Raport

NON-FINANCIAL
STATEMENT
of XTB S.A. Capital Group
for 2021
Warsaw, 8 March 2022
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Table of Contents
1 Publication Basis 2
2 Organisation of XTB Capital Group 2
2.1 Business Proﬁle 2
2.2 Management of Non-Financial Assets in XTB Group 3
3 ESG Strategy 6
4 Description of the Capital Group's Business 8
4.1 Description of Basic Products and Services 8
4.2 Suppliers 9
4.3 Customers 10
4.4 Cooperation with Contractors 12
4.5 Commercial Contracts and Transactions 12
4.6 Public Aid 12
4.7 Technology Development 12
5 Employment 14
5.1 XTB's HR Policy 14
5.2 Ensuring Diversity 15
5.3 Employment Structure 17
5.4 Employment Conditions 22
5.5 Employees' Development 26
6 Occupational Health and Safety 30
7 Environmental Aspects 31
8 Impact of COVID-19 Pandemic on Non-Financial Issues 36
9 EU Non-Financial Taxonomy 36
10 Business Ethics 39
11 Data Protection 41
12 Compliance 41
13 Risk Regarding Non-Financial Issues 42
14 XTB Foundation 44
Signatures of Managers 46
1
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
1 Publication Basis
This Non-Financial Statement of XTB S.A. Capital Group (XTB Capital Group, Group, XTB Group) has
been prepared under Article 55 point 2b in conjunction with Article 49b of the Accounting Act.
This Statement covers information regarding XTB Capital Group companies for 2021. Preparation of this
XTB Statement has been based on the Non-Financial Reporting Standard (NFRS) issued by the
Reporting Standards Foundation. This Non-Financial Statement complies, in principle, with NFRS,
subject to incompatibility of sectors provided for in NFRS with the business conducted by XTB Capital
Group as well as substantially limited operating activities of subsidiaries functioning within XTB Group,
making assignment of certain NFRS indices to the business of a speciﬁc subsidiary inexpedient.
2 Organisation of XTB Capital Group
2.1 Business Proﬁle
XTB S.A. (XTB, Company) is one of the largest Forex and CFD brokers in the world, listed on the stock
exchange and specialising in trade in ﬁnancial instruments, present on markets in Europe, Asia, Latin
America and other.
Since 2016, XTB has been listed on the Warsaw Stock Exchange. XTB Capital Group comprises foreign
branches and subsidiaries, according to the structure presented further in the Statement.
XTB Group supplies products, services and technological solutions in the scope of trade in ﬁnancial
instruments. XTB specialises in OTC market and, in particular, CFD derivatives that are investment
products and the return on which depends on ﬂuctuations of prices and values of instruments and
underlying assets.
XTB Group operates in two segments: retail activity and institutional activity. The retail activity of XTB
Group includes mainly online trade in derivatives based on underlying assets and instruments traded on
ﬁnancial and commodity markets, serving mostly retail customers. As regards institutional customers,
XTB Group offers technologies allowing such customers to offer trading in ﬁnancial instruments under
their own brand to their own customers. XTB Group is also a liquidity provider for institutional
customers.
XTB Group offers their customers various transaction execution options, depending on the
advancement level of the given customer (from a beginner to an expert) and access method
(smartphone, web interfaces, PC applications).
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NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
The functionality of XTB Group's offer allows the customers to open accounts, deposit funds in them,
place orders and transfer funds between the accounts as well as ordering statements via the Internet.
The basic technology of XTB Group uses software designed to ensure functionality and scalability.
2.2 Management of Non-Financial Assets in XTB Group
As at 31 December 2021, XTB Group comprises XTB, as the Parent Entity, and 10 subsidiaries. XTB also
has 7 foreign branches. The diagram below presents the Group structure as at 31 December 2021.
For detailed information regarding individual subsidiaries and branches, see Management Board's Report
on the Operations for the Year Ended on 31 December 2021, Section: Description of Group's Organisation.
There were no major changes in the business model of XTB Group in the ﬁnancial year.
The key processes of the operating activities are those connected with supply of proprietary technology
to the users (responsibility for this area lies with XTB's IT Department) and those related with customer
acquisition and support. The processes related to customer acquisition and support are conducted both
directly by XTB in Poland as well as through branches and subsidiaries operating on the local markets.
3
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
XTB is also responsible for coordination of activity of individual subsidiaries and branches, management
processes, setting of development targets for the businesses functioning in particular countries, setting
budgets and ﬁnancial targets, procedural standards, supervising accomplishment of the above.
Subsidiaries and branches employ from several to several dozen persons. Thus, the majority of
operating processes is carried out by XTB in Poland and the activity of subsidiaries and foreign
branches, in principle, supports the sale and ensures compliance with local regulations required for the
conducted business. In consequence, also in terms of ESG-related issues, the most important
processes and solutions regarding management of non-ﬁnancial issues are executed by XTB in Poland,
and creation of developed corporate solutions and dedicated policies for speciﬁc subsidiaries must be
considered ineffective.
Bearing the above in mind, identiﬁcation of essential management areas and related risk, also in relation
to non-ﬁnancial aspects, is carried out at the level of XTB in agreement with individual organisational
units functioning in the subsidiaries.
This process is related to the continuous assessment of impact on the surrounding and the risk
connected with individual areas of interaction with stakeholders. Furthermore, the assessment takes
into consideration on-going changes (including but not limited to legal, economic and social changes) in
the surrounding. These aspects are identiﬁed and assessed in detail in accordance with the relevant
procedures regarding identiﬁcation of threats and assessment of risk for the given area.
The companies belonging to XTB Group take individual actions to meet the requirements of local
regulations.
On the other hand, XTB is the addressee of information regarding effects of activities in speciﬁc ESG
areas, including but not limited to situations where these effects could result in breach of effective laws
and related ﬁnancial liability or image-related repercussions. Therefore, according to the best knowledge,
this Non-Financial Statement does not omit any information that could have a signiﬁcant impact on the
reliability of description of the impact of XTB Group on social issues, employment-related issues, natural
environment, respect for human right, counteracting corruption or climate-related issues.
The following areas where relations of high signiﬁcance exist are identiﬁed in the business activities and
management processes.
Area of relations
Examples of impact
Customer relations
● supply of reliable software
● marketing communication
● educational and training activities
Relations with employees
● ensuring good work conditions
● development of employees' competences
● educational activities
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NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Relations with regulators
● ensuring compliance of conducted business with local regulations
● preventing breaches of effective regulations
● prevention of unethical conduct
Occupational health and safety
● ensuring a safe work environment
Impact on the environment
● energy consumption
● environmental education
Identiﬁcation of stakeholders
Considering the nature of the business activity conducted by XTB Group, the following key groups of
stakeholders are identiﬁed for the purpose of management processes:
● employees,
● retail and institutional customers,
● prospective customers - persons interested in education regarding ﬁnancial markets,
● suppliers,
● competitors,
● state institutions, including local supervisory authorities,
● media,
● shareholders, analysts and prospective investors.
The needs and expectations of stakeholders are regularly identiﬁed, including identiﬁcation of legal
requirements and feedback obtained from speciﬁc groups of stakeholders.
Communication with stakeholders
For the purpose of due communication with its stakeholders, XTB publishes information on the
assumptions of its strategy, including long-term goals and planned actions, on its website.
The strategy implementation process, determined by means of ﬁnancial and non-ﬁnancial measures, is
presented in current and periodical reports. The Company holds quarterly meetings for investors,
inviting especially shareholders, analysts, industry experts and media representatives. As a stock
exchange-listed company, XTB publishes periodical reports every quarter. Its reports for supervisory
institutions are prepared at least once a month.
For information regarding actions taken in terms of communication and education of retail customers,
see point Communication with the customer of this Statement.
5
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Business sites
XTB Group conducts its business activity based on licences granted by the regulators in Poland, United
Kingdom, Cyprus, Belize and United Arab Emirates. The business of XTB Group is regulated and subject
to oversight of competent authorities on the markets where the Group operates, including EU Member
States, on the basis of the so-called single European passport. Currently, the Group focuses on
developing its business on 12 key markets, including Poland, Spain, Czech Republic, Portugal, France
and Germany, while Latin America, Asia and Middle East are considered the priority regions of further
expansion of the Group.
Both in Poland and in other countries, the Group conducts its business in rented properties only. These
include oﬃce space and IT infrastructure space.
3 ESG Strategy
The ESG Strategy of XTB Group was adopted in Q4 2021.
As part of its ESG Strategy, XTB puts emphasis on continuation of previously applied solutions and
fulﬁlment of commitments in the area of environmental protection and sustainable development. In
connection with the aforementioned, XTB set targets to be gradually accomplished. Taking various
initiatives in this area will allow to build environmental awareness not only among employees, but also
among customers and business partners. The intention of XTB is continuous increase of involvement in
corporate social responsibility projects.
