Ethical foundations of doing business
“In PZU we live up to the highest standards. Treating clients and business partners honestly and objectively is something that sets us apart. This is a guiding principle for doing business ethically and is incumbent upon all PZU Group employees. We attach great importance to instilling and strengthening the awareness within our organization that by adhering to professional ethics and conducting ourselves in compliance with the law we build clients’ trust in PZU. This also evidences the high quality of our services. It also points to the direction in which the entire financial market should move.” PZU Group’s policies [Accounting Act]
[GRI 102-16, GRI 103-2, GRI 103-3]
The compliance risk management system in the PZU Group is based on the best market standards and proprietary solutions, while using a number of agreements between PZU entities and group policies. It is an integrated set of values, standards, tools, including procedures and regulations, supported by adequate communication with, and education of, employees. Individual companies in the PZU Group have a range of separate policies, procedures and practices in this area. The following elements constitute the overall system:
- values and rules of conduct, including the “Best Practices of the PZU Group”, “Code of Conduct in Alior Bank” and the “Code of Conduct in the Pekao Group”;
- procedures, policies and organizational arrangements;
- a system of reporting irregularities and potential malpractice (whistleblowing system);
- educational and communication activities addressed to employees and suppliers.
The “Best Practices of the PZU Group” are the foundation of ethical standards in the PZU Group whose aim is to develop the company’s consistent organizational culture in all key aspects of its operation.
The “Best Practices of the PZU Group” define behaviors and conduct towards all of the company’s stakeholders based on respect and trust. At the same time, this document serves as the common denominator of corporate culture in all of the Group’s entities. Thanks to the consistent compliance of our fundamental principles, all our activities and processes are carried out based on coherent assumptions, thus ensuring a high operating standard throughout the Group. Separate codes of ethics are in place in the Alior Bank Group and in the Pekao Group.
Additionally, PTE PZU has adopted the “Code of Conduct for Employees of PTE PZU SA”, which contains 11 key principles. Above all, it compels employees to act in accordance with the law and the principles of fair trade and the company’s internal regulations. Thus it refers to acting professionally and ethically, showing due diligence in action and showing care for the employer’s image. In turn, this Code of Conduct forbids employees from getting involved in activities that could be deemed to be at odds with the interests of fund members. Moreover, it is not allowed to utilize inside information to make investment decisions.
The “Best Practices of the PZU Group” are in force in the PZU Group. This document has been adopted as a uniform model of the standards observed by all PZU Group entities, except for the Alior Group and the Pekao Group, which have adopted the “Code of Conduct in Alior Bank” and the “Code of Conduct in the Pekao Group”. The “Best Practices of the PZU Group” are a collection of values and principles by which employees should be guided. They form an obligation of conducting business in compliance with these values, the prevailing laws and regulations and the highest standards of conduct.
The “Best Practices of the PZU Group” describe the PZU Group’s values and the fundamental rules of conduct on the part of employees in reference to the following issues, among others:
- conflict of interest;
- handling sensitive information;
- corruption and gift policy;
- reporting ethical problems;
- rules of cooperation with business partners;
- disclosures;
- and many others.
[GRI 102-16]
| PZU Group’s values | Our promise to the client | Our promise to the employee |
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| Honesty |
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| Innovation |
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| Responsibility |
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Alior Bank abides by the rules of honesty and business ethics in all of the areas of its operations. It applies its “Compliance Policy”, which precisely lays down the rules for adhering to the law, market standards and internal regulations. The actions of Alior Bank as a public trust institution are based on the principles described in the “Code of Conduct in Alior Bank”. They are also enforced at the level of subsidiaries, i.e. Alior Leasing sp. z o.o., Serwis Ubezpieczeniowy sp. z o.o., NCS Bancovo and Alior TFI. The employees of other companies belonging to the Alior Bank Group are employed by the bank; consequently, they are obligated to act in accordance with the principles of the “Code of Conduct”. This document is addressed to employees and the persons through whom the bank conducts its banking activities.
The “Code of Conduct in Alior Bank” is composed of four parts containing the rules of conduct toward clients, employees, business partners, the market and local communities. The Code contains guidelines on applying the principles of professionalism and respect in the workplace as well as the principles of good manners, openness toward diversity and tolerance. Moreover, employees will find information in this document encouraging them to care for the natural environment.
The Code of Conduct in the Pekao Group contains the most important principles applicable to all employees regardless of the position held. It describes the method of conduct in interactions with clients, business partners, representatives of local communities and other stakeholders as well as in relations between employees. In addition, a “Corruption Prevention Policy” is in force in Bank Pekao. It regulates conduct in the event of identifying and preventing potential “acts of corruption”.
PZU Group companies (PTE PZU, TFI PZU, TUW PZUW, PZU Finanse and PZU Centrum Operacji) excluding banks also have principles of ethics for the members of their corporate bodies to follow, i.e. the “Principles of ethics of the management board members in PZU Group companies”, the “Principles of ethics of supervisory board members in PZU Group companies who are not employees of a PZU Group company and who are not bound to a PZU Group company by some other contract of a similar nature” and “Principles of ethics of supervisory board members in PZU Group companies who are employees of a PZU Group company or who are bound to a PZU Group company by some other contract of a similar nature”. The principles of ethics applicable to members of corporate bodies serve the following purposes:
- they ensure that the members of the corporate bodies discharge their functions properly in compliance with the highest standards of conduct;
- they prevent the occurrence of a conflict of interest, in particular by counteracting the use of the position held to reap private gains;
- they specify the ethical standards, values and attitudes by which management board members should be guided.
Highest ethical standards
PZU Group’s ethical culture is developed in observance of the highest standards and in line with the needs of the Group’s entities, consequently taking account of the scale, character and type of their operation and local laws.
The PZU Group furthers its ethical culture by creating systemic solutions at the level of PZU. As the parent company, PZU sets and develops standards of conduct, and then recommends their proliferation to other Group companies (save for the banks that have their own codes of conduct in place). These solutions are implemented in the various companies in keeping with the principle of relevance and suitability. The companies report compliance risk to PZU while respecting legally protected secrets.
The obligation of abiding by the enacted standards pertains to all PZU Group employees without exception.
PZU places great emphasis on instilling an awareness among employees that ethical values and compliance are of equal importance in the company doing business and employees discharging their daily duties.
Actions instilling an awareness of compliance:
- Employee training
Compliance standards are a permanent part of training for new hires in the PZU Group. Employees may participate in additional topical workshops and training sessions regarding its anti-corruption policy, among others. - Internal communication
Every quarter PZU employees receive the Compliance Bulletin, an inhouse magazine devoted to compliancerelated topics. Employees regularly receive Compliance Alerts. They are distributed in the form of e-mail messages to describe planned amendments to the law and new guidelines of national and European supervisory authorities and industry organizations.
Ethics are also a part of compliance risk management on the following bases:
- on a systemic basis – practiced by the Management Board, which is responsible, among other things, for setting the strategy and adopting policies related to compliance risk management and promulgating the adherence to standards of conduct in PZU, and by the Compliance Department which coordinates the compliance risk management process,
- on an ongoing basis – by the managers of various cells and organizational units in PZU in the area subject to their oversight.