Human rights

The Code of Ethics also addresses the requirement to respect human rights in the PGE Group. In doing so, it
refers to the Universal Declaration of Human Rights and the standards of the International Labour Organisation, as well as the Ten Principles of the United Nations Global Compact.

PGE is a member of the United Nations Global Compact, the world’s largest United Nations initiative for sustainable business, with more than 24,000 organisations actively engaged in working on the global implementation of the UNGC Ten Principles in the areas of environment, human rights and corporate governance.

The PGE Group communicates its approach to human rights issues to suppliers and other business partners already before a relationship is established. Furthermore, in accordance with the PGE Capital Group’s Anti-Corruption Policy, contractual clauses are applied obliging Business Partners to observe at least the minimum ethical standards set out in the Code of Conduct for Business Partners of PGE Group Companies, explicitly citing the requirement to respect human rights.

The PGE Group’s top management is responsible for human rights compliance issues, while the human capital management area is responsible for organisational coordination.

The validity of the training is 3 years. After this period, it is repeated as refresher training. It is planned to increase the frequency of training on the Code of Ethics and on anti-corruption regulations and to introduce an annual cycle of training sessions.

On 19 December, the Management Board of PGE Polska Grupa Energetyczna S.A. passed a resolution concerning the adoption of an update of the Code of Ethics of the PGE Capital Group, setting its effective date for 1 February 2024 (in parallel to the changes to the Code of Ethics described below, the same resolution updated the Code of Conduct for Business Partners of PGE Capital Group Companies).

The introduction of changes to the content of the PGE Capital Group Code of Ethics and the Code of Conduct for Business Partners of PGE Capital Group companies is primarily related to regulatory (current and upcoming) requirements on ESG issues, which have an increasing impact on the assessment of PGE Polska Grupa Energetyczna S.A. and the PGE Capital Group by the external environment and the related needs:

• to pay more attention to the impact of our activities on the climate, the environment and human rights,
• to intensify and operationalise the activities of PGE S.A. and the PGE Capital Group in support of the sustainable development of the PGE Group,
• increasing the attentiveness and scope of value chain management, including supply chain management,
• to update information on the system in place in the PGE Capital Group for reporting and resolving potential non-conformities.

The changes made to the Codes take into account the following aspects:

• the diversity policy, human rights, including children’s rights, and other PGE Group policies,
• the principles of sustainable development,
• the broader coverage of health and safety and environmental issues, including the circular economy,
• the information and consultation obligations towards employees,
• follow-up actions to be taken in the event of possible breaches of the Codes.

On this occasion, the content of both documents was also comprehensively reviewed by the organisational units of PGE S.A. and editorial changes were proposed.

Mechanisms for seeking advice and raising concerns

The structure of the compliance management system implemented in the PGE Group takes into account the functioning of units responsible for compliance issues in PGE S.A. and in PGE Group companies.

One of their roles is to consult on ethical concerns related to compliance with internal regulations such as:

Code of Ethics

Code of Conduct for Business Partners

Anti-corruption regulations (including, for example, those relating to the existence of a conflict of interest or a gift policy)

The Code of Ethics imposes a reporting obligation on any person acting for and on behalf of the PGE Group, who is aware of an irregularity resulting in a breach of the law, the internal regulations or the Code of Ethics of the PGE Group. Non-compliance can be reported anonymously.

Individuals who report non-compliance are granted the whistleblower status and are protected. A whistleblower may not face retaliation from employees, other persons or the employer for reporting a non-compliance event. A whistleblower can be anyone, in particular an employee, consultant, contractor, subcontractor, supplier. This is a person who reports non-compliance, information on suspicion or occurrence of a non-compliance incident the consequences of which may be detrimental to PGE Group companies. It is particularly important to report criminal and corrupt activities, violations of employee rights or conflicts of interest.

The wide range of possible forms of whistleblowing and the possibility to report non-compliances, including anonymously, also facilitates communication for people who fall into a vulnerable group (e.g. people with disabilities), for whom it may be more difficult to take advantage of the opportunity to report in person. People who fall into vulnerable groups can make reports without fear of being stigmatised due to the disclosure of non-compliances. Reports are reviewed, among others, by the Compliance Department Director. The system allows for the reporting of both the risk of a non-compliance (alert system) and actual non-compliances that have already occurred. The designated channels for reporting problems or violations of the law or the corporate values and principles are also available for questions in the area of compliance.

In addition, a separate email address for questions or concerns is indicated on the corporate website: OpiniaCompliance.pgesa@gkpge.pl. This address can be used by both employees and all external stakeholders of the PGE Group, including contractors and subcontractors.