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NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
The ESG Strategy is based on three pillars, i.e. i) Environment, ii) Social Responsibility, iii) Corporate
Governance.
Environment
Social Responsibility
Corporate Governance
● Taking care of the natural
environment at the work place.
● Implementation of a number of
solutions aiming at more
eﬃcient management of natural
resources.
● Aiming at reduction of the
organisation's carbon footprint.
● Building environmental and
climatic awareness among
employees and co-workers.
● Ensuring immediate access to
ﬁnancial markets around the
world.
● The paramount goal of XTB
Group is economic education of
the society.
● XTB shares knowledge and
experience, cooperating with
universities and other
institutions.
● The XTB team is composed of
ambitious people who are
supported in continuous
development and
accomplishment of their goals.
● XTB is one of the largest
stock exchange-listed
Forex & CFD brokers in
the world.
● XTB Group's business is
subject to ﬁnancial
oversight on
international ﬁnancial
markets, including but
not limited to: FCA,
BaFin, ACPR, CySEC,
IFSC.
The ESG Strategy document is available on the corporate website of XTB. Information regarding
implementation of the ESG Strategy is presented in consecutive non-ﬁnancial statements and reports of
XTB Group.
Information regarding planned initiatives in individual areas is described further in this Statement.
As of December 2020, XTB's stocks are WIG-ESG index-listed. The purpose of the WIG-ESG index is
measurement of the value of portfolio of stock exchange-listed companies qualiﬁed to WIG20 and
mWIG40 Indices, veriﬁed by means of the adjustment factor, i.e. assessment of the level of observance
of environmental, social and corporate government principles in the business activity.
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NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
4 Description of the Capital Group's Business
4.1 Description of Basic Products and Services
XTB Group is an international supplier of products, services and proprietary technological solutions in
the scope of trade in ﬁnancial instruments. XTB Group specialises in the OTC market and, in particular,
CFD derivatives.
XTB's product offer
FOREX
Forex (Foreign Exchange Market) is the
largest ﬁnancial market in the world. Trading
on the Forex market takes place 24 hours a
day, 5 days a week. XTB offers ca. 500 CFD
instruments based on currency pairs.
INDICES
CFDs are derivatives. This means that you
are not actually becoming the holder of the
underlying instrument - you simply speculate
whether its price will increase or decrease.
XTB offers over 40 CFD instruments based
on stock indices from the entire world: USA,
Germany, China.
COMMODITIES
Thanks to commodity/raw material CFD
transactions, customers can invest in
instruments based on such raw materials
as gold, silver and oil. This enables
earning on speculations on raw material
prices, i.e. price increase and decrease.
XTB offers selection of over 20 raw
material CFD instruments.
STOCKS
XTB offers access to stock CFDs and
regular stocks.
Stocks are securities conﬁrming
participation in the given enterprise. They
combine property rights (right to dividend)
with non-property rights (voting right).
ETF
The exchange-traded fund (ETF) is an
investment fund the purpose of which is
faithful representation of the given index,
and the participation titles are listed on
the stock exchange.
XTB's offer includes both ETF CFDs and
cash instruments.
CRYPTOCURRENCIES
Cryptocurrencies are a form of electronic
currency created and stored electronically.
XTB offers a CFD instrument, which means
that you do not have to purchase the
cryptocurrency physically. All you need to do
is invest and speculate on future ﬂuctuations
of prices, without holding of the underlying
instrument.
XTB has made 15 CFD derivatives based on
cryptocurrencies available
8
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
At the end of 2021, the Group's offer included over 5 400 ﬁnancial instruments from around the world.
These included over 2 100 CFD derivatives with a leverage, including nearly 50 based on currency pairs,
ca. 20 based on commodities as well as ca. 40 based on indices and 15 based on cryptocurrencies, ca.
1 900 based on stocks of stock exchange-listed companies in 16 countries and over 100 based on
American and European ETFs. The offer of XTB includes also over 3 200 cash instruments, including
over 3 000 stock instruments and nearly 300 ETF instruments from the European markets.
The environmental and social aspects are not the dominant factor in designing the product offer.
Nevertheless, the XTB's offer includes ﬁnancial instruments (e.g. ETFs) enabling investments in
climate-aware entities or entities classiﬁed to indices factoring in ESG criteria. Furthermore, the XTB's
offer includes ﬁnancial instruments related to the rights to CO2 emissions (EMISS contract) and XTB is
considering extending its offer with instruments supporting direct management of selected aspects of
the climate risk, e.g. weather derivatives.
4.2 Suppliers
Materials used and services provided to the Group
As part of its business activity, XTB Group cooperates with providers of services supporting
organisational, marketing, analytical processes, IT development as well as supporting the trading area.
The activity of these entities is located mainly in Europe and USA.
In most cases, cooperation with suppliers is of permanent nature. In speciﬁc cases, single-time
cooperation is also possible to pursue a speciﬁc goal.
The key suppliers of XTB are providers of services supporting XTB's customer service processes
(including providers whose services contribute to automation of the above processes) as well as
providers of services used in the trading area (e.g. providers of market data).
As regards other supplies, these include, in particular, purchase of IT hardware, energy and oﬃce
supplies.
No cases of violation of employees' rights by the suppliers of XTB Group were identiﬁed in years
2020-2021. Due to the proﬁle and location of activity of the suppliers, XTB Group has not identiﬁed
suppliers who could pose a threat to the right to freedom of association and collective disputes or who
could violate such rights.
Reliance on suppliers
Due to the nature of conducted business activity, XTB Group does not rely on any suppliers.
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NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
4.3 Customers
XTB Group operates in two segments:
• retail activity,
• institutional activity.
In 2021, the retail activity segment generated ca. 90% of the total volume of the Group's turnover, while
the institutional activity segment - ca. 10%.
Retail segment
The retail activity of XTB Group includes mainly online trade in derivatives based on underlying assets
and instruments traded on ﬁnancial and commodity markets, serving mostly retail customers.
The retail customers of the Group are granted access to the front-end type trading platform and a
number of its components as well as back-oﬃce systems.
The customer base of XTB in the retail segment is characterised with the following parameters: i) new
customers, ii) total number of customers and iii) average number of active customers.
10
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
In 2021, XTB's Group acquired 189 187 new customers and their total number was 429 157. On the
other hand, the number of active customers (i.e. customers who executed at least one transaction in
2021) was 190 452.
Communication with the individual customer and educational activity
From the very beginning of its existence, XTB pays special
attention to education regarding the functioning of ﬁnancial
markets. The paramount goal of XTB is building investment
awareness and facilitation of access to economic knowledge to
everybody. XTB makes sure that any person interested in the
functioning of ﬁnancial markets has access to the necessary
knowledge. Most educational materials prepared by XTB are
available to the prospective customers for free.
These materials include nearly 100 hours of educational
trainings in a video version, available on the xStation platform
developed by XTB, and tens of articles shared as part of the so-called Trading Academy.
The authors of trainings are both XTB's internal specialists as well as external experts from the ﬁnancial
markets. The variety of subjects and advancement levels makes them valuable for both beginning and
advanced investors.
Furthermore, depending on individual needs, customers can participate in the regular conferences and
webinars organised by XTB.
No penalties were imposed on the XTB Group companies and no breaches of such companies were
recorded with regard to competition regulations in 2020-2021.
In 2021, non-conformities in the area of Internet marketing communication conducted by the XTB
branch with the local regulations were identiﬁed on the French market. After identiﬁcation of
irregularities in this area, actions were taken immediately to adapt communication to the regulatory
requirements. Nevertheless, in connection with the situation that took place in 2021, a penalty was
imposed on the French branch, but it was not signiﬁcant from the point of view of the business activity
of XTB Group.
No penalties related to breach of marketing communication regulations were imposed in years
2020-2021.
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NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Institutional segment
As regards institutional customers, XTB offers technologies allowing such customers to offer trading in
ﬁnancial instruments under their own brand to their own customers. XTB is also a liquidity provider for
institutional customers. Institutional customers include, without limitation, brokerage houses, start-ups
and other ﬁnancial institutions. Institutional customers are granted full access to the management
settings and functions, branding system and risk management tools.
In the institutional segment, the average number of active customers in 2021 was 22, and the total
number of customers was 38.
Reliance on recipients
Due to the nature of the primary business activity, focused on retail customers, there is no risk of
becoming reliant on any recipient.
4.4 Cooperation with Contractors
Contracts with the contractors do not include any clauses regarding ethical, environmental or human
rights-related clauses in a scope other than resulting from the locally governing law.
The XTB's business model does not provide for participation in public tenders. In 2020-2021, the XTB
Group companies did not participate in any tenders of this type.
The XTB Group companies did not order any audits regarding the environmental, OHS, human rights or
ethical areas in years 2020-2021. XTB's Group contractors did not order any XTB audits in the above
areas either.
