Ethical foundations of business operations

PZU Group’s policies [UoR]

The compliance risk management system in the PZU Group has been established based on the best market standards and proprietary solutions, while using a number of agreements between PZU Group entities and group policies. It is an integrated set of values, standards of conduct, tools, including procedures and regulations, supported by adequate communication with, and education of, employees. Individual companies in the PZU Group have a range of separate policies, procedures and practices in this area. This system comprises, inter alia:

• values and rules of conducts, including Best Practices of the PZU Group, Alior Bank Code Of Ethics and the Pekao Group Code Of Ethics;
• procedures, policies and organizational arrangements;
• a system of reporting irregularities and potential malpractice (whistleblowing system),
• educational and communication activities addressed to employees and suppliers.

The PZU Group Best Practices are the foundation of ethical standards in the PZU Group. Its aim is to develop a consistent organizational culture of the company in all key aspects of its operation.

The Group Best Practices define behaviors and conduct towards all stakeholders of the company, based on respect and trust. At the same time, this document serves as a common denominator of corporate culture, for all entities in the Group. Thanks to the consistent compliance of our fundamental principles, all our activities and processes are carried out based on coherent assumptions, thus ensuring a high operating standard throughout the Group. Separate codes of ethics are in place in the Alior Bank Group and in the Pekao Group.

Both Alior Bank and the other Alior Bank Group companies operate a Code of Ethics, which regulates, inter alia, the relationship of the company and its employees to clients, ethical behavior and respect for the law. Furthermore, Alior Bank has implemented an Environment Policy applicable to a workplace free from undesirable conduct. The Policy applies to all Alior Bank employees and is a reflection of the Employer’s fulfillment of the obligation to prevent and counteract undesirable conduct in the workplace, in particular discrimination, mobbing, and harassment, including sexual harassment. The employees took part in a training “Undesirable Conduct in the Workplace”, which discussed behaviors that are considered objectionable and what to do if they are observed. Another implemented policy is the Policy of Unfair Selling Prevention, in order to manage the risk of misselling and improve the quality of the Bank’s products offering process.

The Pekao Group operates a Code of Conduct, designed to ensure the highest standards of service and protection of reputation by the Group’s employees.

The principles of the Code of Conduct are as follows:

• treat everyone with respect and dignity,
• respect human rights,
• protection of reputation,
• standards of communication,
• occupational health and safety,
• protection of assets
• financial reporting,
• care for natural resources,
• responsible marketing and promotion,
• protection of legally protected information,
• counteracting money laundering and financing of terrorism,
• consumer protection,
• fair competition and prevention of monopoly practices,
• confidential information and market abuse,
• management of conflict of interests,
• counteracting corruption.

TFI PZU has in place the Principles of Ethics for associated members and the Principles of Ethics for members not associated with the PZU Group. The principles have been adopted to ensure that supervisory board members not associated with the PZU Group discharge their function correctly, to prevent conflicts of interest and mitigate reputation risk and corruption risk. Additionally, contrary to the document designated for members not associated with the PZU Group, the Principles of Ethics for members associated with the PZU Group contain two appendices: Appendix No. 1 – Rules for managing conflict of interest, and Appendix No. 2 – Rules for accepting gifts.

TFI PZU has also adopted the Rules for managing conflict of interest. It sets out the circumstances, which in respect to the individual activities in the area of TFI PZU’s activity, cause or may cause a conflict of interest to occur associated with a material risk of violation of interests of clients, and defines actions aimed at identifying conflicts of interest, preventing and managing them and mitigating, as much as possible, the potential effects of the risk of conflict of interest. 

PZU Group’s ethical culture is developed in observance of the highest standards and in line with the needs of the Group’s entities, taking account of the scale, character and type of their operation and local laws.

The PZU Group deploys its ethical culture by creating system-based solutions at the PZU level. As the parent company, PZU sets and develops the standards of conduct, and then recommends them for deployment in the other Group companies. The companies then implement the solutions and standards of conduct recommended by PZU, abiding by the so-called principle of proportionality and adequacy, i.e. the scale, character and type of their activities, provisions of local law and purposefulness of a given solution in the company’s operation; they report compliance risks back to PZU, with due respect for legally protected secrets ensured.

PZU emphasizes building of compliance awareness among its employees, by developing an organizational culture of the PZU Group based on the fundamental ethical values. The most important activities building awareness include:

• PZU Compliance Week - z regular event designed to build and improve the awareness of PZU Group employees as regards the local and European regulatory environment and key information about the compliance function, in and easy to understand form, including expert talks, training, knowledge contests, as well as individual and group compliance knowledge tournaments. The event was awarded in the category “Compliance Idea of the Year” in the Polish nationwide Compliance Awards 2019.
• PZU Compliance Newsletter - a quarterly which presents, in an easy to understand form, current regulatory challenges faced by the PZU Group, as well as selected market events which may be interesting and useful for all PZU employees in their daily work, as well as standards of conduct enforced in the PZU Group.
• Compliance Network - regular meetings addressed to the personnel responsible for compliance in the PZU Group companies. The meetings are designed to acquaint the compliance professionals with the most important developments in the area of compliance.
• Training: e-learning and classroom courses, including for newly-hired employees, where we emphasize compliance aspects and verify the level of knowledge after the training is completed.