risk management system is to function in the Group, defining the rules for reporting to the Supervisory Board on the types and size of risk in the activity in a way that allows the supervision of the risk management system in the Group, annual assessment of the adequacy and effectiveness of the risk management system. The Risk Committee of the Supervisory Board supports the Supervisory Board in supervision over the Group's risk management system. The Committee operates based on the Rules of Procedure of the Risk Committee of the Supervisory Board of Alior Bank approved by the Supervisory Board. The most important tasks of the Risk Committee of the Supervisory Board include in particular: supporting the Bank's Supervisory Board in supervising the risk management system at the Bank, giving opinions on the Bank's overall, current and future readiness to take risk, giving opinions on the Bank's risk management strategy and analyzing the information submitted by the Management Board regarding the implementation of this strategy, monitoring issues related to the implementation of the audit plan and recommendations issued by the Audit Department, issuing opinions/conclusions on materials regarding the risk management system, including with regard to the annual report of the Risk Strategy Department, Compliance Department, Audit Department, in order for the Bank's Supervisory Board to assess the adequacy and effectiveness of the internal control system and risk management system, supporting the Bank's Supervisory Board in overseeing the implementation of the Bank's risk management strategy by senior management, verification of compliance of the price of liabilities and assets offered to clients with the Bank's business model and its risk strategy; in the event of non-compliance, presenting to the Bank's Management Board proposals to ensure the adequacy of the prices of liabilities and assets to these types of risk, issuing opinions on regulations defining the Bank's strategy and approach to risk-taking, analysis of periodic reports on the implementation of the above strategies and policies. In 2025, 11 meetings of the Risk Committee of the Supervisory Board and 1 combined meeting of the Risk Committee of the Supervisory Board and the Audit Committee of the Supervisory Board were held. Legal basis Row number Details The Management Board of the Bank designs, implements and ensures the operation of a coherent risk management system in the Group, adjusted to the risk profile, including the rules for managing individual risk types of the Group, ensuring their consistency with the Group's risk management strategy, and determining the risk appetite. Moreover, the Management Board determines the organizational structure of the Bank, including foreign branches, taking care to properly divide the roles that are key to risk management. In the effective management of individual risks, the Board is supported by Committees established for this purpose. The Committees take decisions and make recommendations at standing meetings or by circulation . The objective of the Capital, Assets and Liabilities Management Committee (CALCO) is to support the Bank's Management Board in effective management of market risk, liquidity risk, counterparty risk, business risk, capital risk and excessive leverage risk, as well as to supervise the operation of the Recovery Plan. In 2025, the CALCO Committee held 42 meetings. The Operational Risk Committee (KRO) was established to support the Bank's Management Board in the effective management of operational risk, including issues related to the maladjustment or unreliability of processes, the operation of people and systems or resulting from external threats, including significant subsidiaries. The Committee monitors the level of exposure to operational risk and assesses the situation in the area of operational risk throughout the Bank. In 2025 the Operational Risk Committee held 12 meetings. The objective of the Credit Risk Committee and Business Initiatives Committee is to support the Bank's Management Board in effective management of the Bank's credit risk, including credit concentration risk. In 2025, the Credit Risk and Business Initiatives Committee held 14 meetings. The Model Risk Committee supports the Bank's Management Board in the effective management of model risk, taking into account significant subsidiaries where model risk has been recognized as material under the Internal Capital Adequacy Assessment Process (ICAAP). In 2025, the Model Risk Committee held 14 meetings. The subject of the Bank's Credit Committee is to approve credit decisions on the Bank's on-balance sheet and off-balance sheet exposure, to make decisions on the introduction of special offers and to make decisions on all matters not regulated in the Credit Competence Rules, which involve the Bank taking credit risk, up to the limit of competences granted to Bank's Credit Committee, and recommending to the Bank's Management Board credit decisions for exposures exceeding the limit granted to the committee. In 2025, the Bank's Credit Committee held 107 meetings. The Bank supervises the functioning of the subsidiaries of the Bank's Capital Group. The Bank supervises the risk management systems in these entities and takes into account the level of risk related to the activities of individual entities as part of the risk