4.5 Commercial Contracts and Transactions
Due to the nature of the conducted operating activities and generation of revenues mainly based on
individual contracts concluded with natural persons, with concurrently dispersed group of suppliers, XTB
Group did not conclude any signiﬁcant contracts regarding its operating activities in years 2020-2021.
4.6 Public Aid
In the period from 2020-2021, the Company received ﬁnancial support in the form of de minimis aid
from the National Training Fund (NTF). In 2020, the gross amount of ﬁnancial support was PLN 28
thousand, in 2021 the ﬁnancial support from NTF amounted to gross PLN 30.2 thousand.
At the same time, the Company enjoyed no preferential treatment in relation to other entities, adhering to
common and uniform support criteria.
Apart from that, the XTB Group companies did not use any public support.
12
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
The XTB Group companies did not use any support resulting from the so-called anti-crisis shields.
4.7 Technology Development
XTB is developing the functionalities of its proprietary trading system - xStation - to meet the
expectations of the customers. Works consisting in creation and development of highly innovative,
comprehensive solutions in the area of online transactions and investments ("R&D works") were carried
out in the reporting period. The purpose of the above works is development of innovative technologies
and solutions enabling further development of products offered to the customers.
The R&D works performed in 2021 aimed at development of tools needed for eﬃcient functioning of
XTB's transactional systems as well as modernisation and upgrading of CRM systems to align them
with identiﬁed development needs. The research areas focused mostly on elimination of errors and
ensuring functionality and security of system operation, including databases. R&D works aiming at
development of new electronic trade systems were also carried out. The main types of activities
performed as part of R&D works include, inter alia:
● development of new or upgrade of existing software solutions used by XTB's customers in the
process of trade in ﬁnancial instruments,
● development of new or upgrade of existing software solutions used by XTB's customers in the
process of account opening and during use of the back oﬃce modules (deposits, withdrawals,
account update, etc.),
● development of XTB's IT infrastructure in order to, inter alia, ensure an effective network,
continuous improvement of servers and other devices active in XTB,
13
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
● development of new or upgrade of existing software solutions supporting XTB's business,
● creation and development of the key transactional applications and CRM systems,
● development of solutions in the scope of improvement of security of work on the web
and remote access,
● development of solutions in the scope of data retention security,
● development and implementation of new innovative hardware, hardware-software and software
solutions in the company,
● analysis of possible product development, including in terms of existing technological solutions,
● work on improvement of the level of security of processed data, both with regard to data
retention and transmission protocols.
5 Employment
5.1 XTB's HR Policy
The HR Policy of XTB is strictly connected with the company's mission and strategy. The guidelines of
the HR Policy aim at effective management of human resources through effective selection, support of
development and retention of the team of employees that will guarantee performance of the business
activities planned by the Company at the highest level. The HR Policy is based on the assumption that
the most important factor of the Company's success is its staff and, thus, the paramount goal is
continuous striving for creation of the best work places and work conditions possible that enable
development of competences.
The aim of the HR Policy includes, in particular:
● acquisition of the optimal number of employees having speciﬁc qualiﬁcations and professional
potential required to ensure proper staﬃng of speciﬁc organisational units of XTB by means of
a professional recruitment process;
● support in the process of identiﬁcation of employees with the organisation's goals and mission;
● shaping of attitudes and standards of conduct of employees compliant with internal
regulations, ordinances and procedures effective in XTB;
● ensuring professional stabilisation, counteracting turnover of employees and retaining highly
qualiﬁed and valuable staff;
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NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
● support of development of specialised qualiﬁcations required to perform tasks and accomplish
set goals;
● creation of an incentive system based on proper shaping of work conditions in combination
with the remuneration, promotion and bonus system as well as assessment of professionalism
and performance.
Areas of operation in the scope of HR Policy include:
● employment planning;
● recruitment;
● employees' performance assessment;
● retention of employees (incentivising, remunerating, promoting, granting of bonuses);
● development of employees (individual professional development programmes, trainings).
All XTB Group entities rely on the assumptions of the HR Policy.
Detailed provisions regarding the above area are included in the HR Policy document and related
procedures.
Dialogue with employees
The documented dialogue with employees usually takes place in the mode of e-mail communication or
online meetings.
The results of XTB Group, on-going strategy implementation and strategic plans for the next period are
communicated to the employees by the President of the Management Board quarterly or every six
months.
During the pandemic, the President of the Management Board updated the information regarding
remote work on a current basis, addressing communications to the employees of the entire XTB Group.
An anonymous global survey of satisfaction of XTB's employees was carried out at the turn of 2020 and
2021, offering the employees an opportunity to express their opinion with regard to such areas as
training and development, motivation, communication, work environment, eﬃciency as well as
management and relations. Additionally, the employees had an opportunity to present their opinion
about the employer and to make requests. The survey aimed also at determination of expectations
regarding remote work during the pandemic and preferences regarding work in the hybrid form. The
results of the global satisfaction survey have been published and are available to all XTB's employees.
In connection with the planned return to hybrid work at the end of 2021, changes in the work regulations
and remote work regulations as well as rules effective in the XTB's oﬃce during the COVID-19
epidemiological threat were consulted with representatives of employees.
15
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
5.2 Ensuring Diversity
Managerial approach to diversity
The employees of XTB Group have different talents, skills, traits, personalities, experiences, personal
situations, views and other attributes. XTB Group recognises diversity and equal treatment of all
employees, governing bodies and key managers as fundamental due its deep conviction that diversity,
as a fundamental value of the contemporary society, has a material impact on development,
competitiveness and innovativeness of the organisation. This approach aims at full use of the
employees' potential, skills, talents, passion, knowledge and qualiﬁcations.
XTB Group creates an organisational culture oriented at accomplishment of the organisation's goals
through building of internal teams diversiﬁed in terms of sex, age and qualiﬁcations, making problem
solving more eﬃcient, improving work atmosphere, improving creativity of design teams and making
sharing of knowledge more effective.
The employees of XTB Group are diversiﬁed in terms of sex, age, education, qualiﬁcations, professional
experience, nationality, ethnic origin, religion, creed, atheism, political views, health condition, sexual
orientation, family status, lifestyle, place of residence, form, scope and basis of employment. To them,
XTB Group ensures respect, tolerance and equal treatment at work as well as creation of a work
environment conducive to utilisation of all these differences for the beneﬁt of the organisation.
16
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Diversity management consists also in inclusion of provisions in XTB's policies and procedures that
regard counteracting discrimination, mobbing and other regulations determining the standards of equal
treatment, protection against violence, sexual abuse or unjustiﬁed dismissal. The principles of equal
treatment in employment are described in internal documents, including but not limited to the work
regulations, and are available to the employees.
According to the effective whistleblowing procedure, all employees and co-workers are obliged to react
if they witness exclusion or harassment of their colleagues.
In October 2021, XTB joined the Signatories of the Diversity Charter and, thus, took another step towards
social cohesion and equality. The Charter is a commitment signed by organisations that decided to
implement a ban on discrimination at the work place and to work towards creation and promotion of
diversity, and it expresses the readiness of the company to involve all employees as well as business
and social partners in such activities.
In years 2020-2021, there were no cases of discrimination, mobbing or sexual harassment reported in
XTB Group. No cases of breach of human rights were reported in the above period either.
Diversity policy regarding the Members of the Company's Management Board
17
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
As regards diversity in connection with appointment of the Company's governing bodies, the Diversity
Policy for the Members of the Company 's Management Board was adopted. XTB ensures diversity of
qualiﬁcations and competences in terms of education, professional experience and skills of the selected
staff, including the management staff, to guarantee comprehensive and reliable performance of
entrusted tasks. Furthermore, under the Diversity Policy, in the recruitment process the governing
bodies take into consideration professional qualiﬁcations, reputation, professional experience,
predispositions to perform obligations on the given position or in the given function as well as diversity
in terms of sex, age, place of origin and education. The members of XTB's governing bodies specialise in
various areas of knowledge and have diversiﬁed industry-related experience corresponding with their
current function. The individual competences of the members of XTB's governing bodies are
complementary in order to ensure the appropriate level of collective management in the organisation.
5.3 Employment Structure
Bearing in mind the business model of XTB Group, the main groups of employees are IT specialists and
persons working in the customer support areas.
Figures regarding employment are presented below.
