Compliance

• revised the Anti-Corruption Policy, also addressed to external stakeholders, indicating, inter alia, the commitment to prevent corruption, key anti-corruption principles, responsibilities regarding their observance and how to respond to suspected irregularities in this regard; and  
• new General Procedure – Counteracting Corruption in PGE Group, replacing the previous Anti-Corruption Policy, binding on employees and persons acting for and on behalf of PGE Group companies, specifying in detail the tasks, roles and responsibilities with respect to counteracting corruption in the Group.

• anti-corruption regulation addressed and communicated to external stakeholders, thus implementing the recommendations from the „Recommended Standards for a Compliance Management System for Anti-corruption and a System for the Protection of Whistleblowers in Companies Listed on Markets Organised by the Warsaw Stock Exchange”,
• clarifying the responsibilities of individual organisational units,
• reference to the WSE’s anti-corruption standards and the CBA’s anti-corruption guidelines (in the latter case, to the extent relevant to the company),
• requirement to ensure that reviews, including, inter alia, analyses of transactions and financial flows, potential errors and deviations, are carried out at least once a year to verify that no corrupt funds are operating within the companies’ structures,
• clarifying the rules of cooperation with business partners (e.g. exercising due diligence in verifying information on possible proceedings and/or convictions, considering, depending on the situation of termination of cooperation, additional supervisory measures, caution in meetings with these partners, good practice in documenting meetings),
• inclusion of 'ethics clauses’ and rules for their application in the appendix to the General Procedure – Counteracting Corruption at PGE Group
• consistency of approach to training – validity for three years for all staff, plus in-depth/dedicated training for selected groups – depending on needs and specificities,
• amendments concerning the avoidance of conflicts of interest.

Preventive actions and education of groups working in areas most exposed to risks significant to the organisation are an element of building a safe, transparent and business-efficient working environment. Such activities allow these people to avoid dangerous situations and react appropriately in the event of their occurrence, thus positively influencing the performance of the company and PGE Group.

As part of the implementation, the Internal Supervision Department has identified groups of PGE SA employees particularly exposed to the risk of corruption.

In the Compliance Assessment, most companies of PGE Group declare that they have also identified groups particularly exposed to the risk of corruption, mainly including persons from the areas for which extended anti-corruption training was dedicated in the previous version of the anti-corruption regulations and/or the areas specified in the Procedure, i.e. primarily in the following areas: purchasing, trade, supply of raw production materials, retail sales, investor relations, communication, administration, human resources management, accounting and bookkeeping, as well as persons from other areas, maintaining business relations with business partners as part of their tasks. Most companies in the Compliance Assessment also declare that measures have been taken to inform these persons that they belong to a group with a higher risk of corruption.

The implementation of business gift rules serves the purpose of transparency of decision-making processes in relations with business partners, as well as reducing the risks of irregularities and/or abuses within these relations, in particular the risks of actions contrary to the provisions of generally applicable laws. This action also follows the guidelines of the „Recommended Standards for a Compliance Management System for Anti-Corruption and Whistleblower Protection in Companies Listed on Markets Organised by the Warsaw Stock Exchange SA, 2018.” It is recommended that the company develops and applies an internal policy or regulation that sets out the general standards and rules for the provision and acceptance of occasional gifts (including invitations), including those of a marketing nature. It is also recommended that the company designates in the Anti-Corruption Code rules for the creation of a detailed register of all gifts, including invitations, given or received by company employees.

In December 2020, an amendment to the rules for giving and receiving gifts was implemented in PGE Group, under which the following changes were introduced:

• it was established that gifts received are recorded only when their value exceeds PLN 200 gross, i.e. when they are one of the types of conditionally permissible gifts. The rules for keeping records of gifts given remained unchanged,
• the responsibility of gift recipients is clarified,
• records of gifts received are kept by the company’s compliance department or another designated organisational unit, ensuring that the information is accessible to Compliance on an on-going basis. records of gifts given may be kept by another designated organisational unit within the company, also with access for Compliance,
• a prohibition is introduced on giving gifts to persons exercising public functions in situations that could give the impression of a corrupt transfer of a financial advantage,
• between the companies of PGE Group, only the exchange of gifts of symbolic value and participation in traditional, jubilee or industry celebrations, such as „Barbórka”, and during important holidays is permitted, subject to gifts presented at such events.

