We are a big company, employing approx. 40 000 people. For such a large organisation, setting out shared values for an exceptionally diverse group of employees is a great challenge.
The main document in the area of ethics and compliance is the PGE Group Code of Ethics, which constitutes an overarching declaration and basis for other internal regulations and guidelines. The document describes basic ethical values and standards which the organisation expects from all employees and other persons performing work for PGE Group. The Code indicates and defines common key values and ethical principles of PGE Group, serving as a foundation for the organisation’s operations and the achievement of strategic objectives at PGE Group.
PGE Group is a place for those who value ethics rules and the law. We believe that ethics have much greater impact on the observance of law than the mere fact of legal regulations being in force. Even the best legal system is useless when confronted with a lack of an ethics culture in the organisation. Illegal activities may be explained by errors of individual employees, but the person breaking the rules had to have the opportunity to do it. A solid ethical culture may help companies in trouble caused by the actions of individual employees.
We are certain that all values – even corporate ones – start and end with the human being. Corporate values thus also come from us – individual people, employees. Therefore, the observance of corporate values most importantly depends on the personal values of each one of us.
The Code specifies the attitudes and behaviours that are expected of all employees and managers. The Code streamlines and collects in one place rules that employees should follow inside and outside the organisation, in contacts with business partners or co-workers.
To ensure that the Code is known, understood and respected, we were holding workshops across PGE Group for employees and management. First, we invited colleagues from inside the Group, who became internal trainers for the Code of Ethics. Training the trainers, numerous meetings and discussions to explain objectives, materials, exercises and all other doubts. Finally, the time, involvement and hearts of our internal trainers dedicated to best prepare and conduct training.
Every new employee within the Group undergoes individual adaptive training shortly after starting work at PGE Group companies, where he/she finds out about the existing Code, the law and the obligation for employees to react to any potential irregularities. New employees get a chance to learn the details of the Code at adaptive group training called „Turn on the power”. These training sessions are conducted entirely by Group employees.
In 2020, refresh trainings of the PGE Group’s Code of Ethics, which has been in force since 2015, were launched. Taking into account the feedback received after previous training sessions and wanting to ensure the greatest relevance of the content and form of training for the recipients, and thus the best possible effectiveness, the recurring training was planned based on the principle of individualization and personalization of both training materials and assumptions as to how to implement them.
Communication on ethical issues is carried out on an ongoing basis. The text of the Code of Ethics (and the Code of Conduct for Business Partners of the PGE Capital Group companies) is available to employees and stakeholders on the websites of the PGE Group and the particular companies. In each of the companies, posters and leaflets informing about the values and principles are available together with a hotline number to report non-compliance. In 2020, the ethical principles were reminded to employees through the available internal channels: in the “Pod Parasolem” magazine (6 articles) and on the Intranet of the PGE Group (9 articles). The monitors located in the PGE headquarters presented videos with statements made by managers on how they understood and implemented the PGE values in their work. Additionally, in 2020 the curricula of other training courses conducted in the companies of the PGE Group contained elements concerning attitudes and behaviours reflecting the PGE values. The training programme entitled “The Development Network” is based on such PGE Group values as Partnership, Development, Responsibility. The ethical principles have also been introduced into the internal regulations applicable to selected business and operational areas. These measures aim to translate the values and principles into the language of practical behaviours and attitudes.
In communications related to the Code of Ethics, employees’ personal responsibility for their actions is emphasised in accordance with the Group’s ethical values and rules expressed in the Code.
Adopting the Code and clearly communicating the rules contained therein has a straightforward objective: support PGE Group’s Strategy and 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.
In order to implement the principles of the Code of Ethics, almost 1 500 training hours (containing a training module on respect for human rights) were conducted in 25 PGE Group companies with compliance structures in 2020. 38 182 employees had been trained and percentage of employees trained amounted to 99%.
The rules governing cooperation with business partners are defined first of all in the Code of Ethics of the PGE Capital Group, which is a set of values and principles in force in the entire PGE Group. Among other things, it defines the PGE Group’s approach to building business partnerships. The Code of Ethics of the PGE Capital Group is supplemented by the following practical guidelines:
Business partners are natural persons, legal persons or organisational units without legal personality, operating in the public or private sector, with whom the PGE Group has any business relations. In particular, these are contractors, suppliers’ subcontractors, consultants, wholesale trading partners, agents, financial institutions, industry organisations and other entities with which the PGE Group companies conduct business cooperation of a similar nature.
Good procurement practices are a set of recommended attitudes and principles that should be followed by employees and potential business partners during tender procedures. The principles are based on four aspects of cooperation: partnership, transparency, fair competition and information security. The good procurement practices also include the principle of „no gifts”, which is binding for employees initiating a procurement process (submitting a purchase application), members of committees and all persons participating in the process and persons performing contracts concluded as a result of the procurement process.
The PGE Group’s expectations towards its business partners are set out in the Code of Conduct for Business Partners of the Companies in the PGE Capital Group. The content of this document is available on the companies’ websites (most often in the section dedicated to procurement procedures). Additionally, the obligation to comply with laws and ethical standards, with direct reference to the provisions of the Code of Conduct for Business Partners of the Companies in the PGE Capital Group, is applied as a standard element of contracts.
In order to mitigate the risk of incurring financial or reputational losses resulting from establishing or maintaining a business relationship with a partner who does not comply with the law and ethical principles, the PGE Group companies examine available information on their business partners in accordance with internal regulations, in particular in the areas of procurement raw materials for production and trade.
When formulating offer evaluation principles, the PGE Group promotes innovative solutions that streamline internal processes through their automation and those that limit the negative impact on the natural environment through, for example, lower paper consumption, water consumption and greenhouse gas emissions, as well as pro-ecological waste management. It is required that supplied products possess marketing authorisations for the Polish and European markets.
In the course of the procurement process, the PGE Group informs its contractors that they must familiarise themselves and comply with the Code of Conduct for Business Partners of the Companies in the PGE Capital Group and the Good Procurement Practices. This is also an example of the implementation of corporate social responsibility in the area of procurement. Contractors and subcontractors are obliged to comply with regulations relating to information security, environmental protection, occupational health and safety, and to take actions aimed at reducing the nuisance caused by construction works to local communities.