Criterion
XTB Group
2021
2020
contract of employment
(in full-time equivalents)
below 30 y.o.
total
266
197
women
93
67
men
173
130
30-40 y.o.
total
284
259
women
82
71
men
202
188
40-50 y.o.
total
42
38
women
11
10
men
31
28
over 50 y.o.
total
5
7
women
0
1
18
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
men
5
6
contract of employment
for an indeﬁnite term
(in full-time equivalents)
below 30 y.o.
total
179
138
women
57
51
men
122
87
30-40 y.o.
total
262
226
women
73
60
men
189
166
40-50 y.o.
total
41
36
women
11
9
men
30
27
over 50 y.o.
total
4
7
women
0
2
men
4
5
other (contracts of
mandate)
below 30 y.o.
total
17
7
women
4
2
men
13
5
30-40 y.o.
total
0
0
women
0
0
men
0
0
40-50 y.o.
total
0
0
women
0
0
men
0
0
over 50 y.o.
total
1
0
women
1
0
men
0
0
19
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
The highest employment diversity understood as diversity of functions and positions is recorded in the
Parent Entity in the XTB Headquarters. The employees of subsidiaries and branches are mainly persons
responsible for support of sale processes on the local markets.
Shares of key categories of positions and functions in the XTB Headquarters, i.e. without department
activities, are presented below.
Area/position
2021
2020
IT area
39%
27%
sale area
3%
3%
customer service area
24%
19%
other specialised positions
13%
29%
management positions
14%
15%
executive positions
7%
7%
Information regarding staff turnover is presented below.
Criterion
XTB Group
2021
2020
hiring of employees
below 30 y.o.
total
139
97
women
47
32
men
92
65
30-40 y.o.
total
54
46
women
21
11
men
33
35
20
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
40-50 y.o.
total
7
8
women
3
2
men
4
6
over 50 y.o.
total
0
1
women
0
0
men
0
1
employees leaving
below 30 y.o.
total
68
53
women
23
14
men
45
39
30-40 y.o.
total
41
29
women
12
8
men
29
21
40-50 y.o.
total
2
2
women
2
0
men
0
2
over 50 y.o.
total
1
2
women
0
1
men
1
1
including in
connection with
acquisition of
old-age pension
or disability
pension rights
total
0
10
women
0
2
men
0
8
staff turnover ratio
2021
total
20,0%
21
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
women
22,2%
men
19,4%
The information regarding cooperation of XTB Group under civil law contracts is summed up below.
Criterion
XTB Group
2021
2020
civil law
contracts
number of civil law
contracts at the end of the
period
total
54
46
number of civil la contracts
concluded in the period
total
50
23
number of civil la contracts
terminated/concluded in
the period
total
33
15
In the period of 2020-2021, the number of the disabled employed by XTB Group was 10 and 11,
respectively.
No persons were hired in the outsourcing mode or as temporary employees in 2020. On the other hand,
the number of employees with whom XTB Group (in Poland and Cyprus) cooperated on the outsourcing
basis in 2021 was equal to 13.5 full-time equivalents.
There are no trade unions in any of XTB Group companies. According to the law, representatives of
employees have been appointed in the XTB Headquarters in Poland.
There were no collective disputes in 2020-2021.
In 2021, there was no situation recorded where a woman resigned from work after giving birth and
returning to work within 12 months from that return. On the other hand, 3 such cases took place in 2020
in XTB Group.
Considering its business model, XTB Group does not envisage hiring employees from economically
weaker countries for the purpose of performance of the so-called low-cost tasks. XTB Group ensures
also equality of the terms of employment on similar positions - even if an employee comes from a less
economically developed country, he/she is employed on terms equal to those offered to employees
from Poland, EU or other regions of the world.
22
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
5.4 Employment Conditions
Remuneration system
According to the internal remuneration system, the employees receive remuneration for work
corresponding to the type of work performed by them and qualiﬁcations required for this purpose, taking
quality and quantity of performed work into account. The internal remuneration regulations lay down
the principles and conditions of remuneration for work and services connected with work as well as the
terms of granting them.
The employee remuneration, rotation and promotion system of XTB is implemented through creation of
mechanisms incentivising the employees to improve the quality and effectiveness of performed work.
Due to the intention to enrich the remuneration system with non-wage beneﬁts and striving to increase
integration and identiﬁcation of the employees with the company, the persons employed in the XTB
Headquarters are covered by the package of additional beneﬁts. The remuneration/promotion system is
built in cooperation with directors of departments of the XTB Headquarters by the HR Management
Department. The employee remuneration system and scope of non-wage beneﬁts in the departments
are determined by the directors of departments in cooperation with regional directors.
The promotion, incentivising and bonus policy takes into account the needs in terms of vacant positions,
planned budgets of departments of the headquarters/foreign departments as well as assets allocated
to human resources, qualiﬁcations of employees and assessment of their performance.
The general rules of the remuneration policy aim at ensuring alignment of the system of remuneration
and additional beneﬁts for the employees with pursuit of the long-term development strategy as well as
consideration of the costs adopted in the ﬁnancial plan, concurrently ensuring compliance of risk and
functional stability management.
Gender Pay Gap Ratio
In the scope of remuneration, the Company applies market rules, i.e. it makes the value of remuneration
of employees conditional upon, in particular, possessed knowledge, professional experience and
substantive contribution to the Company's development.
The organisation carries out periodical analysis of the remuneration of men and women in all
Departments. If any discrepancies are detected, the Head of the Department is consulted and remedial
actions are taken if needed.
Information regarding the Gender Pay Gap Ratio (GPGR) for XTB Headquarters is presented below. The
Company presents the ratios for XTB Headquarters due to the highest diversity of positions in XTB
23
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Headquarters in comparison to other organisational units, i.e. foreign branches and subsidiaries where
employees on sale positions are predominant.
GPGR is expressed as a percentage calculated as the absolute value of difference of the product of
average monthly pay of women divided by the average monthly pay of men and number 1. The ratios are
presented taking into consideration the base salary as well as base salary plus extra beneﬁts.
XTB Headquarters
2021
GPGR
(based on base salary)
Employees on managerial
positions
12%
Employees on executive
positions
1%
Employees on positions other
than above
19%
GPGR
(base salary plus extra monetary beneﬁts,
awards, etc.)
Employees on managerial
positions
15%
Employees on executive
positions
6%
Employees on positions other
than above
12%
The Company explains that ca. 40% of employees of XTB Headquarters are IT Department employees
(especially software developers) whose remuneration value and predominant share of men in this
category result in a gender pay gap. The high remuneration of this professional group is related to the
pay pressure on the labour market and need to acquire and retain high class specialists in this area. This
dependency is, however, typical for the IT industry and does not apply only to XTB.
Bearing the aforementioned in mind, the above ratios are presented excluding IT Department
employees.
XTB Headquarters excluding IT Department
2021
GPGR
(based on base salary)
Employees on managerial
positions
0%
Employees on executive positions
0%
24
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Employees on positions other
than above
8%
GPGR
(base salary plus extra monetary beneﬁts,
awards, etc.)
Employees on managerial
positions
8%
Employees on executive positions
7%
Employees on positions other
than above
6%
The difference between the rate based on base salary and the rate based on based salary plus extra
beneﬁts is related mainly with higher share of men employed in the Trading Department and Sale
Department where additional beneﬁts (i.e. including but not limited to bonuses and premiums) are
higher than analogous beneﬁts on administrative positions.
The relation of the lowest remuneration in the Company (based on conversion into full-time equivalents)
to the average remuneration of the members of the Management Board in years 2020-2021 was ca.
0.08.
Non-wage beneﬁts
Information regarding non-wage beneﬁts available in the Company is presented below.
● private healthcare - available for persons cooperating with the Company both under a contract
of employment and contract of mandate;
● refund of costs of corrective glasses - available for Company's employees;
● holiday vouchers - employees' entitlement;
● holiday allowances - available for employees;
● MyBeneﬁt platform and Multisport package - available for employees and persons hired under
contracts of mandate;
● group life insurance - available for employees.
The scope and form of non-wage beneﬁts in the subsidiaries are adjusted to the local conditions and
standards in the area of remuneration of employees and include, for instance, additional healthcare
services, group insurance or holiday gifts.
25
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Promotion of health
In 2021, XTB provided ﬂu vaccines to its employees for the eleventh time. The employees who did not or
could not get vaccinated in XTB's oﬃce on the given date had the opportunity to get vaccinated for free
within the framework of the medical subscription in the selected health care centre.
XTB improves the employees' awareness in the scope of environmental protection and health
promotion. Health protection is promoted by means of such actions as the European Breast Cancer Day
or Movember - organisation of meetings with medical doctors regarding health prophylaxis.
Additionally, XTB ﬁnances projects connected with promotion of sport activities among its employees,
support the XTB team playing in the business football league.
XTB plans to introduce a health day for its employees when they will have an opportunity to undergo the
most important prophylactic examinations, with its goal being the increase of involvement in promotion
of more sport disciplines.
Satisfaction survey
Satisfaction surveys are carried out once a year for the entire XTB Group - information is collected by
means of anonymous questionnaires completed by the employees online. The satisfaction survey
report is made available to all employees.
5.5 Employees' Development
Managerial approach
XTB puts emphasis on creation of conditions conducive to long-term professional development of
employees and continuous improvement of professional qualiﬁcations. Creation of proper conditions for
development of employees aims at effective use of human resources and ensures professional
performance of duties and entrusted tasks. Employees' career planning and development are
considered both in the context of personal development of the employee and XTB's requirements in the
scope of desired competences and qualiﬁcations of the staff.