monitoring and reporting system at the level of the Bank's Group. The Risk Materiality Group is responsible for the risk review at Alior Bank SA. The Group is composed of representatives of individual divisions and areas of the Bank's operations, having appropriate knowledge of the current and potential risk. In particular, they are representatives of units responsible for managing credit risk, market risk and operational risk. Due to the variety of phenomena accompanying particular types of risk, each of them is managed by the appropriate leading unit. In the case of credit risk, individual functions related to identification, measurement, assessment and monitoring have been divided among several organizational units. The detailed scope of tasks of individual units is presented when discussing each type of risk. Legal basis Row number Details The Audit Department conducts independent audits to provide the Supervisory Board and the Management Board of the Bank with objective information regarding the assessment of the effectiveness and adequacy of the risk management system in the Bank's Capital Group. Point (e) of Article 435(1) CRR c) The implemented and applied risk management system in the Group is appropriate from the point of view of the Group's profile and strategy. Point (c) of Article d) Risk measurement and assessment includes the determination of risk measures adequate to the materiality of a given type of risk and risk quantification using the established measures, as well as 435(1) CRR risk assessment consisting in determining the level of risk that may pose a threat to the achievement of the Group's strategic goals. As part of the risk measurement, stress tests are carried out on the basis of assumptions ensuring reliable risk assessment, which include an analysis of the impact of changes in the environment and functioning of the Group on its financial and capital position. The measurement results are regularly reported to the Bank's authorities and designated organizational units. Point (c) of Article e) Risk reporting consists in regularly providing the Supervisory Board, the Management Board, committees and organizational units of the Bank indicated by the Management Board with reliable 435(1) CRR and regular information on changes in the size and profile of the Group's risk, as well as on the undertaken and recommended actions in the field of risk management. The scope, frequency and form of reporting are adjusted to the management level of the recipients, which is regulated in detail in the Bank's internal regulations. Point (a) of Article f) Credit risk Credit risk management and keeping it at a safe level, defined in the risk appetite, is of fundamental 435(1) CRR importance for the Bank's stable operation and development. Credit risk is controlled by the credit risk management system in place at the Bank, which is comprehensive and integrated with the Bank's operational processes. The description of the risk control system operation is reflected in the regulations in force at the Bank, in particular in the lending methodologies and risk valuation models tailored to the client's segment, product and transaction type, rules for establishing and monitoring legal loan collateral, and monitoring and debt collection processes. By managing the risk (both on an individual and portfolio basis), the Bank takes actions that lead to: minimizing the level of credit risk of a single loan with the assumed profitability level, reduction of the total credit risk resulting from the Bank's specific loan portfolio. As part of minimizing the risk of a single exposure, the Bank assesses each time when granting a loan product: credibility and creditworthiness of the client, taking into account, inter alia, detailed analysis of the source of exposure repayment, credibility of the accepted collateral, including verification of their formal, legal and economic status, taking into account, inter alia, LTV adequacy undertakes effective monitoring and debt collection activities adequately defined at the level of a single client thanks to the segmentation models used. In order to maintain the credit risk at the level defined in the risk appetite, the Bank takes the following actions: sets and controls concentration limits, monitors the structure and quality of a new credit exposure in relation to the defined objectives and signals of EWS, analyzes changes in internal factors as well as market and geopolitical factors and the sensitivity of the loan portfolio, particularly with regard to negative events identified as potential risks, regularly monitors the loan portfolio, controlling all significant parameters of credit risk (including SRC,PD, LGD, LTV, DTI, COR, NPE, NPL), Legal basis Row number regularly carries out stress tests. Details In addition to individual organizational units in the credit risk management process, an active role is played by the Supervisory Board, the Bank's Management Board, the Credit Risk Committee and Business Initiatives Committee and the Bank's Credit Committee. Operational risk The Bank has a formal operational risk management system that prevents the occurrence of operational events and limits losses in the event of risk materialization. Operational risk management includes the identification, measurement and assessment of operational risk, management activities and risk monitoring