The PGE Group, as a responsible provider of services to its customers and consumers, operates on the basis of internal procedures, regulations, and Polish and international law. In its actions and regulations, the PGE Group also takes into account commonly applicable standards and regulations, thereby observing all rights related to proper customer service and the observance of human rights.
The regulations directed to the companies are developed with consideration of the Compliance Programme of PGE Dystrybucja S.A., whose objective is to ensure non-discriminatory treatment of users of the distribution system. Monitoring is carried out by the appropriate organisationalunits of PGE S.A.
The process of implementing procedures and policies is monitored through periodic reporting and operational meetings.
The PGE Group has adopted general policies related to managing and remedying the negative effects of material impacts, as well as the risks or opportunities associated with consumers and end users, as well as those specifically related to specific subject areas. General policies, regulations, and procedures at the central level, binding within the PGE Group companies, are adopted by the Management Board of PGE S.A.
The key management solutions within the PGE Group, forming general policies further specified by detailed sectoral regulations, include:
Retail sales and customer relations management policy in the PGE CG
This policy defines the rules for cooperation between PGE CG companies engaged in retail sales and responsible for relationships with retail customers and the Corporate Centre represented by the organisational unit in charge of sales and customer relations at PGE S.A. It describes the objective, scope and method of managing the area of retail sales and customer relations, and effective management in this area across the PGE CG. It sets out the roles, tasks, and responsibilities of the entities concerned. Its objective is to define the operating rules of the retail sales area and retail customer relations and to ensure effective management thereof. It specifies that the business owner of customer relations within the PGE CG is PGE S.A., as the parent company of the Group, which delegates operational activities in this area to individual PGE CG companies. Their customer-related activities are supervised and coordinated by the Corporate Centre. The management boards of PGE CG companies are responsible for executing activities in the area of sales and customer relations.
General Procedure for retail sales and customer relations management in the PGE CG
This procedure defines the rules for functioning in the area of product implementation, sales, and customer service in the PGE CG on the Retail Market. Its aim is to describe the rules of cooperation between PGE Group companies in the retail market area, particularly in the areas of developing new products, product implementation for sale, conducting sales processes, after-sales customer service, and strategic organisational and process-related projects.
General Procedure for cooperation between PGE CG companies and the Corporate Centre in the field of consumer rights protection
This procedure defines the principles of cooperation between PGE CG companies serving consumers and the organisational unit responsible for sales and customer relations at PGE S.A., with the aim of minimising the likelihood of risks arising in the area of consumer rights protection and any resulting effects. The procedure covers: general consumer rights protection principles applicable in the PGE CG, the necessary scope of regulations regarding the consumer rights protection process, and the rules of cooperation between the Corporate Centre and the PGE Group companies.
Additionally, issues concerning customers and consumers have been addressed in other regulations adopted within the PGE CG, including:
One of the key documents concerning customer relations (including with consumers) is the PGE CG Code of Ethics. One of its principles is: we are here for our customers, which outlines the approach to customer interaction within the PGE Capital Group. Actions taken to deliver products, services, and solutions must meet customer expectations in terms of quality, safety, and care for the climate and natural environment. Information on the Code of Ethics in relation to minimum disclosure requirements is provided in section G1 of this Statement.
Information on the Human Rights Policy in relation to the minimum disclosure requirements is provided in section S1 of this Statement.
Information on the Code of Conduct for Business Partners of PGE CG companies in relation to minimum disclosure requirements is provided in section G1-1 of this Statement.
Within the framework of the Code of Ethics and the Code of Conduct for Business Partners, the PGE Group takes into account issues related to human rights, relevant from the perspective of consumers and end-users, obliging the PGE Group and its business partners to respect and uphold them. They include control processes and mechanisms that monitor compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. In cooperation with consumers and end-users, PGE Group companies provide information about the costs and methods of using the products and services they offer.
Where applicable, they make available in writing a set of rights to which consumers are entitled. Customers are informed about options and procedures for lodging complaints, which are handled in accordance with applicable deadlines and standards. Companies offer their customers the possibility of out-of-court dispute resolution. They also conduct educational campaigns to promote the safe use of the services provided. Particular care, grounded in legal provisions, is shown towards vulnerable customers, who may benefit from special treatment, e.g. in the debt collection process or when addressing outages. Any person associated with the organisation (including customers), who becomes aware of irregularities, may report such events through the PGE CG’s incident reporting system, including the risk of irregularities or misconduct in the Group’s operations. Under the incident and non-compliance management system implemented in the PGE CG, there are several reporting channels (including an online form, a dedicated email inbox, traditional correspondence, and a dedicated telephone number), and the option to submit a report as a Whistleblower. During the reporting period, no breaches of the aforementioned guidelines concerning consumers or end users in the area of human rights were identified in the PGE CG’s operations or value chain.
Information on the reporting channels is included in section G1-1 of this Statement.
The Code of Ethics, Human Rights Policy, and Code of Conduct for Business Partners of the PGE CG companies are publicly available on the website www.gkpge.pl.
Among the specific policies referring to individual thematic areas, the following may be listed by topic:
The issue of managing material impacts as well as risks and opportunities relating to privacy in the context of customer relations has been regulated, due to the nature of the services provided, in internal procedures concerning personal data protection. The aim of these actions is to ensure data security and thereby the privacy of consumers and end-users. Issues related to cybersecurity are described in the section ‘Health and safety / Security of a person‘.
