“The compliance area and managing the risk of conflicts of interest and corruption are crucial for the overall PZU Group to function on the market. For that reason our employees familiarize themselves with these issues during their first obligatory training sessions and later they systematically develop their knowledge on that subject. The precisely defined rules and processes described in detail help not only catch improper conduct but also minimize the risk of its occurrence in the future”.PZU Group’s policies [Accounting Act]
[GRI 102-11, GRI 103-4, GRI 103-3]
There is zero tolerance for corruption in the PZU Group. The organization’s implemented solutions define the method of corruption risk management, including identification, mitigation and monitoring.
The Group’s companies have in place internal regulations to prevent corruption, including, inter alia, rules for accepting and giving gifts, conflict of interest management, and ethical principles to be followed by members of the company’s statutory bodies. Relative to the entity in question, these rules have been covered by a range of implemented documents, regarding, inter alia, prevention of corruption, whistleblowing, conflict of interest management, and procurement. Those issues are also discussed during internal employee training.
The rules for Group employees to accept and give presents and the rules for registering them have been strictly defined. Presents whose value is lower than the threshold specified in the standards of conduct may be offered or received in the course of customary business practices. Under no circumstances can money or its equivalent be offered or received. Giving and receiving gifts cannot be so frequent, excessive or generous as to represent an actual or perceived risk of conflict of interest or breach local statutory or executive regulations.
Anti-corruption policy
The basic document in the anti-corruption policy is the document entitled “Best Practices of the PZU Group”. They constitute the model for the standards, values and principles for all Group employees and they outright forbid corruption in companies. They obligate employees to act in compliance with the law and defined ethical standards: “We do not tolerate corruption. We act ethically and in accordance with the law when performing our business tasks and cooperating with our business partners”. All of the PZU Group companies implemented the “Best Practices”, except for the Alior Bank Group, which has in place the “Code of Conduct in Alior Bank” and except for the Pekao Group, which has in place its own “Code of Conduct in the Pekao Group”. In turn, LINK4 has in place its “Corruption Prevention Compliance Policy”.
Corruption risk is part of the ongoing management of compliance risk in various areas of activity. PZU has therefore implemented solutions imposing an obligation to identify and assess corruption risk. The 2020 corruption risk assessment confirms that the system solutions work correctly in PZU and that actions aimed at managing this risk were taken with due diligence.
[GRI 205-1]
PZU, PZU Życie, PZU Zdrowie and Tower Inwestycje have in place the “Anti-Corruption Program in PZU and PZU Życie”, which lays down the standards of conduct to reduce corruption risk. The master rules described therein for managing corruption risk form the basis for introducing detailed internal regulations in the various areas of the company’s business. This “Program” aims to uphold the company’s reputation as an honest company in terms of its managerial practices and business activities. The Management Boards of PZU and PZU Życie oversee the execution of this “Program”. Non-compliance with the provisions of the “Program” constitutes a breach of employee duties and is subject to the sanctions provided for in the provisions of labor law. PZU Zdrowie has in place its own the „Anti-Corruption Program”.
According to the rules prescribed by this “Program”, companies conduct business in accordance with the law in an honest manner and counteract any and all forms of corruption, which may be linked to their business. In turn, their employees are obligated to act ethically and in compliance with the law in favor and on behalf of PZU and to avoid factors increasing corruption risk. Employees are prohibited from proposing, promising, giving or demanding any material or personal benefits in order to manipulate a pending decision, including the usage of gratification.
The “Anti-Corruption Program in PZU and PZU Życie” defines the business areas in which corruption risk is potentially the greatest and specifies symptoms of unethical employee conduct. Mechanisms to identify and monitor corruption risk function in those areas of business that are particularly susceptible to corruption risk.
The “Anti-Corruption Program in PZU and PZU Życie” supports prevention and educational solutions encompassing the definitions of unwanted behavior and examples of corruption factors.
Corruption
It is a direct or indirect demand, acceptance, provision or promise to provide a material benefit or a personal favor in exchange for taking or not taking an action in connection with discharging a function in PZU.
Gratification is a form of corruption. It involves making small and unofficial payments or some other types of benefits to procure the accelerated execution of a routine activity, which the party delivering the gratification has the right to receive.
In turn, a bribe, which is also a form of corruption involves giving or receiving a present, loan, fee, award or some other material or personal benefit to or from another person as an incentive for a dishonest or illegal action or breach of trust in the course of the company’s business activity.
Material benefit
This is a material benefit given or received by an employee in connection with his or her position or function in the company net of his or her salary and other benefits due in connection with acting in this function and souvenirs given customarily whose unit value is not subject to personal income tax.
