Cooperation with contractors

PGE’s approach to building business partnerships is set out in the PGE Capital Group Code of Ethics. The Code of Ethics was used as a basis for the development of the Code of Conduct for Business Partners of PGE Capital Group Companies. Every contractor cooperating with the PGE Group is obliged to be familiar and comply with this document.

The Code of Conduct for Business Partners of PGE Capital Group Companies

Furthermore, the Code takes into account the requirements arising from the guidelines of the “Recommended standards for a compliance management system with respect to counteracting corruption and a whistleblower protection system in companies listed on the markets organised by the Warsaw Stock Exchange” and the internal rules in force in the PGE Capital Group, including the gift policy and the possibility to report factual or suspected violations.

The Code of Conduct for Business Partners of PGE Group Companies was adopted at the level of top management by resolutions of the management boards of individual companies belonging to the Group.

Maintaining corporate governance in the purchasing process

An important part of the systemic approach to the purchasing process is, among other things, the requirement to use clauses such as employment clauses in contracts with contractors, taking into account the specificities of certain contracts such as contracts for the provision of security, cleaning, maintenance or construction services. The requirement to employ people on the basis of an employment contract is aimed at ensuring the key rights for those who perform works for the benefit of the PGE Capital Group and particularly their protection under the generally applicable law.

The condition for starting cooperation between a partner and the PGE Group is the partner’s verification with regard to the absence of arrears in payments under the law (social security, taxes), possession of appropriate insurance, permits, certificates, as well as, among other things, identification of the beneficial owner or verification of the contractor on national and European lists of persons and entities subject to sanctions, against which measures are applied, as referred to in the Act on Special Solutions to Counteract Supporting Aggression in Ukraine and to Protect National Security.

The PGE Group minimises risks with regard to the objects and subjects of sanctions imposed on Russia as a result of the armed conflict in Ukraine by verifying business partners and subject matters of contracts in order to exercise due diligence through a developed verification mechanism. The guidelines created for this purpose cover purchasing processes and processes for establishing business relationships, including entering into contracts. They are binding for all PGE Group companies and form the basis for fair, reliable and safe cooperation with business partners. Cyclical activities, in the form of employee training, monitoring of legal conditions, introduction of uniform standards and patterns of conduct in the PGE Group, constitute the basis for due diligence.

At PGE S.A., training was conducted in 2023 for selected groups of employees regarding the verification of counterparties vis-à-vis sanction lists. The training took place in an online format.

Unified purchasing process in the PGE Group

Standards in the planning and purchasing process as well as the selection of contractors are set out in the PGE Group’s General Purchasing Procedure. The procedure unifies the purchasing process in the PGE Group. Certain companies are also obliged to comply with the public procurement regulations. A set of recommended attitudes and principles to be followed by employees and potential business partners during tenders is set out in the Good Purchasing Practices, developed in two language versions (Polish and English) and including, among other things, the anti-corruption rules in force in the PGE Capital Group. One of the principles is: “no gifts”, which is binding for employees initiating a purchasing process (submitting a purchase application), members of committees and all persons participating in the process and persons performing contracts concluded as a result of the purchasing process.

Prior to the final decision on the selection of a contractor, a proper analysis and evaluation of the submitted documents is carried out to determine whether the supplier meets the requirements set out in a given procedure.

Common purchasing system for PGE Group companies

The PGE Capital Group Purchasing System includes a Help Desk for contractors. Help Desk consultants provide technical support, for example when registering with or logging into the purchasing system, navigating the system, as well as the OnePlace Platform, where potential contractors who wish to participate in tenders need to register. Consultants also provide technical assistance for participating in electronic auctions.

The implementation of the purchasing system has influenced cost optimisation, as well as increased automation of purchasing processes.