Avoiding conflicts of interest
A significant factor that raises the risk of adverse events is a conflict of interest. The PGE Group’s internal regulations define what it is and who can be in this type of conflict. Each employee or any other person acting for and on behalf of PGE Group ompanies makes a declaration of the absence of any conflicts of interest and undertakes to provide information if such a conflict should arise in the course of fulfilling their official duties.
The prevention of conflicts of interest serves to ensure that decisions in PGE Group companies are made on the basis of objective criteria, in a transparent manner and in accordance with the best interests of a particular PGE Group company.
The principle of avoiding conflicts of interest is implemented in a comprehensive manner.
It covers employees and other persons who act for and on behalf of PGE Group companies on a basis other than an employment contract up to the level of top management.
Employees submit declarations of the absence of any conflict of interest as soon as they start working for PGE. With regard to other persons, an appropriately dedicated part of the declaration is applied or, alternatively, appropriate contractual provisions are used, which are incorporated in the templates of contracts of mandate or contracts for specific work. By signing their declarations, all signatories simultaneously undertake not to engage in activities leading to a conflict of interest, and to inform their supervisor and the company’s compliance function in writing of any concerns in this respect or of the occurrence of such a situation. They also confirm their acceptance of the instruction as to liability that attaches to any failure to comply with the obligations arising from the declaration made. Enquiries regarding conflicts of interest, including, for example, concerns about the existence of conflicts of interest, are recorded by the companies’ compliance function in order to ensure transparency in the analyses, recommendations and monitoring of eventual measures taken in individual reported cases. For contracts relating to services that PGE S.A. has assessed as most exposed to the risk of conflicts of interest, additional dedicated contractual clauses are used. In 2023, the risks of conflicts of interest for compliance coordinators combining their function with other tasks in PGE Group companies were additionally analysed and guidelines were issued in this respect.