The approach to personal data protection is consistent across all PGE CG companies. It is governed by adopted policies and procedures within the Group, including:
General Procedure – Guidelines on personal data protection in the PGE CG.
The guidelines are intended to establish uniform rules for data processing within the PGE CG, in compliance with legal requirements. These guidelines define documentation standards, rules for cooperation with supervisory authorities, and the assurance of privacy (privacy by default and privacy by design). These policies apply to PGE CG companies, their management boards, employees, administrators, collaborators, contractors and individuals whose data are processed within the PGE CG. The guidelines also specify the tasks of the Data Controller and the Data Protection Officer, as well as methods for building awareness of safe data processing. Information with regard to the minimum disclosure requirements is provided in section S1 of this Statement.
Regulations – Structure of the Data Protection area in the PGE CG
An extension of the Guidelines is the Regulations – Structure of the Personal Data area in the PGE CG. It covers a scope of entities analogous to that in the Guidelines. Its aim is to ensure a coherent organisation of the personal data protection area within the PGE CG through the establishment of a group of experts to develop recommendations for PGE CG entities, leading to the continuous improvement of the personal data protection standard in the PGE CG – the DPO Group. The aim of the regulations is also to standardise solutions in the field of data protection and minimise the risk of personal data breaches while maintaining the required quality standards and interests of the PGE CG, as well as compliance with data protection laws, particularly the independence of PGE CG companies as data controllers.
With regard to health and safety as well as security of a person, i.e. the management of identified material impacts, the PGE CG has implemented a security management policy for the physical protection and technical safeguarding of the PGE CG’s assets and those of its companies, upon which the personal safety system is built.
Security management policy for physical protection and technical safeguarding of PGE CG and company assets
The purpose of the policy includes enhancing the effectiveness and efficiency of business process control and reducing risks. The policy is one of the elements that ensures the security of electricity and heat supply, thereby ensuring safety for, among others, end users, customers, and public utility entities. The security management policy for physical protection and technical safeguarding of PGE CG and company assets constitutes the foundation upon which the personal safety system in the PGE CG is built. Based on it, companies adopt internal regulations.
From the perspective of the continuity of the energy market, the reliability of ICT systems is essential. Their importance will grow due to the digitalisation of the economy, including the production, transmission and management of energy consumption (and energy mix) at the level of the energy system and individual consumers. The PGE CG attaches great importance to the systemic regulation of cybersecurity matters by introducing central regulations.
General ICT Security Procedure
This procedure ensures consistent rules for the operation of ICT systems and the corporate network, minimising the risk of unauthorised access or system failure and detecting unauthorised actions. It includes rules for managing ICT systems, data protection, and the rights and responsibilities of the Data Manager and Administrator.
General Procedure for Cybersecurity Incident Management in the PGE CG
Supplementing the General ICT Security Procedure is the General Procedure for Cybersecurity Incident Management. Its purpose is to ensure effective management of cybersecurity-related incidents in the PGE CG, in particular: the effective and swift detection and response to cybersecurity incidents, thereby limiting their negative consequences as much as possible, identifying the causes of incidents and the perpetrators, and undertaking corrective actions and mitigation measures.
Privacy protection policies apply to PGE Group companies, their management boards, employees, administrators, collaborators, contractors, third parties and individuals whose data are processed by the PGE Group (including consumers and end-users).
The issue of managing significant impacts as well as risks and opportunities in relation to transparent and responsible communication has been addressed, among other things, in the PGE CG Strategy until 2030 and in the PGE CG Code of Ethics.
An important element of the Code of Ethics is the principle ‘We compete fairly,’ which refers to fair and transparent market competition rules and responsible marketing practices. Another principle taken into account is ‘We build trust by communicating reliably about our activities,’ under which the Group pursues a transparent, reliable and active information policy that fosters good relationships with customers. Emphasis is placed on the development of modern solutions that facilitate customer communication, including marketing communication. Another key element is the absence of any content or statements in marketing messages that are false or potentially misleading to consumers.
Within PGE CG, the Corporate Centre develops standards and guidelines for product marketing, promotion and advertising, for example through the preparation and implementation of the PGE CG Visual Identity System, including supplements related to conducting campaigns, producing video content, or issuing guidelines for specific business lines. The Corporate Centre supports Group companies in planning activities in these areas and also approves the campaigns carried out by these units. It also monitors the effectiveness of campaigns conducted both by the Corporate Centre and by companies of PGE CG.
PGE Obrót S.A., as the main sales company of PGE CG, has additionally implemented the following management instruments:
Product implementation procedure at PGE Obrót S.A.
PGE Obrót S.A. has introduced a procedure for implementing new products. Its aim is to describe and systematise the rules for implementing products that meet the business objectives of PGE Obrót S.A. and customer expectations, excluding individual offers and tariffs approved by the President of the Energy Regulatory Office. Access to high-quality information is reflected in the requirements for developing product documentation and conducting product consultations.
After-sales customer service procedure
Another key policy at PGE Obrót S.A. is the after-sales customer service procedure. Its aim is to ensure appropriate service quality through the effective handling of matters raised by customers, and to implement solutions aimed at standardising, harmonising and streamlining the customer service process at PGE Obrót S.A. The policy enables safeguarding, effective enforcement, and evaluation of its implementation within the company.