and control at all levels, from organizational units responsible for operational risk management in their areas, operational risk coordinators, through the Operational Risk Management Department, the Operational Risk Committee, to Management Board and Supervisory Board. An element of operational risk management is also reporting the level of this risk, both for internal and external purposes. The recipients, frequency and type of management information in operational risk reports are described in the Management Information System Principles (approved at the level of the Bank's Management Board). As part of the identification of operational risk, the Bank recognizes risk factors that significantly influence its level. At the identification stage, various methods of obtaining information are used, including: collecting data on events and losses at the Bank, identifying risks in products, processes, systems, contracts and business reports (projects, initiatives), analysis of external operational risk events. Measurement and assessment of operational risk are carried out using quantitative and qualitative measures and include, among others: the new standardised approach (SMA) is used to determine the own funds requirements for operational risk for Alior Bank S.A. and at the consolidated level of the Alior Bank S.A. Capital Group, estimation of the Bank's internal capital for operational risk using the results of the internal model, scenario analyses, self-assessment of operational risk of products, processes, systems, contracts and business notifications, setting an internal target and a limit for operational risk costs, determining the level of target utilization and the limit for operational risk costs, setting business goals for operational risk costs, KRI, valuation of actual and potential losses related to identified operational events, conducting Stress Tests. From 2025, for the purposes of determining own funds requirements for operational risk for Alior Bank S.A. and at the consolidated level of the Alior Bank S.A. Capital Group a new standard approach (SMA) is used, in accordance with the guidelines of the Regulation of the European Parliament and of the Council (EU) of 31 May 2024 amending Regulation (EU) No. 575/2013 with regard to requirements regarding credit risk, risk related to credit valuation adjustments, operational risk, market risk and the minimum capital threshold (Resolution No. 459/2024 of the Management Board of Alior Bank S.A. of December 30, 2024). Market risk The following types of market risk have been identified in the Bank and are subject to management: interest rate risk in the banking book, Legal basis Row number Details market risk in the trading book (including interest rate risk in the trading book, currency risk and commodity price risk). The objective of market risk management is to limit potential losses due to changes in market risk factors to an acceptable level by appropriately shaping the structure of the balance sheet and off-balance sheet items. The Bank distinguishes the following market risk factors: exchange rates, interest rate indices, stock / index prices, prices of goods, credit spread related to the rating of a given issuer, options volatility parameters. The Bank has a clear division of competences in the area of market risk management, including: concluding treasury transactions, measurement, monitoring and reporting of market risk, transaction settlement process, operational service and operational support for business processes. Supervision over the above-mentioned activities related to concluding transactions as well as independent measurement and reporting of risk at the Bank has been distributed to the level of a Management Board Member, which guarantees full independence of their operations. Points (a) and (d) of Article 435(1) CRR g) Credit risk Collaterals are established in relation to the credit risk incurred by the Bank and in a flexible manner to the client's abilities. Its establishment does not release the Bank from the obligation to examine the customer's creditworthiness. The purpose of securing the loan is to provide the Bank with the repayment of the granted loan together with the interest and costs due, if the borrower fails to pay the amounts due within the time limits specified in the loan agreement and the restructuring activities do not bring the expected results. Details in points b and c of EU CRC - Qualitative disclosure requirements related to CRM techniques. Operational risk In order to limit the risk of materializing the effects of rare but potentially severe operational events, the Bank purchased a number of insurance policies. The above-mentioned policies included, among others: insurance in the field of: property (including electronic equipment), civil liability, fiscal penal liability and professional liability. The terms of individual policies are adapted to the scale and scope of the risk incurred. An important element of operational risk management at Alior Bank is business continuity management (BCM). As part of BCM, the Bank implements the BCM system and strategies in accordance with the Business Continuity Management Policy and the ICT Business Continuity Management Strategy approved by the Bank's Management Board. The above aspect is also regulated by the "ICT Business Continuity Management Policy" introduced