The means intended for improvement of qualiﬁcations are included in the budgets of speciﬁc XTB
departments. The training budget of foreign branches is determined by each branch director. The
employees are delegated to trainings by their immediate superiors, according to the requirements in
terms of improvement of their education level.
XTB promotes willingness to gain specialised qualiﬁcations by its employees, reimbursing costs of
passed exams, e.g. obtaining broker, investment advisor or CFA licences, etc.
External trainings
26
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
The main training categories include:
● technical (IT area);
● specialised (regarding improvement of professional knowledge, including post-graduate
studies, CFA, ACCA, MBA, ICA, course preparing to obtain the broker's licence, etc.);
● training in the scope of soft skills
● language courses (co-ﬁnancing of education, reimbursement of language course costs,
access to the eTutor foreign language e-learning platform).
In 2020, in XTB Headquarters:
● 6 persons used co-ﬁnancing of studies and post-graduate studies, including MBA;
● 2 persons used co-ﬁnancing of language courses;
● 12 persons used the eTutor foreign language e-learning platform - 178 training hours were used;
● 20 persons participated in conferences
● 7 persons participated in technical trainings (IT area);
● 28 persons participated in specialised trainings
● 39 persons participated in trainings in soft skills
In 2021, in XTB Headquarters:
● 5 persons used co-ﬁnancing of studies and post-graduate studies (co-ﬁnancing for
employees who continue studies during subsequent semesters was maintained and,
thus, participation in education costs is planned also for the years to come);
● 30 persons participated in conferences
● 45 persons participated in technical trainings (IT area);
● 28 persons participated in specialised trainings
● 30 persons participated in trainings in soft skills
● 4 persons used co-ﬁnancing of language courses;
● 31 persons used the eTutor foreign language e-learning platform - 226 training hours were
used;
In 2021, XTB Group held over 160 trainings, including IT trainings, specialised trainings, trainings
connected with foreign languages as well as soft skills. In 2021, XTB Group trained ca. 260 persons,
offering nearly 4.5 thousand training hours.
27
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
In 2020, XTB's employees did not use training leaves. On the other hand, 1 person used training leave in
2021.
In 2020, XTB received funds from NTF and used it to ﬁnance trainings for the group of 19 employees,
including 9 women, with regard to the following areas:
● 14 persons - trainings in accounting, bookkeeping, banking, insurance, investment
analysis;
● 5 persons - trainings in the area of IT and computer use.
On the other hand, trainings for the group of 13 employees, including 2 women, were organised in 2021
using NTF funds. The subject of all trainings was IT and use of computers.
Internal training system
XTB acts with due diligence to ensure that employees have a level of knowledge and competences
adequate to the scope and nature of performed activities, enabling compliance with the effective legal
requirements and recommendations of the supervisory authorities, ethical standards, and to ensure they
act in compliance with fair trade principles and in the best interest of the customer or prospective
customer.
The rules of functioning of the training system are described in the dedicated Procedure for Educational
Trainings and Conﬁrmation of Knowledge and Skills of Employees.
From the point of view of training criteria, XTB divided employees into authorised and unauthorised
employees to whom dedicated training platforms were made available.
Authorised employees are employees authorised to supply information on brokerage services provided
by XTB and ﬁnancial instruments covered by XTB's offer to the customers or prospective customers.
Authorised employees are hired in the Global Customer Support Department, Analysis Department,
Customer Service Department, Sale Department and External Partner Cooperation Department, and they
are obliged to participate in the mandatory educational programme.
Furthermore, authorised employees are obliged to:
● regular participation in additional educational trainings in the principles and mode of
provision of brokerage services, held by XTB in connection with legal changes or
introduction of new legal regulations applicable to XTB's business,
● regular participation in additional educational trainings provided by XTB with regard to
features and characteristics of ﬁnancial instruments offered by the Company or to be
introduced in XTB's offer,
● taking the annual knowledge and competence test by authorised employees, and
passing it with a positive result.
28
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
If an authorised employee fails to take the knowledge and competence test, he/she is deemed to be in
breach of employee's duties, which can result in the authorised employee being unable to continue work
for XTB.
The obligation to participate in the educational programme for new employees is also imposed on
non-authorised employees. In such a situation, training materials are transferred automatically via the
education platform on the ﬁrst days of work.
In addition to the mentioned educational programme, a closed training was organised in 2020 for the
management staff of XTB regarding the issue of remote management, challenges and methods of
effective action, communication with a team working in a remote mode, building commitment in the
remote work formula. The programme was deployed in the online formula for 24 managers and team
leaders. In 2021, a dedicated training in an analogous formula was provided to the group of 30
employees of the IT Department of XTB in the scope of management, addressed mainly to the
management staff and persons planning their professional development in the area of team
management.
Additionally, the HR Department of the XTB Headquarters conducts the "First Day at XTB" training - it is
an onboarding training held on the ﬁrst day of work for all new employees, including trainees and
persons hired under contracts of mandate. In 2020, 121 persons participated in the onboarding training.
On the other hand, 178 persons participated in such onboarding trainings.
Employee performance assessment system
The employee performance assessment system is an essential area of HR management in XTB.
Obtaining reliable information is an essential element of the HR Policy, enabling formulation of the
assessment of employee's performance, taking into consideration his/her competences, possibilities,
motivation and contribution to performance of tasks.
The assessments are carried out for the following purposes:
● improvement of quality and effectiveness of work of XTB's employees;
● providing feedback to the employee with regard to the assessment of his/her performance;
● recording and promoting accomplishments;
● improving employees' motivation;
● identiﬁcation and analysis of potential problems, mistakes in performance of obligations;
● making sure the superior can make reasonable staff-related decisions, including planning of
individual professional development of employees (delegation to trainings).
The assessments are carried out objectively, professionally and reliably, so as to reﬂect the actual level
of performance of duties and work performed by the assessed employee. The employees are subject to
continuous, on-going assessment carried out by immediate superiors as well as periodical
29
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
assessments. Continuous assessment is carried out by the immediate superior and its purpose is
informing the subordinates about the quality of their work and fulﬁlment of entrusted duties. It is carried
out in the form of routine and periodical communication between the employee and his/her immediate
superior. Periodical assessments of employees' performance are carried out quarterly or annually,
depending on the department and position. The quarterly employee performance assessment is carried
out, inter alia, by the superiors from the Customer Service, Trading and Sale Departments.
The annual assessment applies to employees of other departments, higher tier employees and
management staff who are assessed by their immediate superiors.
Development Review programme - career planning
XTB has introduced the Development Review programme the purpose of which is support in planning of
professional development, gaining knowledge and new competences.
A survey is carried out once a year to ensure support in career development within the organisation. The
results of the survey help in career planning and reaching employees with accurate career-related
proposals.
Internship programmes
In pursuit of one of the aspects of the diversity policy, XTB provides internships and professional
trainings to university students and graduates with various professional proﬁles. XTB has launched the
internship programme called the IT Academy. The purpose of the IT Academy is promoting knowledge
that XTB is not only a brokerage house but, ﬁrst and foremost, also a FinTech organisation, creating
proprietary IT products based on various technologies. XTB conducts periodical recruitment of
candidates for internships in software engineering who, having completed the onboarding period under
supervision of a mentor, join selected teams using technological innovations. In addition to the IT
Department, internships held by the XTB Headquarters were organised in the Marketing, Analysis, Risk,
Legal, Trading, Controlling, Customer Service and Global Business Development departments.
Internships are organised by the XTB Headquarters all year long. In 2020, 19 trainees completed
internships in the XTB Headquarters. The highest number of internships, i.e. 9, were held in the IT
Department. In 2021, 39 trainees completed trainings in the XTB Headquarters, including 28 persons
participating in the IT Academy programme.
The internship programmes are also implemented in the foreign branches but, due to the scale of
activity of speciﬁc branches, cooperation in this area regards usually one or two interns - mostly in the
marketing or sale departments.
30
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
6 Occupational Health and Safety
In connection with announcement of the state of epidemic, an ordinance regarding rules of safe work
was adopted. The ordinance contained also information on mandatory use of personal protection
equipment and adaptation of the work station and entire oﬃce space to the pandemic situation.
Furthermore, the assessment of occupational risk threats was updated, taking into account the above
factor irrespective of the employee's location. Instructions in case of suspected COVID infection in an
employee have also been prepared. The Work Protection Committee has been appointed to lay down the
rules of occupational health and safety in XTB's oﬃces in connection with the pandemic.
