Alior Bank S A: Financial document (Capital Adequacy and Other Information Subject to Disclosure of the Alior Bank S.A. Capital Group 30.06.2025)

Capital Adequacy and Other Information Subject to Disclosure

of the Alior Bank Spółka Akcyjna Capital Group

as at 30 June 2025

Disclosure Pillar III

List of Tables for the period 2025/06

No.

Table

1.

EU KM1 - Key metrics template

2.

EU KM2 - Key metrics - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities

3.

EU TLAC1 - Composition - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities

4.

EU TLAC3b - Creditor ranking - Resolution entity

5.

EU REM1 - Remuneration awarded for the financial year

6.

EU REM2 - Special payments to staff whose professional activities have a material impact on institutions' risk profile (identified staff)

7.

EU REM5 - Information on remuneration of staff whose professional activities have a material impact on institutions' risk profile (identified staff)

8.

Guidelines EBA/GL/2022/06 and EBA/GL/2021/04

9.

Management Board's statement

Alior Bank SA is obliged, pursuant to 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, amending Regulation (EU) No. 648/2012, as amended (hereinafter referred to as the "CRR Regulation") and the Banking Law Act of August 29, 1997, as amended (hereinafter referred to as the "Banking Law Act"), publish in a generally accessible manner interim information of a quantitative and qualitative nature in the field of Pillar III of excluding non-essential, proprietary or confidential information.

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 disclosures by institutions of the information referred to in Part Eight, Titles II and III, 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 policies.

The disclosure of information regarding the minimum requirement for own funds and eligible liabilities - MREL - is in accordance with Commission Implementing Regulation (EU) 2024/1618 of 6 June 2024 amending Implementing Regulation (EU) 2021/763 laying down implementing technical standards for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council and Directive 2014/59/EU of the European Parliament and of the Council with regard to the supervisory reporting and public disclosure of the minimum requirement for own funds and eligible liabilities .

Data regarding the remuneration policy have been supplemented or updated in relation to the report: "Capital Adequacy and Other Information Subject to Disclosure of the Alior Bank Spółka Akcyjna Group for the year ended December 31, 2024", with the value of variable remuneration that was awarded and accepted in accordance with Remuneration Policy after the date of publication of the annual report.

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 semi-annual scope of information is consistent with the requirements of Articles 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 June 30, 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 in this document was disclosed on the basis of data from the interim condensed consolidated financial statements of the Alior Bank SA Capital Group for the 6-month period ended June 30, 2024. Alior Bank SA has the dominant influence on the shape of the risk profile in the Bank's Capital Group, therefore some of the information contained in the report concerns individual data of Alior Bank SA.

Figures are drawn up in Polish zlotys (PLN) and are rounded up to one million zlotys (M), with accuracy to one decimal place.

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 KM1 - Key metrics template

PLN m

a

c

e

30.06.2025

31.12.2024*

30.06.2024

Available own funds (amounts)

1

Common Equity Tier 1 (CET1) capital

9 930,0

9 741,9

8 591,4

2

Tier 1 capital

9 930,0

9 741,9

8 591,4

3

Total capital

9 930,0

9 741,9

8 797,7

Risk-weighted exposure amounts

4

Total risk exposure amount

58 504,4

51 211,5

50 196,3

4a

Total risk exposure pre-floor

58 504,4

Capital ratios (as a percentage of risk-weighted exposure amount)

5

Common Equity Tier 1 ratio (%)

16.97%

19.02%

17.12%

5a

Not applicable

5b

Common Equity Tier 1 ratio considering unfloored TREA (%)

16.97%

6

Tier 1 ratio (%)

16.97%

19.02%

17.12%

6a

Not applicable

6b

Tier 1 ratio considering unfloored TREA (%)

16.97%

7

Total capital ratio (%)

16.97%

19.02%

17.53%

7a

Not applicable

7b

Total capital ratio considering unfloored TREA (%)