by the Decision of the Vice-President of the Bank responsible for the IT Area. As part of the BCM Bank system, periodically: analyzes business processes / operational activities, reviews and updates the strategy for action in emergency and crisis situations, develops and implements emergency solutions and Business Continuity Plans (BCP), performs tests, updates and self-assessment of the BCM system, builds awareness in the organization in the field of BCM. The implementation of the agreed BCM system and strategy is intended to ensure the implementation of critical business processes in the event of an unplanned disruption. The bank has periodically tested emergency solutions for the implementation of critical processes (including replacement locations) and disaster recovery solutions. Legal basis Row number Market risk Details Market risk is limited by a system of limits and warning thresholds as well as an appropriate number of regulations defining the framework of the Bank's operations in terms of exposure to market risk. The limits are defined in particular in the form of the market risk appetite at the level of the Bank's Supervisory Board. Moreover, the CALCO Committee additionally limits the market risk with supplementary limits. Market risk is hedged by appropriate shaping of the Bank's balance sheet structure (natural hedge) and by concluding appropriate hedging transactions. Some of the hedging transactions are designated for hedge accounting, both for cash flow volatility and fair value volatility. ‌EU OVB - Disclosure on governance arrangements Legal basis Row number Details Point (a) of Article 435(2) CRR As at December 31, 2025, members of the Bank's Management Board: Piotr Żabski (President of the Bank's Management Board), Marcin Ciszewski (Vice-President of the Bank's Management Board), Zdzisław Wojtera (Vice-President of the Bank's Management Board), Jacek Iljin (Vice-President of the Bank's Management Board), Wojciech Przybył (Vice-President of the Bank's Management Board) Beata Stawiarska (Vice-President of the Bank's Management Board). Members of the Bank's Management Board, in addition to their positions at Alior Bank S.A., held the following positions: Piotr Żabski, Polski Standard Płatności sp. z o.o. - Member of the Supervisory Board, Jacek Iljin, Alior TFI S.A. - Chairman of the Supervisory Board, Wojciech Przybył, Alior Leasing sp. z o.o. - Chairman of the Supervisory Board, Zdzisław Wojtera, System Ochrony Banków Komercyjnych S.A. - Member of the Supervisory Board. Point (b) of Article 435(2) CRR The following applies at Alior Bank Spółka Akcyjna: Policy for the selection and assessment of suitability of members of the Management Board of Alior Bank S.A. and Policy for selection and assessment of suitability of members of the Supervisory Board of Alior Bank S.A. , taking into account, among others, the provisions of the Methodology for assessing the suitability of bodies of entities supervised by the Polish Financial Supervision Authority (hereinafter referred to as the "Methodology"). In relation to members of the Management Board, its purpose is to fulfill obligations arising from legal provisions and support the implementation of the Bank's strategy by ensuring that the functions of members of the Management Board are performed by persons with knowledge, skills and experience appropriate to the functions they perform and the duties entrusted to them, and provide a guarantee proper performance of these duties. In order to ensure the individual suitability of the Management Board members, the Nomination and Remuneration Committee of the Supervisory Board and then the Supervisory Board assess the initial suitability of the candidates and, based on this assessment, decides on appointment to the Management Board. The collective suitability of the body is also assessed. The Nomination and Remuneration Committee of the Supervisory Board and the Supervisory Board periodically (once a year) verify the suitability of the Management Board members, making a secondary assessment of the individual suitability of individual Management Board members and assessing the collective suitability of the Management Board. Secondary evaluation of Management Legal basis Row number Details Board members also takes place in the event of changes in the areas subject to evaluation according to the Methodology. Point (c) of Article 435(2) c) The Bank makes efforts to ensure diversity of the Management Board, in particular in terms of education and professional experience, specialist knowledge, gender and age of the Management CRR Board members, to the extent that ensures a broad spectrum of views of the management body. When selecting the composition of the Management Board, the Bank aims to achieve a balance in terms of gender representation in this body, the total number of positions in the Management Board and the Supervisory Board of the Bank held by persons of the underrepresented gender at a level no lower than the number closest to 33% of all positions in both bodies, in a situation where at least one person of the underrepresented gender holds a position in the Management Board of the Bank. In order to achieve the assumed target share of both genders in the Management Board, the Nomination and Remuneration Committee ensures the participation of both sexes in the process of selecting Management