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Preventing corruption and conflict of interest

Annual Report 2019 > Preventing corruption and conflict of interest
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Best Pratices in PZU
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Corruption and gift policy - “We do not tolerate corruption. We act ethically and in accordance with the law when performing our business tasks and cooperating with our business partners. The PZU Group has strictly defined rules in force for accepting and giving gifts. We do not give unpermissible presents to business partners, their employees, agents or other third parties. Nor do we promise or expect to receive such presents, nor do we accept them. In particular, this applies to situations in which the type and extent of these gifts affect the actions or decisions of the recipient. It is also unacceptable to make use of third parties to circumvent this rule.”
“The awareness and observation of standards of conduct, especially in business ethics and compliance form one of the pillars of quality in the PZU Group’s business. The ethical standards and risk management processes we have implemented, including the risk of a conflict of interest and corruption risk demarcate the avenues for doing business at a systemic level and support current practice, thereby enhancing the condition of the financial market and clients.” 

Marcin Góral, Compliance Department Director 

PZU Group’s policies [UoR]

The PZU Group has, and will always have, zero tolerance for any form of corruption. The organization’s implemented solutions define the rules of corruption risk management, including the identification of this risk, its prevention and monitoring.

The Group’s companies operate solutions designed to prevent corruption, including, inter alia, the rules of accepting and giving gifts, conflict of interest management, and ethical principles to be followed by members of the company’s statutory bodies. Relative to the entity in question, these rules are covered by a range of implemented documents, regarding, inter alia, prevention of corruption, whistleblowing, conflict of interest management, and procurement. These issues are presented also during internal training courses at the company. Gifts and entertainment, exclusively of low value, may be offered or received in the course of typical business practice. Under no circumstances can money or its equivalent be offered or received. Giving and receiving gifts cannot be so frequent, excessive or generous as to represent an actual or perceived risk of corruption, or breach local statutory or executive regulations.

BEST PRACTICE

Considering corruption to be one of the most serious factors threatening the principles of democracy and market economy, OECD has taken actions to combat this phenomenon. For many years Poland has been a member of OECD, which has developed the provisions of the convention on combating bribery of foreign public officials. 

The basic document in the anti-corruption policy is the document entitled “PZU Group’s Best Practices”, which expressly prescribes zero tolerance for any corruptive behaviors. The provisions of this document obligate each employee to act in compliance with the law and defined ethical standards. The best practices have been implemented in all PZU Group entities as well as the Alior Bank Group and the Pekao Group, which have separate regulations in this respect in place.

PZU has also implemented solutions imposing an obligation to identify and assess corruption risk as part of the ongoing compliance risk management.

The 2019 corruption risk assessment confirms that the system solutions work correctly and that actions aimed at managing this risk are taken with due diligence. In 2019, the results of the conducted measurement of the internal control system performance maintained at a stable level, which permits an assumption that there are still convenient conditions at PZU, which may make it possible to detect corruption threats.

PZU, PZU Życie and Tower Inwestycje have in place an Anti-Corruption Program, which aims to reduce the risk of corruption. The Program shows examples of corruption factors and division of responsibilities to effectively control the risk in the company. It identifies the business areas in which the corruption risk is potentially the highest and describes the symptoms of behavior and conduct of employees which may point to potential corruption threats in the given area. The Program also introduces an obligation of periodic, annual, assessment of corruption risk in PZU. It includes, among other things, corruption risk self-assessment questionnaires conducted among employees, registered notifications of irregularities in specific areas, results of internal inspections and reports of non-governmental organizations dealing with the corruption problem. In 2019, further works on solutions for corruption risk management were performed in PZU. The message on the significance of corruption risk management was reinforced in accordance with the adopted strategy and Anti-Corruption Program. Intensified educational activities for employees (training, publications, ongoing consultations) were performed for the purpose of controlling the corruption risk. In the remaining PZU Group entities, the potential corruption risk analysis or assessment is carried out as part of the analysis of the reports or inquiries related to conflict of interest or accepting/giving gifts.

In the entire PZU Group, 260 cases of corruption and fraud were identified in 2019, which was 55 cases more than in 2018. In both years, 76% of the cases were associated with the Alior Bank Group (140 in 2018 and 198 in 2019). There were no cases of corruption and fraud in PZU and PZU Życie.

After implementation of the Anti-Corruption Program, all PZU and PZU Życie employees were obligated to familiarize themselves with it and comply with its provisions and submit pertinent representations with this respect.

Ethical issues are an element of training for the newly employed. The Compliance Week was held again in 2019. It is the Compliance Department employees’ own project. The purpose of the event is to propagate the knowledge of the compliance principles, novelties in the law, as well as the current and upcoming regulatory challenges home and abroad. All activities are oriented towards reinforcing the compliance culture in the PZU Group. Additionally, the event was awarded in the category “Compliance Idea of the Year” in the Polish nationwide Compliance Awards 2019.

A functionality enabling collection of PZU and PZU Życie employee representations on familiarization and compliance with the Anti-Corruption Program and the legal sanctions related to corruption was implemented in the internal HR system in PZU. 10,033 individuals submitted representations on familiarization and compliance with the principles of the Anti- Corruption Program.

These actions are supplemented by anti-corruption training and campaigns executed in the corporate communication channels, attracting the employees’ attention to the corruption risk. In 2019, a new e-learning training course on the Anti-Corruption Program was delivered. The training was completed by 10,613 PZU and PZU Życie employees. PZU and PZU Group entities, excluding Armatura Kraków and Arm Property, have also adopted their conflict of interest management rules. Each potential conflict of interest which could hinder effective and objective performance of work for the PZU Group should be reported by the employee to their manager and the PZU Group entity’s compliance unit. The conflict of interest management rules introduced in the PZU Group ensure professional, reliable and fair treatment of all clients and persons related to the company in conflict of interest situations.

A person who determines that a conflict of interest has occurred or may occur as a result of the performance of his/her duties is required to take steps aimed at its elimination and to notify the conflict of interest in accordance with the adopted procedure. The report form is submitted to the managers and the compliance unit in the PZU Group entity which analyzes the report.

PZU and PZU Życie have adopted the “Rules for managing conflicts of interest at PZU and PZU Życie”. This regulation aims to ensure professional, reliable and fair treatment of all clients and persons related to the company in a conflict of interest situation.

A person associated with PZU (an employee, a PZU agent), who determines that a conflict of interest has occurred or may occur as a result of the performance of his/her duties is required to take steps aimed at its elimination and to notify the conflict of interest in accordance with the adopted procedure. The report form is submitted to the managers and the Compliance Department which analyzes the report. A detailed analysis of each case of conflict of interest is another dimension of a practical activity in the discussed area.

Numerous training courses were delivered to increase awareness as regards conflict of interest risk management, a dedicated area review as regards conflict of interest risk was carried out. A new e-learning training course in compliance was also developed and, at the beginning of 2020, made available to all PZU and PZU Życie employees as part of an educational platform.