16.97%

Additional own funds requirements to address risks other than the risk of excessive leverage (as a percentage of risk-weighted exposure amount)

EU-7d

Additional own funds requirements to address risks other than the risk of excessive leverage (%)

n/a

n/a

n/a

EU-7e

of which: to be made up of CET1 capital (percentage points)

n/a

n/a

n/a

EU-7f

of which: to be made up of Tier 1 capital (percentage points)

n/a

n/a

n/a

EU-7g

Total SREP own funds requirements (%)

8.00%

8.00%

8.00%

Combined buffer and overall capital requirement (as a percentage of risk-weighted exposure amount)

8

Capital conservation buffer (%)

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 (%)

n/a

n/a

n/a

9

Institution specific countercyclical capital buffer (%)

0.0144%

0.0137%

0.0174%

EU 9a

Systemic risk buffer (%)

0.00%

0.00%

0.00%

10

Global Systemically Important Institution buffer (%)

n/a

n/a

n/a

EU 10a

Other Systemically Important Institution buffer (%)

n/a

n/a

n/a

11

Combined buffer requirement (%)

2.51%

2.51%

2.52%

EU 11a

Overall capital requirements (%)

10.51%

10.51%

10.52%

12

CET1 available after meeting the total SREP own funds requirements (%)

8.97%

11.02%

9.53%

Leverage ratio

13

Total exposure measure

109 464,0

99 219,5

94 339,1

14

Leverage ratio (%)

9.07%

9.82%

9.11%

Additional own funds requirements to address the risk of excessive leverage (as a percentage of total exposure measure)

EU 14a

Additional own funds requirements to address the risk of excessive leverage (%)

n/a

n/a

n/a

EU 14b

of which: to be made up of CET1 capital (percentage points)

n/a

n/a

n/a

EU 14c

Total SREP leverage ratio requirements (%)

3.00%

3.00%

3.00%

Leverage ratio buffer and overall leverage ratio requirement (as a percentage of total exposure measure)

EU KM1 - Key metrics template

PLN m

a

c

e

30.06.2025

31.12.2024*

30.06.2024

EU 14d

Leverage ratio buffer requirement (%)

n/a

n/a

n/a

EU 14e

Overall leverage ratio requirement (%)

3.00%

3.00%

3.00%

Liquidity Coverage Ratio

15

Total high-quality liquid assets (HQLA) (Weighted value -average)

24 132,6

22 632,0

21 227,8

EU 16a

Cash outflows - Total weighted value

13 684,1

14 191,0

14 014,0

EU 16b

Cash inflows - Total weighted value

2 080,7

2 081,1

2 206,0

16

Total net cash outflows (adjusted value)

11 603,4

12 109,9

11 808,0

17

Liquidity coverage ratio (%)

209%

187%

180%

Net Stable Funding Ratio

18

Total available stable funding

78 383,5

76 179,3

72 995,5

19

Total required stable funding

53 586,5

51 518,9

50 830,8

20

NSFR ratio (%)

146%

148%

144%

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

b

c

d

e

f

30.06.2025

30.06.2025

31.03.2025

31.12.2024

30.09.2024

30.06.2024

Own funds and eligible liabilities, ratios and components

1

Own funds and eligible liabilities

11 741,3

n/a

n/a

n/a

n/a

n/a

EU-1a

Of which own funds and subordinated liabilities

11 188,9

x

x

x

x

x

2

Total risk exposure amount of the resolution group (TREA)

58 504,4

n/a

n/a

n/a

n/a

n/a

3

Own funds and eligible liabilities as a percentage of TREA (row1/row2)

20.07%

n/a

n/a

n/a

n/a

n/a

EU-3a

Of which own funds and subordinated liabilities

19.12%

x

x

x

x

x

4

Total exposure measure of the resolution group

109 464,0

n/a

n/a

n/a

n/a

n/a

5

Own funds and eligible liabilities as percentage of the total exposure measure

10.73%

n/a

n/a

n/a

n/a

n/a

EU-5a

Of which own funds or subordinated liabilities

10.22%

x

x

x

x

x

6a

Does the subordination exemption in Article 72b(4) of the CRR apply? (5% exemption)

x

n/a

n/a

n/a

n/a

n/a

6b

Pro-memo item - Aggregate amount of permitted non-subordinated eligible liabilities in-struments If the subordination discretion as per Article 72b(3)