Board members and equal treatment of candidates regardless of gender. In cases where the selection process for a position on the Bank's Management Board involves a choice between candidates with equivalent qualifications, priority is given to the candidate of the gender that is underrepresented in the Bank's bodies, unless other diversity principles specified in legal provisions, based on non-discriminatory criteria, justify the selection of a candidate of the opposite gender. When assessing the diversity of the Bank's Management Board Members in terms of education and professional experience, the following criteria may be taken into account: place (country, region) of obtaining education or professional experience, educational profile, field of study, specialization in a specific field, type of entities in which the candidate for a Bank's Management Board Member held a position or was employed, and length of service. The Bank recruits Members of the Bank's Management Board taking into account, first of all, the criteria specified above - necessary for the proper functioning and suitability of the Bank's Management Board as a whole. As part of its annual review of the composition of the Bank's Management Board, the Nomination Committee assesses its compliance with the objectives and target values referred to above. If these are not met, it should document the reasons for non-compliance, the measures that will be taken, and the deadlines for their implementation to ensure the objectives and values are met. The composition of the Bank's Management Board should not be shaped solely for the purpose of increasing diversity at the expense of the functioning and suitability of the Management Board as a whole or the suitability of individual members of the Bank's Management Board. Point (d) of Article 435(2) d) The Risk Committee of the Supervisory Board of Alior Bank S.A. was established on 22 December 2015 by Resolution No. 81/2015 of the Supervisory Board to support the Supervisory Board in CRR overseeing the risk management process at the Bank. The Committee operates based on the Rules of Operation of the Risk Committee of the Supervisory Board of Alior Bank S.A. approved by the Supervisory Board. Meetings of the Committee are held in accordance with the work plan adopted by the Committee, generally on a monthly basis. Point (e) Article 435(2) e) Reporting to the management body is carried out in accordance with the principles described in the Regulation of the Management Information System (approved at the level of the Bank's Management Board). Management reporting is carried out in the following cycles: Monthly: the monthly information for the Bank's Management Board is to present to the Bank's Management Board the aggregated results of the implementation of the Bank's strategy in terms of individual risks in relation to the adopted risk appetite, the implementation of key risk indicators, including the risk appetite in the credit portfolio of the Alior Bank Group, involves presenting the aggregated results of the implementation Legal basis Row number Details of the Bank's strategy in terms of individual risks in relation to the adopted risk appetite to the Bank's Management Board and the Risk Committee of the Supervisory Board. Quarterly: quarterly information for the Bank's Management Board, the Risk Committee of the Supervisory Board and the Supervisory Board is the presentation to the Management Board of the Bank, the Risk Committee of the Supervisory Board and the Supervisory Board of the aggregated results of the implementation of the Bank's strategy in terms of individual risks in relation to the adopted risk appetite. Semi-annual: report on the assessment of outsourcing and sensitive services in terms of operational risk for the Bank's Management Board and Supervisory Board, Annual: summary of annual risk results, including accounting for risk appetite and risk policy implementation for the previous year, report on information technology risk at Alior Bank for the Bank's Management Board and the Risk Committee of the Supervisory Board, annual report - Operational risk management in the Alior Bank S.A. Group. for the Bank's Management Board, the Risk Committee of the Supervisory Board and the Supervisory Board, includes a summary of the implementation of the operational risk management strategy and policy. ‌EU OVC - ICAAP information Legal basis Row number Details Article 438(a) CRR Alior Bank SA has an internal capital adequacy assessment process (ICAAP) in line with the Regulation of the Minister of Finance, Funds and Regional Policy of 3 August 2021 on the detailed method of internal capital estimation and bank reviews. The purpose of the internal capital adequacy assessment process is to ensure that all risks to which the Bank is exposed are analyzed in terms of materiality and that the Bank has an adequate amount of capital to cover the risks deemed material. The process includes the following phases: identification of material risks - performed as part of the process review on an annual basis, or more frequently in justified cases, quantification of individual risks and total internal capital - performed on an ongoing basis, stress testing - performed on an annual basis or more frequently in justified cases, reporting and monitoring of capital goals, including available capital allocation limits -cyclically, capital management and capital planning - performed on an ongoing basis in order to ensure the adequacy of internal capital, process review - performed on an annual basis, or more often in justified cases. Article 438(c) CRR The Bank did not have any additional regulatory requirements with regard to own funds and their structure based on the supervisory review process referred to in Art. 104 sec. 1 lit. a) Directive 2013/36/EU. ‌EU LI1 - Differences between the accounting scope and the scope of prudential consolidation and mapping of financial statement categories with regulatory risk categories PLN m Carrying values as reported in published financial statements Carrying values under scope of prudential consolidation Carrying values of items Subject to the credit risk framework Subject to the CCR framework Subject to the securitisation framework Subject to the market risk framework Not subject to own funds requirements or subject to deduction from own funds a b c d e f g 0010 0020 0030 0040 0050 0060 0070 Breakdown by asset clases according to the balance sheet in the published financial 1 Cash and cash equivalents 4 063 4 058 4 058 2 Amounts due from banks 2 203 2 203 877 1 326 3 Debt securities and derivatives 26 510 26 492 26 244 248 189 measured at fair value through other comprehensive income 22 543 22 540 22 540 measured at fair value through profit or loss 371 356 108 248 189 measured at amortized cost 3 596 3 596 3 596 4 Derivative hedging instruments 660 660 660 5 Loans and advances to customers 65 451 65 451 65 036 415 6 Property. plant and equipment 829 829 829 7 Intangible assets 551 551 101 450 8 Investments in associates 0 75 75 9 Income tax asset 724 723 685 38 10 Other assets 784 780 780 Total assets 101 775 101 822 98 685 2 649 189 488 Carrying values as reported in published financial statements Carrying values under scope of prudential consolidation Carrying values of items Subject to the credit risk framework Subject to the CCR framework Subject to the securitisation framework Subject to the market risk framework Not subject to own funds requirements or subject to deduction from own funds a b c d e f g 0010 0020 0030 0040 0050 0060 0070 Breakdown by liability classes according to the balance sheet in the published 1 Amounts due to banks 589 589 2 Amounts due to customers 82 621 82 679 3 Financial liabilities 327 327 268 167 4 Derivative hedging instruments 69 69 69 5 Fair value changes of the hedged items in portfolio hedge of interest rate risk 202 202 6 Provisions 404 404 7 Other liabilities 2 040 2 033 8 Income tax liabilities 218 217 9 Debt securities issued 2 322 2 322 Total liabilities 88 792 88 842 337 167 ‌EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statements PLN m Total Items subject to Credit risk framework Securitisation framework CCR framework Market risk framework a b c d e 0010 0020 0030 0040 0050 1 Assets carrying value amount under the scope of prudential consolidation (as per template LI1) 0010 101 822 98 865 2 649 189 2 Liabilities carrying value amount under the scope of prudential consolidation (as per template LI1) 0020 88 842 337 167 3 Total net amount under the scope of prudential consolidation 0030 12 980 98 685 2 312 22 4 Off-balance-sheet amounts 0040 17 123 17 123 5 Differences in valuations 0050 6 Differences due to different netting rules, other than those already included in row 2 0060 7 Differences due to consideration of provisions 0070 -102 -102 8 Differences due to the use of credit risk mitigation techniques (CRMs) 0080 -169 -169 9 Differences due to credit conversion factors 0090 8 904 8 904 10 Differences due to Securitisation with risk transfer 0100 11 Other differences 0110 916 958 -42 12 Exposure amounts considered for regulatory purposes 0120 109 861 107 591 2 270 25 ‌ EU LI3 - Outline of the differences in the scopes of consolidation (entity by entity) Name of the entity Method of prudential consolidation Method of accounting consolidation Description of the entity Full consolidation Proportional consolidation Equity method Neither consolidated nor deducted Deducted a b c d e f g 0009 0010 0020 0030 0040 0050 0060 0070 1 Alior Services Sp. z o.o. Full consolidation x The company operates as an insurance agent for 7 insurance companies (contract administration). 2 Alior Leasing Sp. z o.o. Full consolidation x The company provides fixed asset financing through operational and financial leasing, as well as lease loans. The company has its own sales network of Leasing Advisors responsible for servicing Alior Bank clients and collaborating with external partners - vehicle, machinery, and equipment dealers. The company's strategic goal is to expand its cooperation with Alior Bank in the corporate client segment, continue its dynamic growth among SME and sole proprietorship clients, and increase its presence among machinery and equipment dealers by tailoring its offerings to the needs of clients in the industrial and medical sectors. The Alior Leasing Capital Group also includes: AL Finance sp.z o.o., which specializes in property and motor insurance for clients with lease or lease loan agreements Alior Leasing Individual sp. z o.o., which was established to implement Alior Leasing's strategy for consumer-facing products. Currently, it provides consumer leasing/car rental services on a subscription basis through the internal channels of PZU Group companies and is dedicated to Group employees. Ultimately, the scope of its operations will also include the rental of consumer electronics and household appliances, including consumer electronics, IT equipment, household appliances, and smartphones. Upon broad market entry, distribution will take place through Alior Bank's Trading Partners. This activity will be carried out in close cooperation with Alior Leasing and Alior Bank and will expand the Group's product portfolio. 