The employees were informed on a current basis by e-mail about the government and internal rules and
regulations (including guidelines of the General Sanitary Inspectorate) introduced in connection with the
Covid-19 pandemic. Additionally, the directors of branches and subsidiaries informed their employees
about the local conditions and recommendations in the given region. The employees were informed on
a current basis about health prophylaxis and safety-related needs, option of counselling and
e-appointments in case of any troubling symptoms as well as about the mode of reporting any cases of
actual or suspected coronavirus infections. Additionally, the employees were informed about the
availability of psychologist appointments and participated in webinars regarding stress management.
In March 2020, most employees shifted to remote work - only several dozen people responsible for
supervision and technical support for others stayed at the oﬃce. The Remote Work Rules were adopted
in March 2020. In 2021, work in the remote mode continued. Decisions on acceptance of on-site work by
the employee in the oﬃce were made by the directors of the individual organisational units.
In May 2020, anonymous survey was carried out among employees with regard to remote work. In
December 2020, a survey by means of anonymous online questionnaires regarding dealing with stress
during the pandemic, opinion on remote work as well as potential remarks and commentaries in this
scope was carried out. Based on the results of the above survey, internal trainings were carried in the
form of webinars with regard to stress and task management.
In 2020, XTB adopted the information policy encouraging its employees to get vaccinated. The policy
was continued also in 2021.
In years 2020-2021, XTB Group recorded no accidents at work or accidents connected with accidents at
work.
The OHS Committee, established under the effective laws, has been functioning in XTB since 2018.
31
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
There are no positions for which the threshold limit values (TLV) or permissible exposure limits (PEL) are
exceeded and there are no positions for which the level of assessed occupational risk is unacceptably
high.
No cases of occupational diseases were identiﬁed in 2020-2021.
7 Environmental Aspects
Impact on the environment
Considering the nature of the conducted business, based
mostly on IT and oﬃce activities, XTB Group has not identiﬁed
any major impact on environmental aspects.
Providing its services, XTB uses It infrastructure, oﬃce supplies
and electricity. The generated waste includes, ﬁrst and
foremost, IT hardware and municipal waste.
Thus, the business activity of XTB Group is characterised with
relatively low impact on the natural environment. This activity
does not cause any major emissions and does not generate a
major amount of waste. XTB Group does not use any major
raw materials or materials either.
The rented oﬃce space is located at urban sites, typically in business centres - these sites are not
protected areas in terms of biodiversity. Subject to the waste generated in the course of conducted
business activity, the speciﬁc sites do not generate any major negative impact on the surrounding.
Nevertheless, XTB takes a number of initiatives connected with environmental protection, including
but not limited to:
● initiatives connected with energy eﬃciency of used infrastructure,
● document digitalisation,
● reduction of waste production as well as waste sorting and recycling,
● education of employees - Natural Investment programme,
● new seat of the company - as of January 2022, the seat of XTB is located at a new site,
awarded the sustainable building certiﬁcate - the building of the new XTB seat was designed
with environment in mind, as shown by the excellent level BREEAM certiﬁcate and 100% of
energy used by Skyliner originates from renewable energy sources,
32
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
● activities in the scope of monitoring and calculation as well as initiatives aiming at reduction of
the company's carbon footprint.
Waste
The generated waste is classiﬁed as household waste and
includes mostly packaging and typical oﬃce waste. Due to the
low scale of generated waste, the XTB Group companies were
not obliged to registration in the BDO (Waste Database)
register.
Waste is sorted in the oﬃces. Trash bins for waste sorting,
along with full instructions regarding proper waste sorting, are
placed in the kitchens.
The used electronic equipment is regularly transferred to
recycling. Recycling of used computer equipment is carried out through specialised companies that
collect the equipment from XTB. The equipment transferred to recycling includes mainly PCs, laptops,
screens, telephones and printers. Replaced IT hardware that is still suitable for use is given to charity.
Environmental education programme
XTB has launched an environmental educational programme for XTB's employees entitled Natural
investment. This programme was developed to improve environmental awareness of XTB, creating a
friendly work place where we place emphasis on the care for the environment and eﬃcient use of
natural resources.
The purpose of the programme is encouraging environmentally-friendly behaviours at the work place
which may, at the same time, translate into good habits in everyday lives of the employees.
The programme includes a number of actions aiming at reduction of impact on the environment,
including but not limited to:
● saving of water and electricity by means of information remining about switching off the lights,
saving water, etc. placed around the oﬃce;
● reduction of printing and copying of documents, etc. through periodical mailing and posting of
information reminding about the need to save paper at the printers;
● waste sorting in the common oﬃce parts, with full sorting instructions. Special sorting trash
bins are placed in the kitchens;
● collection of waste paper;
● collection of used batteries in a special container placed in each kitchen, to be then transferred
to the relevant collection centre;
● collecting plastic caps and transferring them to the collection centre or donating them to
support charity actions;
33
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
● promoting environmental days, such as the day without your car, through placement of speciﬁc
information in the common oﬃce parts;
● no to food waste - sharing food in fridges, monitoring of food thrown away;
● gradual replacement of traditional ﬂipcharts with whiteboards;
● replacement of plastic kitchen accessories with biodegradable and compostable utensils;
● elimination of plastic cups at the water dispensers;
● limitation of procurement of disposal accessories;
● increase in the number of plants in the oﬃce space.
The priority is to implement all solutions covered by the programme in the new seat of XTB in Warsaw.
The goal of XTB in the environmental area is continuous increase of environmental awareness of
employees. Extension of the Natural Investment programme to cover the branches and subseries is
planned to achieve cohesion of the environmental policy in work place adopted by the Group.
Fuel and electrical energy consumption
The sources of direct fuel use are business cars and power generators.
Information regarding direct use of fossil fuels by XTB Group is presented below.
Fuel type
UNIT
2021
Diesel oil
t.
1,79
petrol
0,89
The most important sources of electrical and heat energy consumption are oﬃces and the server room.
Information regarding direct use of electrical and heat energy by XTB Group is presented below.
Energy type
UNIT
2021
electrical energy
MWh
GJ
385,0
heat energy
4 374,8
Climate-related issues
Due to the nature of the primary activity of XTB in the form of
ﬁnancial services (online trade in ﬁnancial instruments) and
supply of technological solutions, from the point of view of
environmental impact, including climate changes, the XTB's
business can be characterised as a typical oﬃce activity and
34
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
activity related with maintenance of IT infrastructure the most important impact area of which is
consumption of purchased energy.
Considering the aforementioned, the impact of the conducted business activity on emission of
greenhouse gases is signiﬁcantly limited in comparison to such industries as manufacture, construction
or power engineering.
The XTB's intention is, however, taking actions aiming at gradual reduction of carbon footprint and, as a
target, reaching climate neutrality of the organisation.
The above is planned to be accomplished, in particular, by means of:
● initiatives reducing energy consumption, including but not limiting to the possessed IT
infrastructure,
● use of electrical energy from renewable sources,
● long-term cooperation in the area of forestation,
● effective management of resource consumption.
XTB Group identiﬁes impact on the climate area in the following scope:
● impact on emission of greenhouse gases originating from direct use of fuels,
● indirect impact connected with consumption of purchased electrical and heat energy,
● indirect impact connected with suppliers' activities;
● education of employees and co-workers in the scope of climate awareness.
Concurrently, the climate issues have (or may have in the future) impact on the following areas:
● legislative changes imposing the obligation to incur capital expenditures limiting energy
intensity of IT infrastructure;
● impact on the possessed product offer in the scope of instruments used for the purpose of
climate risk management;
● possibility of intensiﬁcation of local, sudden weather phenomena that could have an effect on
physical destruction of oﬃce sites and IT infrastructure;
● growing prices of electricity and heat.
Information regarding greenhouse gas emissions the source of which is XTB Group is presented below.
The sources of emission ratios for Poland were publications of KOBIZE (National Emission Balancing
and Management Centre) and the Energy Regulatory Oﬃce. The sources of emission ratios for other
countries included, in particular, the UK Government Conversion Factors (Defra)
35
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Unit
2021
Emissions resulting from fuel consumption (Scope 1)
Mg CO2e
7,9
Emission related to energy consumption (Scope 2)
560,9
Total emissions (Scope 1 and 2)
568,8
The climate issues have not been taken into consideration in the decision-making processes of XTB
Group so far. The impact of the primary operating activity (taking into account also the product offer and
the source of revenues and costs) on climate issues can be considered immaterial in comparison to the
impact of organisations with a similar scale of activity and functioning in traditional sectors of the
industry or construction. Nevertheless, the XTB's intention to reduce the impact on the natural
environment (including but not limited to the climate) has become one of the basic criteria taken into
consideration when making decisions in the area of business and administrative support.
The intention is also incorporate of the climate risk in the risk management system effective at the level
of XTB Group.
Concurrently, the following actions are planned to be taken:
● monitoring of carbon footprint for the organisation, as a target: in three scopes;
● as part of the long-term initiative - entering into cooperation with a third-party
organisation to plant trees and take care of a forest together with XTB employees.
● systematic limitation of paper consumption;
● building environmental awareness among employees as part of subsequent initiatives of
the Natural Investment programme and among business partners through incorporation
of the ESG area in the Company's business strategy.
Water consumption
Supply of water and collection of sewerage is provided by local municipal entities, according to the
contracts concluded with building owners. Due to the location of the seat and oﬃces in oﬃce buildings,
the Group companies use only water from water supply systems. The total water consumption of XTB
Group in 2021 was ca. 177.6 m3.
36
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
8 Impact of COVID-19 Pandemic on
Non-Financial Issues
In March 2020, the World Health Organisation stated that the disease caused by the COVID-19
coronavirus can be referred to as a pandemic. In connection with the development of the disease
around the world, all countries take various actions aiming at the limitation or delaying of its spread. The
measures taken have an increasing impact on the global economy. This situation affected the more
than average ﬂuctuations on ﬁnancial and commodity markets, causing a great transactional activity of
customers and translating into an increase in the Group's revenues and growth of the customer base.
In addition to the impact of the COVID-19 pandemic on the work conditions and activities related to, for
instance, education in the health area described earlier herein, XTB has not identiﬁed any impact of the
pandemic on other non-ﬁnancial aspects, including but not limited to those referring to environmental
issues, human rights or counteracting corruption.
9 EU Non-Financial Taxonomy
For the purpose of this Statement, the analysis of share of the EU non-ﬁnancial taxonomy-eligible and
taxonomy-non-eligible activities in total turnover, capital expenditure and operating expenses was
carried out, including adequate quality information in the scope regarding the ratios for ﬁnancial year
2021. The presented ratios refer concurrently to the taxonomy related to mitigation of climate changes
and adaptation to climate changes.
For the purpose of this Statement, compliance with taxonomy is not disclosed.
In relation to the presented ratios, the Group has no comparative data for 2020. So far, the Group has not
implemented the plan referred to in Point 1.1.2.2. of Annex No. 1 to Commission Delegated Regulation
(EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament
and of the Council by specifying the content and presentation of information to be disclosed by
undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally
sustainable economic activities, and specifying the methodology to comply with that disclosure
obligation (Regulation 2178). XTB Group has no investments in equity accounted in joint ventures,
pursuant to IFRS 11 or IAS28.
a) turnover ratio
Turnover ratio - percentage of taxonomy-eligible turnover
revenues (PLN thousand)
share in revenues (%)
37
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
Taxonomy-eligible economic
activity
0
0,0%
Taxonomy-non-eligible
economic activity
PLN 625 595 thousand
100,0%
TOTAL
PLN 625 595 thousand
100,0%
For the turnover ratio:
● the basis were the consolidated total revenues of the Group in 2021 disclosed in the
consolidated ﬁnancial statements, i.e. PLN 625 595 thousand;
● for the purpose of numerator analysis, no revenues on sales of products and services
connected with the activity of XTB Group covered by the EU non-ﬁnancial taxonomy were
identiﬁed.
The XTB Group companies did not issue any green bonds or debt securities to ﬁnance speciﬁc identiﬁed
types of taxonomy-aligned activities.
b) CapEx ratio
CapEx ratio - percentage of taxonomy-eligible CapEx
capital expenditure (PLN
thousand)
share in capital expenditure
(%)
Taxonomy-eligible economic
activity
PLN 188 thousand
1,5%
Taxonomy-non-eligible
economic activity
PLN 12 349 thousand
98,5%
SUMA
PLN 12 537 thousand
100,0%
For the CapEx ratio:
● the basis was the capital expenditure incurred by XTB Group in the amount of ca. PLN 12 537
thousand, calculated according to IAS/IFRS regulations speciﬁed in the Annex to Regulation
2178;
● for the purpose of numerator analysis, capital expenditure connected with the EU non-ﬁnancial
taxonomy-aligned activity in the amount of ca. PLN 188 thousand were identiﬁed.
The taxonomy-eligible capital expenditure includes a single investment covering ﬁxed assets (means of
transport) ﬁnanced by way of lease and regarding the activity provided for in point 6.5 of the taxonomy
38
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
related to mitigation of climate changes and adaptation to climate changes. The said capital
expenditures were disclosed in the books of accounts according to IFRS 16 Lease, point 53, letter h).
XTB Group has not adopted any investment plan regarding capital expenditure referred to in point 1.1.2
of Annex No. 1 to Regulation 2178. The Group companies did not issue any green bonds or other
securities to ﬁnance speciﬁc identiﬁed taxonomy-eligible capital expenditure.
c) operating expense ratio
operating expense ratio - percentage of taxonomy-eligible operating expenses
operating capital expenditure
(PLN thousand)
share in operating expenses
(%)
Taxonomy-eligible economic
activity
0
0,0%
Taxonomy-non-eligible
economic activity
PLN 24 185 thousand
100,0%
TOTAL
PLN 24 185 thousand
100,0%
As regards the ratio of operating expenses, the analysis of components of operating expenses was
carried out according to the deﬁnition of the EU non-ﬁnancial taxonomy, showing that the value of the
denominator for the turnover ratio is ca. PLN 24 185 thousand. The value speciﬁed above includes, in
particular, non-capitalised costs of research and development works amounting in total to ca. PLN 23
736 thousand, which accounts for 98% of the value of identiﬁed operating expense, and expenses
connected with on-going servicing of the Group's ﬁxed assets and their maintenance in proper condition
(including but not limited to costs connected with repairs, renovations or cleaning) amounting in total to
ca. PLN 449 thousand.
Considering the business model of XTB Group consisting in supply of products, services and
technological solutions in the scope of trade in ﬁnancial instruments and due to the fact that the value
of identiﬁed operating expenses is considered immaterial from the point of view of the scale of activity
of XTB Group, for the purpose of calculation of the ratio of operating expenses, the option to assign zero
as the value of the ratio numerator was used.
10 Business Ethics
Code of Ethics
XTB Group acts with due diligence to ensure that the conducted activities comply with the law, internal
regulations, standards recommended for the compliance management system in the scope of
39
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
corruption counteracting as well as the whistleblower protection system in stock-exchange listed
companies organised by the Warsaw Stock Exchange (Giełda Papierów Wartościowych w Warszawie
S.A.), rules of community life, good market practice and rules of fair competition, and all decisions
regarding the activity of XTB Group are made in the appropriate mode, based on reliable data and in a
manner mitigating the risk of conﬂicts of interest.
As of 2019, XTB has a Code of Ethics that lays down the basic norms, rules of conduct and values to be
observed by all employees and co-workers.
All employees are obliged to act in a responsible and ethical manner, observe the rules arising from the
Code of Ethics as well as to act fairly in all activities and contacts with other employees and business
partners.
The Code of Ethics contains provisions regarding:
● ethical principles in mutual relations;
● ethical principles regarding loyalty, integrity and conﬂict of interest;
● ethical principles regarding gifts and loyalty towards contractors, business partners and retail
customers;
Analogous solutions are applied by subsidiaries through common use of developed rules of procedures
and corporate relations within XTB Group.
The ethical aspects are a major element of the onboarding training for all new employees of the
Company. All new employees familiarise with internal procedures and regulations, including the Code of
Ethics, and undertake to comply with their provisions.
Formal references to respect for human rights within XTB Group are included in Work Regulations and in
the Code of Ethics. Any doubts regarding compliance of conducted activities with aspects related to
protection of human rights must be reported, in accordance with the Code of Ethics, as part oft he
whistleblowing procedure.
There were no complaints ﬁled regarding potential breaches of ethical standards in 2020-2021. There
were no complaints ﬁled with regard to potential ethical breaches in 2020-2021.
Counteracting corruption
XTB has not adopted an oﬃcial corruption counteracting policy. Nevertheless, the nature of conducted
business as well as the regulations regarding XTB Group companies as ﬁnancial market entities
(especially regulations regarding the area of counteracting money laundering and terrorism ﬁnancing)
impose various restrictions on the employees, shaping the awareness of speciﬁc organisational units in
the scope of ethics of conduct, legal restrictions in relations with partners as well as sanctions
connected with breaching them.
40
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
XTB Group has adopted an incentives management policy and conﬂict of interest management
regulations. Furthermore, all centralised purchases (i.e. in Poland) are made according to the dedicated
goods and services procurement procedure.
In years 2020-2021, XTB Group recorded no reported/conﬁrmed cases of corruption.
Counteracting money laundering and terrorism ﬁnancing
XTB is the so-called obliged entity within the meaning of the law on counteracting money laundering and
ﬁnancing of terrorism.
Considering the need to ensure compliance with the above regulations, XTB has adopted the so-called
AML Procedure determining detailed solutions, including obligations of employees of speciﬁc
departments in the scope of counteracting money laundering and terrorism ﬁnancing. The said
procedure lays down, inter alia, the rules of conduct and obligations connected with the above area for
the employees of the Sale Department, Global Customer Support Department, Finance and Accounting
Department, Legal and Compliance Department, External Partner Cooperation Department and IT
Development Department.