CRR is applied (max 3.5% exemption)

x

n/a

n/a

n/a

n/a

n/a

6c

Pro-memo item: If a capped subordination exemption applies under Article 72b (3) CRR, 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 (%)

x

n/a

n/a

n/a

n/a

n/a

Minimum requirement for own funds and eligible liabilities (MREL)

EU-7

MREL requirement expressed as percentage of the total risk exposure amount

15.36%

x

x

x

x

x

EU-8

Of which to be met with own funds or subordinated liabilities

15.36%

x

x

x

x

x

EU-9

MREL requirement expressed as percentage of the total exposure measure

5.91%

x

x

x

x

x

EU-10

Of which to be met with own funds or subordinated liabilities

5.91%

x

x

x

x

x

1 Common Equity Tier 1 capital (CET1)

9 930,0

n/a

n/a

2 Additional Tier 1 capital (AT1)

-

n/a

n/a

3 Empty set in the EU

4 Empty set in the EU

5 Empty set in the EU

6

Tier 2 capital (T2)

-

n/a

n/a

7

Empty set in the EU

8

Empty set in the EU

11

Own funds for the purpose of Articles 92a CRR and 45 BRRD

9 930,0

n/a

n/a

Own funds and eligible liabilities: Non-regulatory capital elements

12

Eligible liabilities instruments issued directly by the resolution entity that are subordinated to excluded liabilities (not grandfathered)

1 259,0

n/a

n/a

EU 12a

Eligible liabilities instruments issued by other entities within the resolution group that are subordinated to excluded liabilities (not grandfathered)

-

n/a

n/a

EU12b

Eligible liabilities instruments that are subordinated to excluded liabilities, issued prior to 27 June 2019 (subordinated grandfathered)

-

n/a

n/a

EU12c

Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items

-

n/a

n/a

13

Eligible liabilities that are not subordinated to excluded liabilities (not grandfathered pre cap)

552,3

n/a

n/a

EU-13a

Eligible liabilities that are not subordinated to excluded liabilities issued prior to 27 June 2019 (pre-cap)

-

n/a

n/a

14

Amount of non subordinated instruments eligible, where applicable after application of Article 72b (3) CRR

552,3

n/a

n/a

15

Empty set in the EU

16

Empty set in the EU

17

Eligible liabilities items before adjustments

1 811,3

n/a

n/a

EU-17a

Of which subordinated

1 259,0

n/a

n/a

19

(Deduction of exposures between MPE resolution groups)

x

n/a

x

20

(Deduction of investments in other eligible liabilities instruments)

x

n/a

x

21

Empty set in the EU

22 Own funds and eligible liabilities after adjustments

11 741,3

n/a

n/a

EU-22a Of which own funds and subordinated

11 188,9

x

x

Risk-weighted exposure amount and leverage exposure measure of the resolution group

23 Total risk exposure amount (TREA)

58 504,4

n/a

n/a

24 Total exposure measure (TEM)

109 464,0

n/a

n/a

Ratio of own funds and eligible liabilities

25 Own funds and eligible liabilities (as a percentage of total risk exposure amount)

20.07%

n/a

n/a

EU-25a Of which own funds and subordinated

19.12%

x

x

26 Own funds and eligible liabilities (as a percentage of total exposure measure)

10.73%

n/a

n/a

EU-26a

Of which own funds and subordinated

10.22%

x

x

27

CET1 (as a percentage of TREA) available after meeting the resolution group's requirements

