Whistleblowing System

[GRI 102-17]

In all Group companies, Polish and foreign alike, separate whistleblowing procedures are in place. Employees are advised of the prevailing standards of conduct, inter alia at onboarding training for new hires, during e-learning and during on-site and online training courses. A new mandatory e-learning compliance training course was implemented in 2020 for all employees on PZU and PZU Życie’s internal educational platform.

The Whistleblowing System functions in PZU and PZU Życie. It allows employees and entities cooperating with PZU to report irregularities of an ethical nature. Information may be transmitted in name or anonymously. In every instance confidentiality, discretion and protection of personal data are guaranteed. An employee who reports a potential irregularity in good faith is not at risk of any sanctions; nor does he or she incur any consequences pertaining to his or her employment relationship due to that report. The Whistleblowing System supports the application of PZU’s ethical standards as cited above and the management of the accompanying risks.

Reports transmitted by clients are subject to examination in accordance with separate internal regulations defining the organization of the complaints handling process.

In 2020, roughly 100 suspected irregularities were reported in PZU and PZU Życie, which confirms that the Whistleblowing System actually functions. All reported cases were recorded in the register and examined in accordance with the applicable the „Whisteblowing Procedure”, and if necessary, with other internal regulations.

Whistleblowing Procedure

Employees learn about the “Whistleblowing Procedure in PZU and PZU Życie” at mandatory training sessions on compliance available on the internal educational platform, among other places. It is also discussed at training sessions for newly hired employees. Information concerning the standards of dignity, including precisely how to report irregularities is also regularly disclosed to external entities cooperating with PZU, among others, to agents and business partners.

In accordance with the “Whistleblowing Procedure in PZU SA and PZU Życie SA” all of the aforementioned information pertaining to irregularities and fraud may be reported using the following channels of communication operated by the Compliance Department:

• dedicated hotline and fax; 
• traditional mail to the address of the compliance unit; 
• dedicated e-mail addresses; 
• dedicated form;  
• in person: directly to an employee of the compliance unit.

Thanks to the various forms of contact with the compliance unit an employee may file a report in the most convenient form and time 24 hours a day, 7 days a week.

In accordance with the “Procedure” in force, Compliance Department employees run the proceedings on reported irregularities in PZU and PZU Życie. The person conducting a given case coordinates the actions taken during the explanatory proceedings; he or she also analyzes the factual circumstances and the legal status specified in the notification.

The person overseeing the Compliance Department is notified in every instance of the outcome of the proceeding concerning cases of significant importance to the company’s interests, while if the notification pertains to that person – then the President of the Management Board of the company is notified. The execution of the recommendations given after completing proceedings is subject to monitoring by the Compliance Department and is reported to the company’s Management Board and Supervisory Board as part of regular reporting on compliance risk.

The “Whistleblowing Procedure in PZU SA and PZU Życie SA” will be adjusted to meet the requirements regulated by the new domestic regulations. According to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law, this harmonization at the domestic level is supposed to take place by 17 December 2021, while the implementation in organizations should take place in accordance with the deadline specified in domestic regulations.

The companies belonging to the Group have independent mechanisms for reporting information concerning the suspicion, possibility or occurrence of irregularities or abuse. However, the basis for their creation was linked to the rules in force in PZU and PZU Życie. Therefore, similarly, the employees of these entities learn about the whistleblowing procedure during training courses, while cases are examined by the compliance unit.

PZU LAB, PZU Pomoc and Armatura Krakow have in place the “Rules for Classifying, Documenting and Reporting Irregularities Detected by the Internal Control System”. This regulation is supposed to provide for homogenous standards of conduct if irregularities are identified that affect the achievement of targets.

The “Whistleblowing Policy in Bank Pekao S.A.” is an expression of Bank Pekao’s engagement in promoting corporate culture that supports ethical behavior.

The purpose of the “Whistleblowing Policy in Bank Pekao S.A.” is to create safe channels for communicating about practices observed in the bank that are inconsistent with the prevailing law, internal regulations, unfair and unethical or unjustified suspicions about their occurrence and ensure that the reported problems are accepted, analyzed and duly managed, while the person reporting them in good faith will be protected against vengeance. 14 violation reports were filed in the Pekao Group in 2020 using the whistleblowing mechanism, with 8 of them in the bank itself. None of these cases was not an instance of corruption substantiated to such a degree that it was reported to the law enforcement authorities. Nor were there any confirmed cases of failing to adhere to the rules on how to act when it comes to ethics.

The bank’s subsidiaries have in place internal procedures regulating the process of reporting violations, e.g. Pekao Bank Hipoteczny has in place the “Violation Notification Policy”, Pekao Investment Banking has its “Violation Notification Procedure” and Pekao TFI has devised its “Unacceptable Conduct Disclosure Policy” and its “Procedure for Anonymously Reporting Violations”.

Alior Bank attaches enormous importance to properly organizing the whistleblowing system so that employees may easily and without any concerns transmit information or share their doubts. Therefore, it affords them the opportunity to avail themselves of many channels of communication for this purpose. A notice may be reported orally, in writing or by e-mail to dedicated e-mail addresses, or directly to Members of the Management Board or of the Supervisory Board. The adopted whistleblowing system facilitates the maintenance of anonymity. The bank absolutely rules out the application of any repressive or discriminatory means or any other unfair treatment against an employee who has submitted a whistleblowing report and it also ensures confidentiality if the whistleblower reveals his or her identity or if it is possible to ascertain his or her identity. The bank also has in place its “Policy of creating a workplace free of undesirable behaviors in Alior Bank S.A.”, which additionally regulates the question of reporting irregularities in the case of undesirable behaviors such as mobbing, discrimination, harassment and sexual harassment.

In all of the PZU companies in the health segment a compliance regulation package has been implemented, comprising, among others, a whistleblowing procedure.

PZU’s foreign companies also have whistleblowing systems in place. Violations are reported there by e-mail, in writing or in person to a compliance unit employee.

In 2020 there was a total of 55 identified breaches of the rules of conduct pertaining to ethics in the PZU Group. 35 cases of irregularities were confirmed in PZU and PZU Życie under the Whistleblowing Procedure in connection with the violation of the standards in force in PZU and PZU Życie, also including violations of ethics, with 29 of these cases pertaining to agents and other sales intermediaries.

Depending on the nature of the case, the relevant organizational structures have taken appropriate management actions, including, inter alia, instructing the agent, reminding about applicable internal regulations, including standards of conduct, training selected areas. 16 cases transpired in Alior Bank and 4 in the Pekao Group. As a result of these cases, the following sanctions were applied: disciplinary talk, transfer of the employee to a different entity, termination of the employment contract. In addition, Alior Bank:

• gives warnings to employees:
• issues recommendations for the HR Business Partner to work with Managers on building positive relations with the team.
• supervises how employees discharge their business duties;
• administers the HMM questionnaire (Harvard Manage Mentor) in the unit managed by the Manager to whom the report pertains.

Despite the independence of the whistleblowing systems, the structures operate efficiently and effectively. Reports summarizing the risks and breaches are presented to the management boards of individual Group companies.