PGE CG’s operations are based on three core pillars representing the fundamental values of the organisation: partnership, responsibility and development. Enabling employees to raise concerns—especially in areas covered by the Act of 14 June 2024 on the Protection of Whistleblowers, as well as matters of non-compliance—is an important expression of these values. This approach facilitates more effective identification of adverse impacts that can be minimised or eliminated at acceptable business cost.
Employees of the PGE Capital Group may raise concerns and provide feedback regarding observed adverse impacts to local HR departments, their line managers or general-access channels, which may vary depending on the employer.
In addition to the tools available within the human capital management framework, the Group also enables employees to report irregularities in accordance with applicable internal procedures. Until 24 September 2024, this was the General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents within PGE CG and Whistleblower Protection. After that date, the updated procedure is titled General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents within PGE CG and Protection of Reporting Persons. A detailed description of how the whistleblowing systems function is provided in Section G1 of this Statement.
In cases where an adverse impact on individuals from within the Group’s own workforce is identified through investigative proceedings under the General Procedure – Reporting and Handling Reports of Suspected Non-Compliance Incidents within PGE CG and Protection of Reporting Persons, a set of recommendations is drawn up and submitted to the company’s Management Board by the team conducting the investigation. Implementation of these recommendations is then monitored as part of a supervisory mechanism.
The primary point of contact for employees in a given company is their line manager and staff from the human capital management units, including individuals serving as HR Business Partners. These are professionals who work closely with management to align human capital activities with business objectives. PGE CG has also made available a formal mechanism for reporting irregularities, through which employees may raise concerns and needs directly with the Compliance Department. Detailed information is provided in Section G1 of this Statement and is also available at www.gkpge.pl under the Compliance tab. Additionally, individuals wishing to ask a question or raise concerns may do so by writing to: OpiniaCompliance.pgesa@gkpge.pl. Employees are also encouraged to contact Compliance Coordinators in their respective companies directly.
In accordance with the Procedure for Preventing Mobbing and Discrimination (applicable both at PGE S.A. and at Group companies employing staff), the reporting mechanism may be used by employees or groups of employees who believe they have experienced broadly understood inappropriate behaviour. A report may concern the behaviour of a single person or a group of individuals. Employees’ representatives are excluded from the standard reporting channel due to the importance of the victim’s testimony and the need to present and verify specific facts. However, to ensure the full use of available mechanisms and to foster a friendly working environment, the Procedure stipulates that any employee who believes they have witnessed inappropriate behaviour may report it to the compliance unit. Such a report is then treated as a non-compliance case.
- by email to the dedicated address, which is subject to strict access restrictions due to the sensitive nature of the data shared;
- by post (addressed to the Director of the Human Capital Management Division);
- in person, either in writing or verbally for the record, during a meeting with a Management Board member, the Director of the Human Capital Management Division, or the Director of Compliance.
Information on these reporting channels is available on the PGE Group intranet, the intranets of individual Group companies, and in the DSZ repository. Managers are also informed about the channels during meetings with HR Business Partners, and the topic is covered in various training sessions that address inappropriate behaviour.
Every employee is required to sign a statement confirming that they have read the procedure mentioned in this section, which allows employers to assume that employees are aware of the available channels for reporting mobbing.
Upon receiving a report via the ‘mobbing’ channel, the content is verified. If the report lacks required formal elements, the reporting person is asked to complete the missing information. However, even if the deficiencies are not remedied, the report is still treated as a non-compliance case.
If the verification is successful, the employer appoints a committee to review the case. Committee members must be of unquestionable integrity and possess the life and professional experience necessary to assess the case objectively. All committee members and any other persons involved in the proceedings (including the secretary) are obliged to maintain strict confidentiality with regard to all facts and personal data obtained during the proceedings, as well as the course of the procedure itself. Breaches of confidentiality may result in sanctions in accordance with internal employer regulations and applicable laws.
After examining the report, the committee decides on further actions, which may include: reviewing evidence, hearing both parties, and interviewing witnesses.
Following the evidentiary proceedings, the committee prepares a final report that contains a summary of the allegations, evidence reviewed, established facts, dissenting opinions (if any), and potentially proposed actions, changes, or improvements aimed at reducing the risk of inappropriate behaviour in the future. After reviewing the report, the employer decides on further steps and the appropriate measures to be taken regarding the individuals involved in the proceedings.
The employer provides the parties to the proceedings with information on how the case was resolved, the decisions taken and the planned actions. The employer may instruct the committee to communicate to the parties either the full or a partial opinion, indicating the scope of the information shared.
The submission of a report by an employee must not result in any negative consequences, including in the sphere of employment, unless the report was made in bad faith or solely with the intention of harming another person. This is to protect against retaliatory actions.
Departments responsible for HCM in the respective Group companies maintain ongoing records of reported incidents and, after the committee’s proceedings are concluded, of their outcomes (with due respect for the privacy of those involved). In addition, under guidelines issued by the Corporate Centre, individual employers inform the Human Capital and Organisational Culture Department at PGE S.A. of every initiation and resolution of such proceedings and submit annual aggregate reports. These reports also include the measures and courses of action recommended by the committees, which help introduce corrective actions and shape the organisational culture in the desired direction.
Departments responsible for HCM in individual companies keep a register of reports of inappropriate behaviour, including information on reports forwarded for review under the applicable General Procedure.
The effectiveness of the ‘mobbing channels’ is monitored, among other things, by verifying the timeliness of the committees’ work, the submission of reports to employers, and the ongoing monitoring of whether new reports have been received through the given channel. In 2024, PGE Group did not assess awareness of the existence of reporting structures or the level of trust in them.
A detailed description of the policies adopted by the PGE CG companies to protect individuals using reporting channels is provided in Section G1.
The description of how individuals belonging to the Group’s own workforce who may be significantly affected by the enterprise, and their representatives, have access to enterprise-level channels at the company in which they are employed or for which they work, in relation to OHS, is presented in Section S1-2.