9.96%

n/a

x

28

Institution-specific combined buffer requirement

x

n/a

x

29

of which: capital conservation buffer requirement

x

n/a

x

30

of which: countercyclical buffer requirement

x

n/a

x

31

of which: systemic risk buffer requirement

x

n/a

x

EU-31a

of which: Global Systemically Important Institution (G-SII) or Other Systemically Important Institution (O-SII) buffer

x

n/a

x

EU-32 Total amount of excluded liabilities referred to in Article 72a(2) CRR

x

n/a

x

EU TLAC3b - Creditor ranking - Resolution entity

PLN m

Insolvency ranking

30.06.2025

1

2

3

4

5

(most junior)

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

2

Empty set in the EU

3

Empty set in the EU

4

Empty set in the EU

5

Own funds and liabilities potentially eligible for meeting MREL

9 930,0

-

-

-

1 259,0

6

of which residual maturity ≥ 1 year < 2 years

-

-

-

-

451,6

7

of which residual maturity ≥ 2 year < 5 years

-

-

-

-

807,4

8

of which residual maturity ≥ 5 years < 10 years

-

-

-

-

-

9

of which residual maturity ≥ 10 years, but excluding perpetual securities

-

-

-

-

-

10

of which perpetual securities

9 930,0

-

-

-

-

EU TLAC3b - Creditor ranking - Resolution ent

PLN m

Insolvency ranking

30.06.2025

6

7

8

9

10

Sum of 1 to 10

(most senior)

1

Description of insolvency rank (free text)

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

Own funds and liabilities potentially eligible for meeting MREL

-

2,3

584,9

5,8

-

11 782,0

6

of which residual maturity ≥ 1 year < 2 years

-

-

34,9

5,4

-

491,9

7

of which residual maturity ≥ 2 year < 5 years

-

2,3

550,0

0,4

-

1 360,1

8

of which residual maturity ≥ 5 years < 10 years

-

-

-

-

-

-

9

of which residual maturity ≥ 10 years, but excluding perpetual securities

-

-

-

-

-

-

10

of which perpetual securities

-

-

-

-

-

9 930,0

EU REM1 - Remuneration awarded for the financial year

PLN m

a

b

c

d

MB Supervisory function

MB Management function

Other senior management

Other identified staff

1

Number of identified staff

7

6

35

18

2

Total fixed remuneration

0,8

7,7

19,9

5,4

3

Of which: cash-based

0,8

7,5

19,4

5,2

4

(Not applicable in the EU)

x

x

x

x

EU-4a

Of which: shares or equivalent ownership interests

-

-

-

-

5 Fixed remuneration

Of which: share-linked instruments or equivalent non-cash

instruments

-

-

-

-

EU-5x

Of which: other instruments

-

-

-

-

6

(Not applicable in the EU)

x

x

x

x

7

Of which: other forms

-

0,1

0,5

0,1

8

(Not applicable in the EU)

x

x

x

x

9

Number of identified staff

10

Total variable remuneration *

1,8

4,7

1,2

11

Of which: cash-based

-

0,9

2,3

1,2

12

Of which: deferred

-

0,4

0,9

-

EU-13a

Of which: shares or equivalent ownership interests

-

-

-

-

EU-14a

Of which: deferred

-

-

-

-

remuneration

EU-14b

Of which: deferred

- 0,4

0,9

-

EU-14x

Of which: other instruments

- -

-

-

EU-14y

Of which: deferred

- -

-

-

15

Of which: other forms

- -

-

-

16

Of which: deferred

-

-

-

-

17 Total remuneration (2 + 10)

0,8

9,4

24,6

6,6

EU REM2 - Special payments to staff whose professional activities have a material impact on institutions' risk profile (identified staff)

PLN m

a

b

c

d

MB Supervisory function

MB Management function

Other senior management

Other identified staff

Guaranteed variable remuneration awards

-

-

-

-

1

Guaranteed variable remuneration awards - Number of identified staff

-

-

-

-

2

Guaranteed variable remuneration awards -Total amount

-

-

-

-

3

Of which guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap

-

-

-

-

Severance payments awarded in previous periods, that have been paid out during the financial year

