Tools
Literally translated, "compliance" means being in accordance with the letter of the law. Acting in line with the law is expected of every employee, and rules of ethics and responsibility for actions towards co-operators, clients or business partners are in effect equally for everyone.
The main aim of the compliance function at PGE Group is to support PGE Group’s Strategy as the most effective and flexible energy group in Poland and to minimise the risk of non-compliance, which could result in penalties or sanctions being imposed or reputation being lost as a result of a failure to adapt to regulations and standards that are stated in law or constitute best practices in this area.
Solutions of compliance system apply to all PGE Group employees, including the management and leadership teams. Compliance system is also to encompass all entities within the Capital Group.
In order to effectively achieve the above key goals, PGE Group is:
The Supervisory Board of PGE S.A. oversees and monitors PGE Group’s compliance management system, evaluates the effectiveness of the system and the compliance function, based on periodic reporting, among other things. The Supervisory Board’s Audit Committee is tasked with on-going supervision of the compliance system.
As part of the internal control system, the Management Board of PGE S.A. implements and maintains an effective compliance management system, separate from the risk management function and internal audit function, implements appropriate and effective solutions that ensure that PGE Group’s employees and management will conduct business in a fair, ethical, consistent manner in compliance with the law and regulations and PGE Group’s internal guidelines. The Management Board of PGE S.A. especially directs the compliance management process at the entire Group and ensures the resources to effectively perform the process, provides the unit responsible for compliance with the right access to information and data that is essential to implement its tasks and sets out general directions for compliance management. The Management Board presents to the Supervisory Board (including the Audit Committee) relevant information and reports regarding PGE Group’s compliance management system.
Organisational unit at PGE S.A. that is in charge of PGE Group’s compliance function, whose director reports to a member of PGE S.A.’s management board.
At business lines and business segments, the compliance function is implemented through designated compliance coordinators.
As part of the Compliance Programme, in 2019 we focused on executing such tasks as:
Within the framework of promoting ethical standards and PDC values as elements of the organisational culture of the PGE Capital Group, educational and communication activities were undertaken involving the management staff (management boards and directors) in the practices of applying PRO values in their respective organizations.
In the PGE Capital Group, as part of adaptation training, trainers acquainted newly hired employees with the principles of the Code of Ethics.
In 2019, the Compliance Department and the Compliance Coordinators organized training events on the PGE Capital Group Code of Ethics, which promoted PDC values and ethical behaviours among the Group’s employees. Each training event in this area ends with a test verifying knowledge and an official statement signed by an employee, confirming their familiarity with the applicable ethical principles.
In addition, as part of the inauguration of a follow-up training course on the Code of Ethics of the PGE Capital Group, a workshop entitled “PROsta droga!” was held, whose participants were the management staff of PGE S.A.
The action aimed at preventing corruption and conflict of interest which was launched in 2019 was an update of the anti-corruption and conflict of interest regulations to ensure compliance with the WSE Standards. In particular, the PGE CG’s Anti-Corruption Policy was supplemented with solutions aimed at preventing the creation of corruption funds.
As regards the performance of activities aimed at counteracting corruption and conflicts of interest within the Group, in 2019 training for employees on the PGE Capital Group’s anti-corruption policy was being continued.
In 2019, activities aimed at preventing irregularities were initiated. A list of types of potential irregularities was prepared, the risk of which was identified in the particular areas of PGE S.A.’s activities. Processes and regulations were reviewed in terms of potential fraud risk and actions taken in the areas of supervision and control.
As part of ensuring compliance of the PGE Capital Group’s transactional activities with the MIFID II Directive and the reporting obligation under EMIR, work on the implementation of the general procedure entitled “Ensuring compliance of the PGE Capital Group’s transactional activities with the Financial Instruments Trading Act and the reporting obligation under EMIR” was started. In 2019, the products of the PGE CG companies were categorized in terms of MiFID II Directive and EMIR, the classification of acceptable types of transactions on financial instruments was carried out, and a model for concluding transactions involving financial instruments by the PGE Group companies was established. Rules were formulated for reporting transactions involving financial instruments by the PGE Capital Group companies as well as business/substantive units conducting Transaction Activity, and the method of reporting transactions under EMIR was established.
