We are one of the largest companies in Poland, and we operate not only in compliance with the law but also with the principles of honest business conduct. We operate ethically and responsibly, and we expect the same from all our employees and business partners.
The entire operation of the PGE Capital Group, including its organizational culture, is based on three values: partnership, development, and responsibility.
Corporate culture
PGE CG establishes its corporate culture to support compliance with the law, ethical principles, and actions consistent with the principles of sustainable development, as defined in the PGE CG Code of Ethics and the PGE CG Compliance Management Regulations.
The development and promotion of corporate culture within the Group is carried out, among other means, through:
- educational activities in the form of training and communications on compliance with laws, internal regulations, and ethical conduct;
- support for the implementation of transparent processes that enable the identification, clarification, and prompt resolution of non-compliance and breaches of principles, as well as actions to prevent future occurrences.
In 2024, numerous communication activities were carried out to promote adherence to the values and principles of the Code of Ethics, using channels such as:
- articles in Pod Parasolem magazine,
- intranet publications.
A campaign was also conducted to promote a culture of ethics and integrity under the slogan ‘energETYCZNI ludzie!’ (a play on words combining ‘ethical’ and ‘energy people’), including a competition among PGE CG employees for artistic expressions on the theme of acting with integrity.
The corporate culture of PGE CG is assessed among employees through initiatives such as the Survey on Familiarity with the Values and Principles of the PGE CG Code of Ethics, one of the aims of which is to examine the extent to which employees apply these values and principles in practice. The most recent survey was conducted at the end of 2022, and a follow-up assessment is planned for 2025.
Management Board Members of PGE CG companies actively promote the corporate culture based on the values and principles of the Code of Ethics among employees, including through participation in communication activities. In their messages to employees, they emphasise the importance of integrity and ethics in business and the role of employees’ attitudes in shaping the organisational culture. The statements of Board Members of individual companies are also featured as introductions to training sessions on the Code of Ethics and anti-corruption.
Training on business conduct
Compliance training is a permanent and essential element of the compliance assurance process. It ensures, among other things, that employees and other persons are properly informed about applicable regulations and practical examples of their application. Training is delivered by staff from the Compliance Department at PGE S.A., Compliance Coordinators, and internal trainers appointed within PGE CG companies, or via e-learning modules developed across PGE CG.
Training on the PGE CG Code of Ethics is mandatory and conducted according to the rules outlined in the General Procedure for Compliance Management. 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:
Every employee of a PGE CG company, as well as any other person acting on behalf of or for the benefit of a PGE CG company, is required to complete training or be familiarised with the PGE CG Code of Ethics, the rules for reporting irregularities, and selected compliance topics within the onboarding programme – preferably within the first few days of employment or engagement, but no later than within the first month. A company may decide not to run onboarding training separately if a full compliance training session is conducted within that first month.
Every employee hired by companies within PGE CG, as well as any other person acting on behalf of or for the benefit of a PGE CG company, is required to complete full training in this area at least once every three years. After this period, it is repeated as a refresher training. The initial training must take place no later than three months from the date of employment or engagement and is conducted in the form of a detailed, interactive workshop on the values and principles outlined in the PGE CG Code of Ethics. The training covers in detail the values and principles applicable within the PGE Capital Group, human rights, the whistleblowing system, and the full scope of protections, rights, and reporting channels available to whistleblowers. After completing the workshop, participants are required to submit statements confirming that they have familiarised themselves with the training content and that they commit to adhering to the principles covered.
There are plans to consolidate the training materials and increase the frequency of regular training sessions on the Code of Ethics and anti-corruption, with the aim of introducing an annual cycle.
The Compliance Department of PGE S.A. also carries out anti-corruption and anti-bribery activities, as described in greater detail in section G1-3 of this Statement.
In all PGE CG companies, members of Supervisory Boards are provided with essential materials for review as part of their training. These include the Code of Ethics, the Code of Conduct for Business Partners of PGE CG companies, and the key internal regulations concerning anti-corruption and the functioning of the Compliance area. Upon request by the Supervisory Board, training sessions may be conducted by Compliance personnel.
Management Board members undergo training through direct meetings, during which they are presented with information on the Code of Ethics, anti-corruption regulations, and the principles governing the Compliance function within PGE CG.
Persons particularly exposed to the risk of corruption are identified based on the provisions of the General Procedure for Anti-Corruption Measures in PGE CG. These include 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.
The PGE Capital Group applies the following mechanisms for identifying and investigating concerns related to unlawful conduct or conduct that violates the Code of Ethics and other internal regulations:
- Identification and investigation mechanisms:
- ongoing identification of legal provisions, including preparation of a monthly Legal Newsletter distributed to the management staff of PGE S.A. and PGE CG companies,
- annual compliance assessments,
- planned and ad hoc compliance monitoring,
- inspection and investigation proceedings,
- planned and ad hoc internal audits.
If any irregularities are identified, including corruption or bribery in the workplace, employees are obliged to report them to their direct supervisor or the Compliance function at the Corporate Centre or in the respective company. The reporting system allows for submissions via dedicated channels.
- Mechanisms for reporting concerns:
- reporting information to a supervisor,
- two reporting systems accessible at www.gkpge.pl:
- non-compliance incident reporting, and
- internal reporting (‘whistleblower’)3,
- a dedicated email address for the Supervisory Board of PGE S.A.,
- an additional channel for questions and concerns: OpiniaCompliance.pgesa@gkpge.pl),
- channels of human capital management units,
- other channels arising from internal regulations or legal provisions, e.g. DPO and OSH.
Reports may be submitted by both internal and external stakeholders.
1PROG 00095 General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents in the PGE Capital Group and Protection of Reporting Persons.
2Procedures for internal reporting and protection of whistleblowers adopted in individual PGE CG companies.