Personal benefit
This is an immaterial benefit augmenting the standing of an employee, his or her loved ones or persons or organizations with whom or with which he or she closely cooperates or cooperated on a professional, business or personal footing.
- transparent process of selecting business partners;
- transparent rules for hiring, promoting and remunerating employees;
- transparent rules for sponsorship and prevention activities.
The “Anti-Corruption Program in PZU and PZU Życie” introduces mandatory, regular and periodic corruption risk assessments. It includes, among other things, corruption risk self-assessment questionnaires conducted among employees, registered notifications of irregularities in specific areas, results of internal inspections and reports of non-governmental organizations dealing with corruption. Intensified educational activities for employees – training sessions, publications and consultations are performed for the purpose of effectively controlling corruption risk.
All PZU and PZU Życie employees have been obligated to familiarize themselves with the Anti-Corruption Program and comply with its provisions and submit the pertinent representations in this respect. In other PZU Group entities in which the anti-corruption program has not been implemented, the potential corruption risk analysis or assessment is carried out as part of the analysis of the notifications or inquiries related to a conflict of interest or accepting or giving gifts.
In the other PZU Group entities, the potential corruption risk analysis or assessment is carried out as part of the analysis of the notifications or inquiries related to a conflict of interest or accepting or giving gifts.
The “Bank’s Security Policy” is in force in the Pekao Group. It constitutes a collection of guidelines pertaining to issues related to the Bank’s security. In addition, the “Official Instructions on Preventing Corruption” directly refer to showing zero tolerance for acts of corruption. They contain clauses on employees using the services of suppliers and business partners, donations to political parties, donations for charitable purposes and sponsoring, receiving and giving presents and other benefits. In turn, the “Official Instructions on Conflicts of Interest” include a model for managing conflicts of interest, the areas in which possible conflicts of interest may appear and the measures for managing conflicts of interest.
Corruption Prevention Officer
To elevate the rank of this area in the Compliance Department in Bank Pekao, a Corruption Prevention Officer has been appointed. Information regarding attempts involving corruption and actions bearing the marks of corruption should be reported to this person.
The “Corruption Prevention Policy in the Bank Pekao S.A. Group” defines the specific tasks of the Corruption Prevention Officer, including the drafting, implementing and supervising of an effective Corruption Prevention Program and conducting the legislative process on the Bank’s internal regulations on preventing corruption.
The Corruption Prevention Officer is authorized to investigate suspicious or factual acts bearing the marks of corruption, including the power to demand that a person suspected of engaging in actions involving corruption must produce documents and to browse through these documents and report such cases in accordance with the contemplated procedure.
[GRI 205-1]
The “Anti-Corruption Program” lays down the standards of conduct to mitigate corruption risk. The rules for managing conflicts of interest and the principles for accepting and giving gifts are in line with the Program.
Management of a conflict of interest
The “Rules for managing conflicts of interest” are in force in PZU and PZU Życie. This regulation aims to ensure professional, reliable and fair treatment of all clients and persons related to the company in a conflict of interest situation. According to this regulation an employee should report a potential conflict of interest to his or her boss and the compliance unit in a given company for that unit to be able to analyze that situation thoroughly from the standpoint of risk.
A conflict of interest may assume various forms. These are usually situations in which there is or may be a discrepancy between:
- the interests of the PZU Group or its affiliates and the interests of a client;
- the interests of a person affiliated with the PZU Group and the interests of the PZU Group.
Rules for managing conflicts of interest are in force in all of the PZU Group companies.
In the Alior Bank Group this document is entitled “Instructions for managing conflicts of interest”. In this document employees will find responses to questions on how a conflict of interest is defined and how its potential and actual outcome are determined and how they should conduct themselves to avoid a conflict of interest. These instructions govern material elements such as the rules for employees to deal with relatives, accept gifts and invitations and conduct gainful activity outside the Group. This document also clearly specifies the rules pertaining to the official ties between relatives while emphasizing the elimination of the risk of nepotism.
In turn, Bank Pekao has implemented the “Rules and Regulations for Managing Conflicts of Interest in Bank Pekao S.A.“. This document specifies the rules for managing conflicts of interest and defines the circumstances that trigger or may trigger a conflict of interest in the activity of the bank. It also describes the means for managing conflicts of interest, among others by defining the rules for remunerating employees so that they do not exert an adverse impact on a stakeholder’s interests and do not eliminate the direct links between the variable portion of remuneration and the business objectives and transferring bank employees to other positions if official reporting lines arise between relatives. Policies and official instructions on conflicts of interest are in force in the Pekao Group’s companies. Containing a model for managing conflicts of interest, the areas in which possible conflicts of interest may appear and the measures for managing conflicts of interest.
