“The basis for our daily work is professional ethics and acting in accordance with the law. We make our employees aware of the meaning underlying the norms that we observe, in order to develop and strengthen our Group’s organizational culture.”
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:
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.
The “PZU Group Best Practices” were implemented in 2018. The document is a uniform model of the standards observed by all PZU Group entities, except for the Alior Group, and the Pekao Group, which have adopted the Alior Bank Code of Ethics and the Pekao Group Code of Conduct. The PZU Group Best Practices are a collection of values and principles that the employees should be guided by.
The PZU Group Best Practices describe the PZU Group’s values and the fundamental rules of conduct of employees, which address the situations such as:
|PZU Group’s values||Our promise to the client||Our promise to the employee|
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:
The Pekao Group conducts education activities for employees to promote the culture of compliance and ethical conduct. Within the framework of these activities, training courses are carried out, brochures and principles are published reminding the standards of conduct. Employees expect information that is short and easy to remember, rather than long and extensive procedures they need to read. Pekao tries to meet these expectations and, as a result, employees admit that training of this type helps them gain knowledge of various inappropriate conduct, including behavior that may give rise to 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: