First of all - awareness

To ensure that the Code is known, understood and respected, we are holding workshops across PGE Group for employees and management. First, we invited colleagues from inside the Group, who became internal trainers for the Code of Ethics. Training the trainers, numerous meetings and discussions to explain objectives, materials, exercises and all other doubts. Finally, the time, involvement and hearts of our internal trainers dedicated to best prepare and conduct training. Currently, we have approx. 100 internal trainers. Trainers conduct training across all business lines and other segments. Workshops are conducted in a very active fashion, where participants talk about what makes honest behaviour easier and more difficult; they meet PGE Group's rules and present their own perception of them.

In addition, in the course of active discussion, they present attitudes that personify our values: Partnership, Development, Responsibility, and propose to introduce specific organisational solutions at their unit or across the entire Group. These conclusions then serve as basis for implementing the best initiatives. These workshops were connected with training in PGE's Good Procurement Practices, conducted by the Purchasing division.

By the end of the first quarter of 2017, Code of Ethics workshops were conducted for approx. 10 000 employees, including over 50% of the Group's management personnel.

Every new employee within the Group undergoes individual adaptive training shortly after starting work at PGE Group companies, where he/she finds out about the existing code, the law and the obligation for employees to react to any potential irregularities. New employees get a chance to learn the details of the Code at adaptive group training called "Turn on the power" (approx. 650 people). These training sessions are conducted entirely by Group employees. 

The Code of Ethics has been distributed throughout the Group in print form, also in English. Furthermore, posters and flyers presenting PGE Code of Ethics values and rules have been put out at locations - facilities and offices.

Additionally, other training was conducted at the Group, in particular training related to combating corruption and preventive counter-intelligence measures. 

Secondly - communication

The Code of Ethics is available to Group employees on the Group's Intranet as well as in paper form. It is also available at the Group's website. The content of the Code has been expanded upon in numerous thematic publications in PGE Group's internal publication "Pod parasolem" and on the Intranet. This content is presented to employees in a cascading manner where they have a chance to discuss values with their superiors and ask them questions. 

If you want to know more about the Code of Ethics of the PGE Capital Group visit our website.

In communications related to the Code of Ethics, employees' personal responsibility for their actions is emphasised in accordance with PGE Group's ethical values and rules expressed in the Code as well as internal regulations, which further detail our processes and procedures. 

Thirdly - combating violations everyday

Adopting the Code and clearly communicating the rules contained therein has a straightforward objective: support PGE Group's Strategy as the most effective and flexible energy group in Poland and to minimise the risk of non-compliance, which could result in penalties or sanctions being imposed or reputation being lost as a result of a failure to adapt to regulations and standards that are stated in law or constitute best practices in this area.   

In order to do this, the following activities are undertaken at Group level:

• Cyclical identification and analysis of existing common law acts and internal regulations.
• Regular identification and assessment of risks related to legal compliance.
• Planning of risk mitigation measures as well as educational and communication activities. This is happening pursuant to PGE Group's Compliance Plan, binding at Group level.
• A compliance assessment is being planned for each of the companies, where respect for existing regulations will be evaluated.
• At the same time, rules for informing suppliers about PGE Group's values and rules and contractual commitments to respect were developed and implemented.
• Implementation of the communication channel for whistleblowers, through which the Group employees may pass information on observed irregularities.
• Thorough clarification of the suspicions and absolute consequences for people who have acted inconsistently with the rules in force.