3 Meritum Services ICB SA Full consolidation x The company conducts service activities in the field of information and computer technologies and provides IT software services. 4 Alior TFI SA Full consolidation x The company's core business is asset management. The bank's collaboration with its subsidiary, Alior TFI, primarily involves the distribution of ALIOR SFIO units. The company continues to hold a license to manage portfolios comprising one or more financial instruments. Name of the entity Method of prudential consolidation Method of accounting consolidation Description of the entity Full consolidation Proportional consolidation Equity method Neither consolidated nor deducted Deducted a b c d e f g 0009 0010 0020 0030 0040 0050 0060 0070 5 Corsham Sp. z o.o. Full consolidation x A company dedicated to implementing venture capital investments. Pursuant to Resolution No. 434/2023 of the Bank's Management Board dated 13 December 2023, the Bank's Management Board decided to discontinue further investment activities. 6 RBL_VC Sp. z o.o. Full consolidation x A company dedicated to managing companies making venture capital investments has been entered into the register of Alternative Investment Company Managers (ZASI). 7 RBL_VC Sp. z o.o. ASI spółka komandytowo-akcyjna Full consolidation x It is an investment vehicle used by Alior Bank SA to make venture capital investments. Pursuant to Resolution No. 434/2023 of the Bank's Management Board dated 13 December 2023, the Bank's Management Board decided to discontinue further investment activities. By Resolution No. 469/2025 of 16 December 2025, the Bank's Management Board granted directional consent to the liquidation of the company as part of the simplification of the structure of the Bank's Capital Group. Detailed information on the structure of the Alior Bank SA Capital Group is included in the Consolidated Financial Statements of the Alior Bank Group for the year ended 31 December 2025. EU LIA - Explanations of differences between accounting and regulatory exposure amounts ‌Legal basis Row number Annex No. 1 to Resolution No. 53/2026 of the Management Board of Alior Bank SA Details Article 436(b) CRR The scope of companies subject to prudential consolidation differs from the scope of companies subject to financial consolidation carried out in accordance with the International Financial Reporting Standards. In 2025, Alior Bank SA and Alior Leasing sp. z o.o. were covered by prudential consolidation. In the opinion of the Bank's Management Board, other subsidiaries were not subject to prudential consolidation due to their insignificant scale of operations in the Bank's Capital Group. The differences between the accounting and prudential scope of consolidation result from the financial data of other companies not included in the prudential consolidation, and from accounting consolidation exclusions. Article 436(d) CRR The main difference between the accounting and prudential scope of consolidation is "Investments in associates", the Bank's shares in subsidiaries not prudentially consolidated. ‌EU LIB - Other qualitative information on the scope of application Legal basis Row number Details Article 436(f) CRR a) In the case of other entities belonging to the Alior Bank SA Capital Group, the Bank does not identify any significant obstacles to the transfer of funds for recapitalization of entities and the repayment of their liabilities. Article 436(g) CRR b) The Bank does not have subsidiaries not covered by consolidation, whose own funds are lower than required. Article 436(h) CRR c) The Bank does not apply the derogations referred to in Art. 7 of CRR, or the individual consolidation method specified in Art. 9 of CRR. Article 436(g) CRR d) Due to the above, this disclosure does not apply to the Alior Bank Group. ‌ EU PV1 - Prudent valuation adjustments (PVA) PLN m Risk category Category level AVA -Valuation uncertainty Total category level post-diversification Equity Interest Rates Foreign exchange Credit Commodities Unearned credit spreads AVA Investment and funding costs AVA Of which: Total core approach in the trading book Of which: Total core approach in the banking book a b c d e EU e1 EU e2 f g h Category level AVA 0009 0010 0020 0030 0040 0050 0060 0070 0080 0090 0100 1 Market price uncertainty 0010 2 Not applicable 0020 3 Close-out cost 0030 4 Concentrated positions 0040 5 Early termination 0050 6 Model risk 0060 7 Operational risk 0070 8 Not applicable 0080 9 Not applicable 0090 10 Future administrative costs 0100 11 Not applicable 0110 12 Total Additional Valuation Adjustments 0120 24 To calculate a prudent valuation adjustment (AVA), the bank uses the simplified method, in accordance with Art. 4, Commission Delegated Regulation (EU) 2016/101 of 26 October 2015 supplementing Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to prudent regulatory technical standards in accordance with Art. 105 paragraph. 