No irregularities with participation of the employees of XTB Group were identiﬁed in 2020-2021 in the
area of counteracting money laundering and terrorism ﬁnancing.
Whistleblowing
XTB has a whistleblowing procedure in place which determines the rules of submitting by the
employees of anonymous reports of actual or potential breaches of the law, including breaches of
regulations regarding counteracting money laundering and terrorism ﬁnancing, internal procedures and
ethical standards. Breaches are reported using a dedicated electronic form ensuring anonymity. The
reports are received by the Member of the Management Board for Legal Affairs, and if the breach
regards the Management Board or is Members - by the Supervisory Board. Concurrently, if the local laws
or regulations are more stringent than the rules provided for in the above procedure, the more stringent
rules apply.
Employees are obliged by internal regulations, including but not limited to the ethical standards provided
for in the Code of Ethics, to react to any irregularities. Every person has the right and can report the
above breaches in a conﬁdential manner and will be protected against retaliation, discrimination or any
other types of unfair treatment, according to the whistleblowing procedure. All reports are considered
with due diligence, reliably, fairly and with full discretion.
The reports are veriﬁed by authorised employees, which allows for reliable and impartial clariﬁcation of
any objections.
41
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
11 Data Protection
For the purpose of protection of privacy and personal data, XTB has introduced the following internal
procedures:
● Regulations of protection of the ﬂow of conﬁdential information and professional secrets in XTB
● XTB's personal data protection security policy
● IT security policy.
In years 2020-2021, the Company received no reports from any regulatory authorities regarding
customers/employees/co-workers in the scope of breach of the law. In years 2020-2021, there were
singular situations where customers reported breaches of their personal data. Appropriate activities
aiming at mitigation of potential negative consequences of these events were taken in each such case.
In certain justiﬁed cases, the President of the Personal Data Protection Oﬃce was notiﬁed of breaches
of customers' personal data conﬁdentiality.
In 2020-2021, XTB Group recorded no incidents connected with leakage, theft or loss of information
regarding customers/employees/co-workers.
12 Compliance
XTB Group operates in a strictly regulated surrounding, with major obligations imposed on it in the form
of many international and local regulations and laws. XTB Group is subject to regulation regarding, inter
alia:
● sale practice, including acquisition of customers and marketing activities;
● maintenance of capitals at a speciﬁc level;
● practice in the scope of counteracting money laundering and terrorism ﬁnancing as well as
know your customer (KYC) procedures;
● obligations regarding reporting to regulators;
● obligations regarding protection of personal data and professional secrecy;
● obligations in the scope of protection of investors and supplying them with information
regarding the risk related to provided brokerage services; and
● supervision over the Group's business;
● conﬁdential information and its use, preventing unlawful disclosure of conﬁdential information,
preventing manipulations on the market;
42
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
● disclosing information as an entity listed on the regulated market.
The Group is subject to supervision by competent regulatory oversight authorities and public
administration authorities in the jurisdictions where the Group operates.
The Group has established a compliance function for each of the Group companies providing brokerage
services to ensure compliance with the law and regulatory requirements the Group is subject to.
The Legal and Compliance Department at the XTB Group level is managed by the Department Director
who, at the same time, is the Member of the Management Board for Legal Affairs and reports directly to
the President of the Management Board. The Legal and Compliance Department is divided into the
following four teams: Internal Control Team, Compliance Supervision Team, Operating Support Team as
well as Team Counteracting Money Laundering and Terrorism Financing. For the purpose of risk
management, dedicated compliance regulations and a procedure connected with management of legal
and regulatory risk were adopted in the above area.
Detailed information regarding description and management of regulatory risk is presented in the
Management Board's Report on the Operations for the Year Ended on 31 December 2021.
In 2020-2021, no sanctions connected with breach of the law in the scope of environmental protection,
human rights and employees' rights, occupational health and safety, corruption incidents,
anti-competitive activities or data conﬁdentiality were imposed on the XTB Group companies.
Detailed information regarding signiﬁcant or potentially signiﬁcant court proceedings and proceedings
before administrative bodies is described in the Management Board's Report on the Operations for the
Year Ended on 31 December 2021.
13 Risk Regarding Non-Financial Issues
Risk related to non-ﬁnancial issues
Considering the business model of XTB Group, the key non-ﬁnancial assets from the point of view of
materiality for the Group's business are the employment, human rights, ethics and corruption
counteracting areas.
Risk related to the employment area
XTB Group has adopted a dedicated HR Risk Management Policy laying down the rules and mode of
management of this risk as part of the operating risk management policy.
Risk identiﬁcation and assessment as well as risk counteracting methods are carried out and
determined by the HR Management Department on a current basis.
Information regarding risk related to the employment area is presented below.
43
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
● key staff turnover,
● psychosocial factors - stress at work, intensiﬁed by isolation caused by the pandemic and
remote work,
● long-term absence caused by sickness,
● high staff turnover,
● insuﬃciency of highly qualiﬁed specialists,
● fraud, embezzlement, unethical practice.
Determination of the impact of the HR risk consists in determination of the expected effects that will
affect performance of tasks and accomplishment of the goals of the organisation. The detailed
description of risk management is provided in the mentioned procedure.
Risk in the area of respect for ethics and human rights
In addition to potential ﬁnancial consequences, any breaches of commitments, ethical standards or
obligations related to human rights would result in damage to the Group's image, which could affect
future relations with customers and prospective customers.
XTB Group identiﬁes impact on social relations in the following areas:
● educational activities;
● respecting human rights.
XTB Group manages the above relations by means of actions in the area of reliable communication,
observance of provisions of the Code of Ethics, transparent cooperation conditions and compliance.
Risk related to counteracting corruption
XTB Group's reliability and transparency in action is key for the image of XTB Group as a trusted provider
of solutions in the scope of trade in ﬁnancial instruments.
Any corruption incident could have a negative effect on XTB Group, potentially hindering business
contacts in the future and harming the image of XTB Group as a trustworthy and reliable business
partner. The activities connected with corruption risk management regard, in particular, compliance with
the Code of Ethics as well as policies, procedures and regulations described earlier in this Statement.
14 XTB Foundation
The XTB Foundation was registered in December 2020.
44
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
The foundation's objects of operation include, in particular:
● increase in entrepreneurship and innovativeness, especially in the area of new technologies and
ﬁnancial market,
● improvement of awareness and knowledge related to the economy, ﬁnance and new
technologies,
● scientiﬁc and research activities as well as promotion of solutions developed as part of the
business activity of XTB Capital Group,
● supporting and organising all initiatives connected with promotion of ﬁnancial institutions and
new technologies;
● ﬁnancial support, providing knowledge or business advising to selected entrepreneurs;
● actions in the scope of corporate social responsibility, sustainable development;
● promotion of employment and education as well as aiming at equal opportunity for
development;
● initiation and support of activities of XTB Capital Group's employees;
● charity and social activity, especially aiming at providing equal opportunities and aid to the
disabled and excluded persons.
The activity of the Foundation was limited in 2021 due to the Covid-19 pandemic and remote work
mode. The said time was devoted to determination of the directions of action and search for possibility
of cooperation with third parties for the purpose of pursuit of the statutory assumptions of the
Foundation.
The annual statements of the Foundation are available on the corporate website of XTB Group.
In March 2021, computer equipment worth ca. PLN 6 thousand was donated to the Primary School in
Piaseczno under a donation agreement.
Activities in the social area planned by the Foundation
● gradual extension of the knowledge base for every advancement level, gradual supplementation
of our video educational materials with stenographic records to facilitate their reception to
persons suffering from hearing impairments
● increasing involvement in programmes supporting development and innovativeness of Polish
entrepreneurs
45
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
● gradual increase of expenditure on charity and development of the area of partnership in social
projects, continuation of the programme of donation of the still operable electronic equipment
replaced by the company to charity for the purpose of elimination of barriers and counteracting
exclusion
● increasing involvement in environmentally-friendly projects, e.g. planting forests, intensiﬁed
involvement in social projects, gradual increase in voluntary work
● taking actions to prevent exclusion of children and youth, economic education programme for
children and youth and support of their education in natural sciences.
Irrespective of the aforementioned, subsidiaries took, depending on their scale, individual activities
in the scope of charity, addressing them mainly to local medical centres and institutions.
Signatures of Managers
46
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
________________________________________
Omar Arnaout
President of the Management Board
________________________________________
Filip Kaczmarzyk
Member of the Management Board
________________________________________
Paweł Szejko
Member of the Management Board
________________________________________
Jakub Kubacki
Member of the Management Board
________________________________________
Andrzej Przybylski
Member of the Management Board
47
NON-FINANCIAL STATEMENTS of XTB S.A. Capital Group
(Translation of a document originally issued in Polish)
WWW.XTB.COM
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