-

-

-

-

4

Severance payments awarded in previous periods, that have been paid out during the financial year - Number of identified staff

-

-

1,0

-

5

Severance payments awarded in previous periods, that have been paid out during the financial year - Total amount

-

-

-

-

Severance payments awarded during the financial year

6

Severance payments awarded during the financial year - Number of identified staff

-

8,0

5,0

5,0

7

Severance payments awarded during the financial year - Total amount

-

8,1

1,1

1,0

8

Of which paid during the financial year

-

7,1

1,1

1,0

9

Of which deferred *

-

1,0

-

-

10

Of which severance payments paid during the financial year, that are not taken into account in the bonus cap

-

-

-

-

11

Of which highest payment that has been awarded to a single person

-

0,3

0,3

-

EU REM5 - Information on remuneration of staff whose professional activities have a material impact on institutions' risk profile (identified staff)

PLN m

a

b

c

d

e

f

g

h

i

j

Management body remuneration

Business areas

MB Supervisory function

MB Management function

Total MB

Investment banking

Retail banking

Asset management

Corporate functions

Independent internal control functions

All other

Total

1

Total number of identified staff

x

x

x

x

x

x

x

x

x

66

2

Of which: members of the MB

7

6

13

x

x

x

x

x

x

x

3

Of which: other senior management

x

x

x

4

6

1

7

17

-

x

4

Of which: other identified staff

x

x

x

2

4

0

1

11

-

x

5

Total remuneration of identified staff

0,8

9,4

10,3

3,7

5,8

0,8

6,4

14,5

-

x

6

Of which: variable remuneration

1,8

2,7

0,8

1,0

0,2

1,3

2,6

x

7

Of which: fixed remuneration

0,8

7,7

7,7

2,9

4,8

0,7

5,1

11,9

-

x

The table presents the remuneration of persons employed as of December 31, 2024. The management function of the management body includes data regarding the Member of the Supervisory Board delegated to perform the duties of Vice President of the Management Board of the Bank.

This report has been supplemented, compared to the report as of December 31, 2024, with the value of variable remuneration for 2024, which was awarded and accepted in accordance with the Remuneration Policy after the date of publication of the annual report.

On June 18, 2025, the Supervisory Board decided to grant variable bonuses for 2023. The Capital Adequacy Report and Other Disclosures of the Alior Bank Spółka Akcyjna Capital Group for the year ended December 31, 2023 was updated with respect to:

EU REM 5: for the item "MB Management function" respectively: "Total remuneration of identified staff": PLN 17.6 million;

"Of which: variable remuneration ": PLN 7.5 million.

* Investment and corporate banking

Representation of male and female

staff in each quartile of remuneration level

All male staff in percent of all staff

All male staff in percent of all staff

All male identified staff in percent based on all identified staff

All female identified staff in percent based on all identified staff

Quartile 1 (low)

27.48%

72.52%

x

x

Quartile 2 (low to medium)

28.41%

71.59%

x

x

Quartile 3 (medium to high)

39.87%

60.13%

x

x

Quartile 4 (high)

61.06%

38.94%

x

x

Total staff/identified staff

39.21%

60.79%

72.88%

27.12%

Table 2: Gender pay pap based on the total gross remuneration

(calculated according to the formula: Gender pay gap in percentage = (average salary of men - average salary of women)*100/average salary of men)

Total gross annual remuneration level

Gender pay gap of all staff, based on median

Gender pay gap of all staff, based on mean

Gender pay gap of identified staff, based on median

Gender pay gap of identified staff, based on mean

Quartile 1 (low)

-0.25%

-0.33%

x

x

Quartile 2 (low to medium)

1.50%

0.93%

x

x

Quartile 3 (medium to high)

1.11%

1.20%

x

x

Quartile 4 (high)

5.56%

9.80%

x

x

Total staff/identified staff

26.43%

26.39%

19.53%

33.34%