3Reports can be submitted via a dedicated online form, email, phone or post.
In 2024, the PGE CG operated under the General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents within PGE CG and Whistleblower Protection, which governed, among other things, the reporting and handling reports of non-compliance incidents relating to corruption and bribery. As of 25 September 2024, following the entry into force of the Act of 14 June 2024 on the Protection of Whistleblowers, internal reporting and whistleblower protection procedures were implemented in PGE CG companies that met the criteria set out in the Act (a separate procedure was introduced in each of the companies concerned). As a result of the implementation of the new internal reporting and whistleblower protection procedures in part of the PGE CG companies, the General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents within PGE CG and Whistleblower Protection, which had been in effect until 25 September 2024, was updated and renamed the General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents in PGE CG and Protection of Reporting Persons. Since then, two reporting systems have been operating in parallel within the Group.
An internal report may be submitted by whistleblowers in the following ways:
- by completing the form available:
- on the intranet site of a PGE CG company (‘Whistleblower Report’ form),
- or on the external website www.gkpge.pl,
- by e-mail to: sygnalista@gkpge.pl,
- by sending a letter to: Head of the Compliance Unit, PGE S.A., ul. Mysia 2, 00-496 Warsaw, with the note on the envelope: ‘Do not open at the Registry Office, concerns PGE S.A.’,
- by oral submission during a direct meeting with a PGE S.A. employee authorised by the Management Board of a PGE CG company and designated by the Head of the Compliance Unit.
Due to legal requirements, the companies 'PGE Dom Maklerski S.A. and PGE Dystrybucja S.A. have established separate whistleblower reporting channels.
The internal reporting procedure allows for the acceptance of anonymous reports of breaches of law.
A whistleblower is protected from the moment of making an internal report or a public disclosure, provided that they had reasonable grounds to believe that the information being reported or disclosed was true and that it constituted information about a breach of law.
Whistleblower protection includes:
- maintaining anonymity,
- ensuring confidentiality and the protection of personal data, including the whistleblower’s role or position, and taking follow-up action in such a way that it is not possible to clearly identify who submitted the report of a breach of law,
- protection against retaliation.
Companies within PGE CG are obliged to ensure that no retaliatory actions, nor any attempts or threats of such actions, are taken against the whistleblower.
A non-compliance incident may be reported by whistleblowers in the following ways:
- by completing the online form: ‘Form – non-compliance report’
- by sending an email to:
- uczciwybiznespge@gkpge.pl,
- rada_nadzorcza.PGESA@gkpge.pl. messages sent to this address are received by the Supervisory Board of PGE S.A.
- by post
- by calling +48 22 340 12 02 (available 24/7).
Employees of PGE Dystrybucja S.A. may submit reports to: uczciwybiznes@pgedystrybucja.pl
In 2024, employees of the PGE CG’s companies have been provided with extensive information about the protection of both whistleblowers and other reporting individuals. This information is a regular part of training on the PGE Capital Group’s Code of Ethics and anti-corruption policies. Following the implementation of the provisions of the Whistleblower Protection Act and the adjustment of regulations in PGE CG companies in this area in September 2024, a broad information campaign was carried out on reporting channels and whistleblower protection.
This information is also provided during the recruitment process and is published on the intranet and on the public website www.gkpge.pl (Compliance section).
Pursuant to applicable legal regulations, the management boards of PGE CG companies authorised PGE S.A. (as an external entity) to receive internal reports. At the same time, the management boards of PGE CG companies authorised selected employees to carry out explanatory and follow-up actions, including the verification of internal reports and further communication within the legal entity’s organisational structure. In 2024, internal training was conducted for persons responsible for receiving reports.
Pursuant to the provisions of the Act of 14 June 2024 on the protection of whistleblowers, each PGE CG company that has implemented an internal reporting system is required to maintain an individual register of such reports. At the same time, non-compliance reports, which fall under the non-compliance system covering all PGE CG companies, are recorded by PGE S.A. in a central register maintained by the Compliance area.
Within the functioning reporting systems in PGE CG companies, reports are examined through explanatory proceedings in accordance with the relevant internal regulations4. The responsibilities of the employee conducting the explanatory proceedings include, in particular:
- planning and carrying out actions aimed at clarifying the report,
- in the scope of the non-compliance system, reporting to the head of the unit responsible for compliance at PGE S.A. on the actions carried out within the defined scope,
- collecting and assessing evidence,
- preparing a final report from the explanatory proceedings, including, among other things, possible recommendations for remedial and improvement actions.
The guarantee of independent and impartial conduct of explanatory proceedings lies in the obligation of impartiality on the part of the person conducting the explanatory proceedings, which arises directly from the procedure. According to its provisions, those conducting the explanatory proceedings must act impartially and with due diligence. In particular, there must be no relationship between the person conducting the explanatory proceedings and the reporting person or individuals associated with the report that could compromise the impartial and objective performance of the tasks involved. In the event of a risk of such a situation, the person conducting the proceedings is required to report it in writing to the head of the Compliance area.
In parallel with Compliance activities, PGE CG applies the Regulations on Inspection and Investigative Procedures, which ensures the independent and objective examination of incidents related to the business activities of the Group companies, including incidents related to corruption and bribery. Employees conducting activities related to events that occurred in PGE CG companies are employed in the Security Division of the Corporate Centre, which reports directly to the President of the Management Board of PGE S.A. The results of control activities are each time presented to the Management Board of PGE S.A. via the Head of the Security Division or, in specific cases, directly, and in the case of identified irregularities, also to the management boards of the audited companies.
4Individual Procedures for Internal Reporting and Protection of Whistleblowers of PGE CG Companies and General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents in the PGE Capital Group and Protection of Reporting Persons.