Caring for high standards

The PGE Group raises its employees’ awareness of applicable laws, regulations and internal standards.
Everyone is required to be aware of the current regulations and agreements governing their everyday duties at the workplace. Each employee is responsible
for acting in accordance with the law, the internal regulations in force in PGE Group companies and the ethical standards described in the PGE Group Code of
Ethics.

The role of immediate superiors is to oversee the work of subordinate staff with respect to the above issues. Internal regulations applicable both in PGE S.A. and across the PGE Group are monitored on an ongoing basis to ensure compliance with the law. In the event of a change in the law that affects the content of an internal regulation, the owner is obliged to amend it. Ongoing communication and training activities aim to build and raise employees’ awareness of the need to regularly update their knowledge of the applicable law.

How we manage compliance

There is ongoing communication within the PGE Group on issues relating to compliance with the law and ethical standards. The contents of the PGE Capital Group Code of Ethics, as well as other policies of the compliance area, are available to employees, business partners and other stakeholders – in both Polish and English – on the website www.gkpge.pl and on the websites of individual PGE Group companies. Information materials, including posters, are available at each company. They provide information on the PGE Group’s values and rules of conduct, as well as channels to report non-compliances.

The full content of the following documents:

• The Code of Ethics of the PGE Capital Group,
• The Anti-Corruption Policy of the PGE Capital Group,
• The Code of Conduct for Business Partners of PGE Capital Group Companies,
• The Policy of Diversity in the PGE Capital Group,

is available at:

https://www.gkpge.pl/grupa-pge/o-grupie/compliance (in Polish)
https://www.gkpge.pl/en/pge-group/about-group/compliance (in English)

Communication of issues relating to compliance with the law and ethical standards

Communication activities are one tool for educating employees. Developing their awareness of the importance of acting with integrity to build the organisation’s value and to achieve its business goals influences employees’ subsequent choices. Thanks to their knowledge, in their daily activities and decisions, they take into account factors related to compliance with not only the law, but also ethical standards.

Extremely important in this context is the role of managers as leaders demonstrating, through their behaviour, decisions and attitudes, actions in line with the values and principles set out in the PGE Capital Group Code of Ethics and Anti-Corruption Policy, promoting them among their employees.

Communication activities related to the compliance area have been carried out in the PGE Capital Group since 2016, i.e. since the adoption of the PGE Capital Group Code of Ethics. In 2023, communication activities included such undertakings as providing information on the intranet, on, among other things, international celebrations of the World Integrity Day or the International Anti-Corruption Day, publishing articles in the corporate monthly “Under the Umbrella” addressed to employees of the PGE Capital Group, organising information campaigns using films, webinars or interviews.

In 2023, the communication activities carried out in the PGE Group focused on the following themes:

Compliance with the law (including the sanctions regime, as mentioned below),

The manager’s role in ensuring the organisation’s compliance

Building an organisational culture based on fairness and integrity

The role of the whistleblower and the need to respond to situations of inappropriate behaviour

Avoidance of conflicts of interest

Issues related to cooperation with business partners (examining business partners or the need to include compliance clauses in contracts)

A significant amount of attention was also given to further building an organisational culture fostering compliance, i.e. a culture based on honesty (integrity) and geared towards open communication and responsiveness (speak-up culture).

Due to the ongoing war in Ukraine, communication activities placed great emphasis on issues relating to sanctions imposed on Russia. Compliance with these sanctions constituted an important obligation of PGE Group companies.

A series of meetings on the most important developments in the area of national and international legal regulations are held on an ongoing basis; they also provide information on the various stages of the ongoing legislative process.

Ongoing activities in the area of compliance in the PGE Group  

The objective of the compliance area is to support the management boards of PGE Capital Group companies in the implementation of uniform operating principles in the PGE Capital Group, as a result of which the organisational culture supports compliance with the law and ethical principles as well as activities in line with sustainable business principles.

This objective is pursued through the following:

Ensuring support in the implementation of the PGE Group strategy, taking into account the applicable laws and internal regulations

Providing education through training and communication activities on issues related to compliance with the applicable laws and internal regulations on corporate governance and attitudes of integrity

Supporting the implementation of transparent processes that ensure that non-compliances and rule violations can be identified, explained and remedied promptly, and actions can be taken to prevent them from occurring in the future

Minimising the risk of non-compliance that may result in penalties, sanctions, or loss of reputation and credibility as a result of non-compliance with regulations and standards that are sanctioned by the law or constitute the best practices in the field

In 2023, the Compliance Department of PGE S.A. continued and improved the existing practice of the compliance management process in the form of conducting cyclical training on the PGE Capital Group Code of Ethics, anti-corruption regulations and compliance communication, as well as executing the core tasks of the process, i.e. identification of laws and regulations, identification and assessment of compliance risks, compliance assessment and cyclical reporting.

The effectiveness of these activities is evaluated regularly and improved as necessary. Ongoing monitoring of the implementation of follow-up measures recommended during compliance-related investigations continued in 2023.

Compliance assessments were carried out in individual PGE Group companies with regard to the following: implementation of the compliance management process, principles of fair business and ethics, respect-based activities (human and employee rights), personal data protection, anti-corruption, conflicts of interest, relations with business partners, anti-money laundering and countering the financing of terrorism (AML/CFT).

In selected PGE Group companies, a compliance assessment also covered the application of fair competition principles and consumer protection issues.

As of 1 July 2023, as a result of the centralisation of accounting services in the PGE Group, PGE S.A. started to provide bookkeeping services and therefore obtained the status of an obliged institution as defined by the provisions of the AML/CFT Act of 1 March 2018. In order to ensure that PGE S.A.’s activities comply with the provisions of the Act and to implement an anti-money laundering and counter-terrorist financing (AML/CFT) system, an AML Office was established on 1 June 2023. Amongst other things, its task is to develop and update internal regulations and guidelines on anti-money laundering and countering the financing of terrorism.  The Office also supervises their implementation by other PGE S.A. units responsible for the provision of bookkeeping services. The AML Office also conducts audits, monitors the implementation of audit and post-audit recommendations, develops and updates risk assessments, develops training materials and conducts AML and terrorist financing training at PGE S.A.

The compliance management system is being continuously improved. In 2023, the approach on how to implement this system in project companies was standardised and the Corporate Centre’s (PGE S.A.) guidelines on compliance structures were updated, among others, with regard to the requirements for the competencies of compliance coordinators and the avoidance of conflicts of interest in connection with the fulfilment of coordination duties.