Rules for acceptance and giving of gifts
The rules in PZU and PZU Życie regulate in transparent and very detailed terms the categories and types of gifts, including permissible and impermissible gifts and they prescribe the procedure for accepting or offering gifts and the rules for registering gifts. These rules are in force regardless of the position held or function discharged in the company.
We do not accept gifts from clients, business partners or associates if those gifts could:
- compromise objectivity in the decisionmaking of a PZU Group entity or evince the impression of exerting such an impact;
- lead to the emergence of an informal obligation to a given client, business partner or person cooperating with the PZU Group;
- trigger or be able to trigger a conflict of interest;
- be interpreted as compensation for a business favor;
- adversely affect in some other manner the method in which an employee performs his or her official duties or the PZU Group’s interests or image and reputation.
The Best Practices of the PZU Group provide examples of proper conduct.
Question: Within the framework of cooperation with a business partner I have received a ticket to a football game. Can I accept it?
Reply: Yes, provided that you obtain the pertinent consent. Participating in a meeting to cultivate good business relations is not forbidden provided that its intention is not for an employee of the PZU Group to obtain or offer benefits and influence in that manner the ability to make an objective judgment and make decisions. According to the rules endorsed by the company, the occasional acceptance of a ticket to attend a sports event does not constitute a breach of the rules. However, the obligation of notifying the acceptance of this gift in the register of gifts should be remembered.
The procedure for giving and accepting gifts is in force in all of the PZU Group companies.
In 2020 Alior Bank employees reported 164 cases of accepting benefits: gifts, invitations to attend conferences or training courses, tickets, souvenirs, etc., which have been registered in a register designated specifically for this purpose. The vast majority of the reported gifts fell within the permissible limit of PLN 200. In the case of gifts exceeding that value, ordinarily the solution is to earmark that item for charitable purposes, e.g. to give to an orphanage. In the case of invitations to attend conferences or business meetings consent was given if the topic of those events was related to official duties.
[GRI 205-3]
In the entire PZU Group, 265 cases of corruption and fraud were identified in 2020. Three situations were reported in PZU and PZU Życie that may have involved corruption (security incidents). After the legal analysis of these incidents PZU decided not to submit notifications concerning the suspected commission of a crime. 65 cases of corruption and fraud were identified in Alior Bank. One instance of corruption was reported to the law enforcement authorities in the Pekao Group.
Communication and training
[GRI 205-2]
These actions are supplemented by anti-corruption training and campaigns executed in the corporate communication channels, attracting the employees’ attention to the corruption risk.
The training course pertaining to the “Anti-Corruption Program in PZU and PZU Życie” is one of the mandatory training courses for all of the employees in these companies. PZU and PZU Życie employees submit declarations in the HR system that they have familiarized themselves with the “Program” and undertake to adhere to it and also that they are aware of the criminal liability for corruption. Every amendment to the “Program” will necessitate the submission of an updated declaration. 566 employees completed this training course in 2020: all new hires (486 people) in PZU and PZU Życie and people who did not manage to take that training in the previous year (80 people).
Topics concerning conflicts of interest, potentially risky situations and the rules of conduct if they are detected are part of the e-learning training course on compliance: 99% of the employees took this training in 2020. These topics are also discussed during training courses for new employees. All PZU and PZU Życie employees may take advantage of the newly-developed training course on conflicts of interest. It has been available on the internal educational platform since early 2020. In this case employees also submit declarations on adhering to the “Rules for Managing Conflicts of Interest”.
Compliance-related issues are regularly described in the Compliance Bulletin. Employees receive it quarterly by e-mail or in printed form. The Compliance Bulletin plays an educational role - it enriches the knowledge gained during training sessions thanks to the readily understandable manner of presenting information (in the form of tables and figures).
Compliance Alerts, i.e. e-mail messages describing planned changes to the law, new guidelines, communications and decisions made by regulatory authorities as well as court decisions of significance from the vantage point of the business conducted by the Group play an important role in disseminating information. Compliance Alerts are sent to employees in selected areas and several hundred more people who have reported their interest in receiving this type of information. These alerts are critical to procure the company’s compliance with the legal regulations. They make it possible for them to obtain information quickly about the projected changes to the law and the regulator’s expectations and adapt to them on a timely basis.
Employees of Alior Bank, Alior Leasing and Alior TFI have been trained on the procedures for fraud prevention and the rules of ethical conduct. The training sessions pertained, among other subjects, to security policy and compliance risk where conflicts of interest were one of the subjects of interest, as were banking secrecy and the gifts policy. Training sessions were introduced as an obligation for all new hires in Alior Bank.