A culture of complying with the law and ethics - the compliance function (compliance management)

Literally translated, "compliance" means being in accordance with the letter of the law. Acting in line with the law is expected of every employee, and rules of ethics and responsibility for actions towards cooperators, clients or business partners are in effect equally for everyone. PGE Group's Code of Ethics outlines values and rules that are known to most employees even without this document. Unfortunately, having the Code does not guarantee that everyone will respect it. Unethical behaviour of individuals may still take place. So, how do we foster respectful attitudes at our firm? How to demonstrate a complete lack of tolerance for corruption, theft, mobbing and obtaining illicit personal gains? The simplest answer is: repeat the rules as much as possible. All the more so that procedural violations do not have to be intentional. It happens that employees take short-cuts, perhaps not fully realising that they are acting unethically or too easily convincing themselves that they are correct to do or not do something.

Whistleblower

In order to support the prevention and remediation of irregularities, Group employees have the right and obligation to react to them. Above all, they should get in touch with their direct supervisor. Alternatively, they can notify any irregularities or suspicions by contacting the Compliance Coordinator or the Compliance Office. Face-to-face, telephone and email contact is possible. It is also possible to use the whistleblower channel by sending an email to uczciwybiznespge@gkpge.pl. PGE Group protects whistleblowers acting in good faith. 

What happens when our values and rules are not respected

All submissions are verified in terms of likelihood and in order to identify submissions that may be made in bad faith, which luckily rarely happens. Our experience shows that most of them are related to actual instances of events taking place that are in violation of the Company's rules or procedures, which does not necessarily mean an intentional misconduct. After such verification, a decision is made whether additional work is to be undertaken by Compliance (e.g. explanatory proceedings, transfer of case to Audit Department or Security Department). People reporting information are ensured anonymity, particularly as it relates to people inside the Group.

PGE Group's compliance function

The compliance function was established at the end of 2015. The compliance function focuses mainly on supporting and advising business lines, branches and other segments as well as the corporate centre. The Compliance Director at PGE S.A.'s Corporate Centre reports to the Management Board of PGE S.A. and may also report directly to the Audit Committee at the Supervisory Board of PGE S.A. This committee also approves annual Compliance Plans for PGE Group and receives reports on their fulfilment. PGE S.A. also has a Compliance Office.

Business lines, other segments and related parties within PGE Group have their own Compliance Office. In the case of most companies, coordinators have also been appointed at branches. According to guidelines, coordinators report directly to a member of the management board at their respective companies (branch director, respectively). At the same time, PGE S.A.'s Compliance Office and Compliance Coordinators directly cooperate on an operational level.

We also introduced an Overall Compliance Management Procedure for the Group.