14, the sum of the absolute value of assets and liabilities measured at fair value as reported in the institution's financial statements in accordance with the applicable accounting framework is less than EUR 15 billion. ‌ EU CC1 - Composition of regulatory own funds PLN m Amounts Source based on reference numbers/letters of the balance sheet under the regulatory scope of consolidation a b 0010 0020 Common Equity Tier 1 (CET1) capital: instruments and reserves 0009 1 Capital instruments and the related share premium accounts 0010 5 182 EU CC2 pos. P10 +P11.1 Series A Series B Series C Series D,E, F Series G Series H Series I, J 2 Retained earnings 0050 78 EU CC2 pos. P14.1 3 Accumulated other comprehensive income (and other reserves) 0060 5 354 EU CC2 pos. P11+P.12+P13 EU-3a Funds for general banking risk 0070 4 Amount of qualifying items referred to in Article 484 (3) CRR and the related share premium accounts subject to phase out from CET1 0080 5 Minority interests (amount allowed in consolidated CET1) 0090 EU-5a Independently reviewed interim profits net of any foreseeable charge or dividend 0100 558 EU CC2 pos. P14.3 6 Common Equity Tier 1 (CET1) capital before regulatory adjustments 0110 11 173 Common Equity Tier 1 (CET1) capital: regulatory adjustments 0119 7 Additional value adjustments (negative amount) 0120 -24 8 Intangible assets (net of related tax liability) (negative amount) 0130 -450 EU CC2 pos. A7 10 Deferred tax assets that rely on future profitability excluding those arising from temporary differences (net of related tax liability where the conditions in Article 38 (3) CRR are met) (negative amount) 0140 11 Fair value reserves related to gains or losses on cash flow hedges of financial instruments that are not valued at fair value 0150 -126 12 Negative amounts resulting from the calculation of expected loss amounts 0160 13 Any increase in equity that results from securitised assets (negative amount) 0170 14 Gains or losses on liabilities valued at fair value resulting from changes in own credit standing 0180 15 Defined-benefit pension fund assets (negative amount) 0190 16 Direct, indirect and synthetic holdings by an institution of own CET1 instruments (negative amount) 0200 17 Direct, indirect and synthetic holdings of the CET 1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution (negative amount) 0210 18 Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution does not have a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount) 0220 PLN m Amounts Source based on reference numbers/letters of the balance sheet under the regulatory scope of consolidation a b 0010 0020 19 Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount) 0230 EU-20a Exposure amount of the following items which qualify for a RW of 1250%, where the institution opts for the deduction alternative 0240 EU-20b of which: qualifying holdings outside the financial sector (negative amount) 0250 EU-20c of which: securitisation positions (negative amount) 0260 EU-20d of which: free deliveries (negative amount) 0270 21 Deferred tax assets arising from temporary differences (amount above 10% threshold, net of related tax liability where the conditions in Article 38 (3) CRR are met) (negative amount) 0280 22 Amount exceeding the 17,65% threshold (negative amount) 0290 23 of which: direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities 0300 25 of which: deferred tax assets arising from temporary differences 0310 EU-25a Losses for the current financial year (negative amount) 0320 EU-25b Foreseeable tax charges relating to CET1 items except where the institution suitably adjusts the amount of CET1 items insofar as such tax charges reduce the amount up to which those items may be used to cover risks or losses (negative amount) 0330 27 Qualifying AT1 deductions that exceed the AT1 items of the institution (negative amount) 0340 27a Other regulatory adjustments 0350 -57 28 Total regulatory adjustments to Common Equity Tier 1 (CET1) 0360 -657 29 Common Equity Tier 1 (CET1) capital 0370 10 515 Kapitał dodatkowy Tier I: instrumenty 0379 30 Capital instruments and the related share premium accounts 0380 31 of which: classified as equity under applicable accounting standards 0390 32 of which: classified as liabilities under applicable accounting standards 0400 33 Amount of qualifying items referred to in Article 484 (4) CRR and the related share premium accounts subject to phase out from AT1 0410 EU-33a Amount of qualifying items referred to in Article 494a(1) CRR subject to phase out from AT1 0420 EU-33b Amount of qualifying items referred to in Article 494b(1) CRR subject to phase out from AT1 0430 34 Qualifying Tier 1 capital included in consolidated AT1 capital (including minority interests not included in row 5) issued by subsidiaries and held by third parties 0440 35 of which: instruments issued by subsidiaries subject to phase out 0450 36 Additional Tier 1 (AT1) capital before regulatory adjustments 0460 Additional Tier 1 (AT1) capital: regulatory adjustments 0469 37 Direct, indirect and synthetic holdings by an institution of own AT1 instruments (negative amount) 0470 38 Direct, indirect and synthetic holdings of the AT1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution (negative amount) 0480

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