PGE CG’s approach to anti-corruption prevention is outlined in the PGE CG Code of Ethics in the form of the principle: ‘We do not tolerate corruption or unfair practices’. Specifically, the prevention of corruption and bribery is governed by two internal regulations at the level of the PGE Capital Group.
These are the PGE CG Anti-Corruption Policy, a general document also available to external stakeholders, and the General Procedure for Anti-Corruption Measures in PGE CG, which provides further details.
The requirement to meet anti-corruption standards has also been imposed on the business partners of PGE CG companies through the inclusion of minimum requirements in this area in the Code of Conduct for Business Partners of PGE CG Companies.
All the above-mentioned regulations are described in more detail in section G1-1.
Anti-corruption prevention in PGE CG primarily includes:
- identifying organisational structures particularly responsible for planning and coordinating anti-corruption and conflict of interest efforts,
- identifying legislation related to anti-corruption,
- ensuring compliance with anti-corruption regulations and the standards of the Warsaw Stock Exchange regarding anti-corruption,
- verifying and updating internal regulations to improve the effectiveness of anti-corruption efforts,
- avoiding conflicts of interest – implemented, among other things, through declarations submitted by employees and other individuals, ongoing monitoring of such declarations, maintaining a register of enquiries, and providing advice in situations where a conflict of interest is suspected,
- assessing and managing corruption risk, including identifying areas particularly exposed to corruption risk,
- raising awareness and engagement among employees and others in counteracting corruption, including communication and educational activities related to these issues and principles of conduct,
- promoting awareness of the principles set out in the Code of Conduct for Business Partners of PGE CG Companies among business partners,
- rules for the exchange of business gifts.
Anti-corruption training is mandatory and is carried out in accordance with the rules set out in the General Procedure for Anti-Corruption Measures. Training materials are typically prepared by the compliance area within the Corporate Centre and are then adapted by the companies to reflect their operational specificities so that the content corresponds to employees’ actual work environment.
Training provided by the Compliance area includes
Two types of anti-corruption training are conducted in PGE CG – cyclical training and training dedicated to persons performing functions exposed to corruption risk.
Every employee employed by PGE CG companies and any other person acting on behalf of and for the benefit of a PGE CG company should complete full training in this area at least once every three years. After this period, the training is repeated as a refresher course. The first training should be completed within no more than three months from the date of employment in the form of a detailed, interactive workshop on anti-corruption rules, standards defined by the WSE, types of corruption, definitions, and anti-corruption regulations in PGE CG.
Additional, as a supplement to knowledge, within the framework of dedicated anti-corruption training delivered in PGE CG, taking into account the specifics of a given area and the scope of duties assigned to specific positions, in consultation with the relevant organisational units.
Persons covered by anti-corruption training programmes
1 In the case of persons in roles exposed to corruption risk, the indicated number refers to persons identified as being at corruption risk. In the case of other roles, the numbers refer to the number of persons holding such positions.
2 General anti-corruption training is mandatory for all individuals and remains valid for 3 years. After this period, employees complete a refresher course. Dedicated training for individuals particularly exposed to corruption risk is indefinite, and the presented data refer to the dedicated training conducted in 2024.
A description of the extent to which training is provided to members of the Supervisory and Management Boards of PGE CG Companies is described in section [G1-1].
The risk of abuse and corruption is managed under the Enterprise Risk Management (ERM) system in segment companies and under the compliance management system in companies covered by it.
This process is cyclical. In companies not covered by the Enterprise Risk Management system, it is carried out in annual cycles.
Upon completion of the training, each individual is required to submit a statement that they have read and commit to comply with the PGE CG’s anti-corruption regulations.
Additionally, two groups of persons have been identified within PGE CG from the perspective of whom corruption prevention is of particular importance. Internally, these are persons holding roles exposed to corruption risk due to the areas in which they perform their duties and/or the positions they occupy. Externally, these are the business partners of PGE CG companies, including natural and legal persons with whom PGE CG companies have business relationships. Anti-corruption measures targeted to these groups are as follows:
- Persons particularly exposed to the risk of corruption, i.e. persons performing tasks in such areas as procurement, administration, human capital management, and other areas involving interaction with business partners, as well as individuals in managerial positions. These individuals receive additional, dedicated anti-corruption training. This includes information on which persons in PGE CG are considered particularly exposed to corruption risk, as well as additional substantive content and guidance on appropriate conduct, e.g. in cooperation with business partners, use of contractual clauses, or behaviour in the case of a potential corruption offer. Additional actions are also undertaken, e.g. special refresher training on gift policy (e.g. in PGE S.A. – December 2024).
- Business partners receive information on anti-corruption prevention through the provisions of the PGE CG CCBP, which contains a dedicated chapter on this subject. Additionally, PGE CG’s approach to combating corruption is set out in the PGE CG Anti-Corruption Policy. Both documents are available on the websites of PGE CG companies in Polish and English. Furthermore, references to CCBP are included in the business partner registration process within the procurement system, in procurement documentation, and ultimately in contract clauses. Details regarding the application of provisions referring to CCBP are included in the annex to the anti-corruption procedure. Additionally, information about CCBP is also communicated during meetings with current or potential contractors.
Information on the communication activities carried out in this area is provided below, as well as in sections G1-1 and G1-2.
Communication of the anti-corruption prevention policy is conducted in PGE CG both externally and internally, using various communication channels. The methods of communicating individual codes and policies are described in Chapter G1-1.
Furthermore, PGE CG conducts additional communication activities concerning anti-corruption matters, including in particular occasional publications and/or announcements (e.g. on the principles of exchanging business gifts), articles in the internal PGE CG magazine ‘Pod Parasolem’ (e.g. on the International Anti-Corruption Day, etc.
Reports of non-compliance
An internal reporting system has been implemented in PGE CG, which is described in detail in Chapter G1-1.