Ethics and compliance

Within the Management Board of PGE S.A., its President, Wojciech Dąbrowski, is in charge of the compliance area. PGE Group has an organisational unit dedicated to the performance of compliance tasks. At PGE S.A., this is the Compliance Department, whose director, acting in the capacity of Compliance Officer, reports directly to the Audit Committee of PGE’s Supervisory Board. PGE Group companies and branches appoint Compliance Coordinators who report to the director of PGE S.A.’s Compliance Department with respect to the performance of their tasks. These persons are also provided with an appropriate direct reporting path to the Management Board of their respective companies. PGE Group currently has 52 Compliance Coordinators.

Employees and other stakeholders have the right and obligation to report incidents of non-compliance, including suspected or actual irregularities the consequences of which can be detrimental to PGE Group companies. It is particularly important to report criminal and corrupt activities, violations of employee rights or conflicts of interest. A person reporting irregularities is called a whistleblower. Anybody can be a whistleblower, in particular an employee, consultant, contractor, subcontractor or supplier.

Incidents may be reported in several ways, including a notification sent to:

• immediate superior,
• relevant compliance unit,
• the email address uczciwybiznespge@gkpge.pl

• using the hotline at: + 48 22 340 12 02
• and by post to the Director of the Compliance Department at the following address: ul. Mysia 2, 00-496 Warsaw, with an envelope marked as “for the attention of Compliance Officer,” also 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.

The main document in the area of ethics and compliance is the PGE Group Code of Ethics, which constitutes an overarching declaration and basis for other internal regulations and guidelines. The document describes basic ethical values and standards which the organisation expects from all employees and other persons performing work for PGE Group. The Code indicates and defines common key values and ethical principles of PGE Group.

PARTNERSHIP

• means employees’ identification with PGE Group and the resulting cooperation
• means effective and creative cooperation leading to synergies in every area of activity – for the benefit of customers, owners, employees and business partners, which results from good cooperation among companies as well as between individual employees and teams
• Partnership means relations based on mutual respect

DEVELOPMENT

• means continuous improvement of people, organisations, processes and technologies
• means creating conditions for the introduction of innovations and active search for new solutions
• development requires the courage to make changes and create new realities

RESPONSIBILITY

• means taking care of the country’s energy security, the company’s sustainable development and the company as a good workplace, as well as maintaining the highest standards of occupational health and safety
• means dependability of both the organisation and all of its employees. It is integrity in every activity undertaken by PGE Group

The Code of Conduct for Business Partners of PGE Group Companies is a tool for communicating requirements regarding operating standards to suppliers and contractors of PGE Group companies. This document presents in a transparent way the minimum expectations from business partners of PGE Group companies in terms of ethics and compliance with the law. One of the principles of conduct set out in the Code of Ethics reads as follows: “We do not tolerate corruption or dishonest behaviours”. In order to implement this principle, the PGE Group Anti-Corruption Policy has been implemented, which sets out rules for PGE Group companies with respect to counteracting corruption, defines the basic terms, indicates which activities or behaviours are proper and acceptable in business contacts, regulates the issue of business gifts and invitations to trips and events (the so-called rules of hospitality). The policy also sets out instructions on how to act in the event of irregularities.

Besides codes and policies, PGE Group has also adopted regulations defining how the compliance management system is organised. These are:

• Regulations of Compliance Management at PGE Group
• General procedure for reporting and handling non-compliance incidents at PGE Group and for protecting whistleblowers

PGE Group’s activities are consistent with the Universal Declaration of Human Rights, standards of the International Labour Organisation and obligations arising from the United Nations Global Compact. The Group conducts its operations with respect for the right to dignity, freedom of association, freedom of opinion, freedom of expression and privacy.

Human rights issues are addressed in a number of internal documents and procedures. One of the most important is PGE Group’s Code of Ethics. Risks related to compliance with human rights, such as discrimination in employment, mobbing and harassment, child labour, “black market” employment, employment in dangerous conditions, are eliminated by using indefinite full-time employment contracts as the basic form of employment, ensuring the highest standards of organising a safe working environment, objective and non-discriminatory criteria of hiring and promoting employees. Respect for diversity is understood in terms of race, gender, sexual orientation, age, culture, marital status, as well as religious and political beliefs, freedom of membership in social and professional organisations. PGE also fulfils all obligations related to the protection of health and life in the workplace. The same standards of observing human rights are expected of the business partners of PGE Group companies; therefore, contracts with business partners include ethical clauses regulating this issue.

PGE Group companies hold regular training sessions on compliance and ethics issues, as well as training for employees who are newly hired or return to work after periods of long absence.