The amended rules on gifts have been implemented in all companies. Companies report gifts received and given to the Compliance function on a quarterly basis, indicating the information or lack of gifts to be recorded in the period. 

• guidelines of the „Recommended standards for a compliance management system concerning anti-corruption and protection of whistleblowers in companies listed on the markets organised by the Warsaw Stock Exchange.”,
• „Best Practices of Companies Listed on the WSE 2021”, 
• additionally, to the extent relevant to PGE SA, the „CBA Anti-Corruption Guidelines for Public Administration” apply.

• PGE Group’s Code of Ethics of – the principle „We do not tolerate corruption and dishonest behaviour”,
• PGE Group’s Anti-Corruption Policy,  
• General Procedure – Counteracting Corruption at PGE Group,  
• work regulations applicable to some of the employers operating within PGE Group (e.g. PGE SA).

• the submission of declarations of interest (in accordance with the applicable model) by employees and other persons (except when another formal solution of identical or broader scope is applied (e.g. a provision in the contract),
• in the case of new employees, the statement is forwarded to the Human Capital Management Department for signature. Signature of the declaration is expected within the first 3 months of employment. quarterly training sessions are held for staff where the issue of conflict of interest is discussed,
• placing the statement in the employee’s personnel file, next to the contract, and in companies using SAP HCM, also marking in a dedicated field in SAP HCM, in order to better monitor the status of the statements made,
• the use of additional contractual clauses regarding the avoidance of conflicts of interest in contracts for consultancy and legal services.

This training is mandatory for all new employees in companies where the compliance management system is implemented. The scope of the training covers basic compliance issues necessary in the first days of starting work or cooperation with a PGE Group company. It is conducted once for each person.

This training is mandatory for all new employees in companies where the compliance management system is implemented. The training takes place within 3 months of commencing work or cooperation with a PGE Group company. As a rule, it is conducted in-class (i.e. directly), in the form of interactive workshops (during the pandemic with the use of available means of communication, i.e. remotely).   E-learning courses are also used. The validity of the training is 3 years. After this period, it is repeated as refresher training. After the first training session, participants submit a declaration confirming that they have read and understand the content provided and that they undertake to observe it. The training program on the Code of Ethics includes, inter alia, a discussion of the application of the values and principles adopted by PGE Group and the observance of human rights, attitudes and behaviours expected of everyone working for PGE Group. The effect of their application is visible in the process of achieving the Group’s established strategic goals.

Training on the anti-corruption regulations in place at PGE Group, just as training on PGE Group’s Code of Ethics, is mandatory for all new hires in companies where the compliance management system is implemented. This training is also conducted within 3 months of commencing work or cooperation with a PGE Group company. The validity of this training is 3 years, after which it is repeated as refresher training.  After the first training session, the participants submit a declaration confirming that they have familiarised themselves with the contents provided and undertake to observe them.

The training program comprehensively covers anti-corruption issues, especially: its legal definition, forms of corruption including: bribery or conflict of interest, as well as detailed anti-corruption rules in force at PGE Group. The training also encompasses examples of practical application of these principles in everyday work.

In addition, depending on the needs, knowledge on anti-corruption may be supplemented with dedicated, in-depth anti-corruption training, taking into account the specifics of the area and the scope of risks and responsibilities in the field of anti-corruption, specific to individual positions and/or areas. In 2021, as part of such dedicated training, a training course was held: „Problems in implementing IT projects, including public procurement,” the aim of which was to build a culture of security in procurement procedures. The training was conducted by representatives of the Central Anti-Corruption Bureau. The course was attended by employees from the area of purchases and IT from the PGE Group.