“The company’s actions should not be limited only to internal measures to reflect, inter alia, the provisions of the OECD Convention on Combating Bribery of Foreign Public Officials, but should also disseminate knowledge in this respect, given the broad range of experiences gathered in this respect.”
Navigation Map Download our best practices
Interactive navigation is a tool that goes beyond the standard navigation of the integrated content (available in the report drop-down bar). New approach allowed to navigate in the two additional business dimensions of the PZU Group, i.e .:
- strategy (insurance, health, investments, finances);
- sustainable development (sales, employees, social responsibility, natural environment and ethics).
The above-mentioned areas were additionally supplemented with related GRI indicators, within each selected issue.
- strategy (insurance, health, investments, finances);
- sustainable development (sales, employees, social responsibility, natural environment and ethics).
The above-mentioned areas were additionally supplemented with related GRI indicators, within each selected issue.
In the CHAPTER
GRI
- 102-7 Scale of the reporting organization
- 103-2 Approach to management and its elements
- 103-3 Evaluation of the approach to management
- 201-1 Direct economic value generated and distributed
- 102-13 Membership in associations and organizations
- 102-40 List of stakeholder groups engaged by the reporting organization
- 102-42 Basis for identification and selection of stakeholders engaged by the organization
- 102-43 Approach do engaging stakeholders, including the frequency of engagement by stakeholder type and group
- 102-44 Key issues and concerns raised by stakeholders and the organization’s response, also by reporting them
In the CHAPTER
GRI
- 102-8 Data pertaining to employees and other persons working for the organization
- 103-2 Approach to management and its elements
- 103-3 Evaluation of the approach to management
- 404-1 Average number of hours of training per year per employee
- 404-2 Managerial skill development and continuing education programs supporting continuity of employment of employees and facilitating the retirement process
- 404-3 Percentage of employees subject to regular assessments of work quality and professional development reviews, by gender and employment category
- G4-FS16 Initiatives to enhance financial literacy by type of beneficiary
In the CHAPTER
In the CHAPTER
GRI
- 103-3 Evaluation of the approach to management
- 307-1 Cash value of penalties and total number of non-financial sanctions for non-compliance with the law and/or regulations on environmental protection
- 301-1 Raw materials/materials used by weight and volume
- 302-1 Energy consumption by the organization, taking into account the types of raw materials
- 302-4 Reduction of consumption of energy
In the CHAPTER
GRI
- 102-9 Description of the supply chain
- 102-11 Explanation of whether and how the precautionary principle is addressed by the organization
- 102-15 Description of key impacts, opportunities and risks
- 102-16 Organization’s values, code of ethics, principles and norms of behavior
- 102-17 Internal and external mechanisms making it possible to obtain advice regarding the behaviors in ethical and legal issues and issues associated with the organization’s integrity
- 103-2 Approach to management and its elements
- 103-3 Evaluation of the approach to management
- 102-5 Organization’s form of ownership and legal form
- 102-18 Organization’s supervisory structure along with the commissions that report to the highest supervisory body
- 205-1 Actions assessed in terms of threats associated with corruption
- 205-2 Communication and training on anti-corruption policies and procedures in the organization
- 206-1 Legal steps taken against the organization for cases of violating the principles of free competition and monopolistic practices
- 405-1 Composition of supervisory bodies and employees broken down into employee groups by gender, age and other diversity factors
- 406-1 Total number of discrimination cases and corrective measures taken in this regard
- 419-1 Non-compliance with the law and socio- economic regulations
In the CHAPTER
GRI
- 103-2 Approach to management and its elements
- G4-FS13 Access points to sparsely populated areas that are less economically developed
- G4-FS14 Initiatives undertaken to improve access to financial services for disfavored persons
- G4-FS15 Policies for the fair design and sale of financial products and services
- 417-1 Internal requirements concerning the labeling of products and services and information regarding them
- 417-2 Incidents of non-compliance with regulations and voluntary codes concerning the labeling of products and services and information regarding them
- 417-3 Incidents of non-compliance with regulations and voluntary codes concerning marketing communications
Read more:
- Client at the center of attention
- Innovations
- Responsible sales
- Insurance
- Banking and strategic partnerships
- Working conditions
- Employee development
- Knowledge sharing
- Enhancing safety
- Health
- Improvement of living conditions in local communities
- Our impact on the natural environment
- Practical challenges in managing direct impact
- Products and adaptation to climate change
Business model
Employee
CSR
Environment
- Ethical foundations of business operations
- Preventing corruption and conflict of interests
- Diversity and respecting human rights
- Whistleblowing system
- Transaction security
- Risk management, taking into account non-financial risk
- Risk appetite
- PZU Group’s risk profile
- Reinsurance operations
- Polish and Baltic States insurance sector compared to Europe
- Regulations pertaining to the insurance market and the financial markets in Poland
- Non-life insurance (PZU, LINK4 and TUW PZUW)
- Life insurance (PZU Życie)
- International operations
- Contribution made by the market segments to the consolidated result
Risk and ethics
Market
Business
Financial results
Read more:
- Client at the center of attention
- Employee development
- Health
- Cultural patronage
- Practical challenges in managing direct impact
- Ethical foundations of business operations
- Diversity and respecting human rights
- Whistleblowing system
- Transaction security
- Risk appetite
- PZU Group’s risk profile
- Risk vulnerability
- Capital management
Business model
Employee
CSR
Environment
Risk and ethics
Read more:
- New approach to sales
- Working conditions
- Employee development
- Diversity and respecting human rights
Business model
Employee
Risk and ethics
Read more:
- Client at the center of attention
- Medical services (Health)
- Working conditions
- Enhancing safety
- Health
Business model
Employee
CSR
- Our impact on the natural environment
- Practical challenges in managing direct impact
- Diversity and respecting human rights
- Medical services (Health)
Environment
Risk and ethics
Business
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 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, a code of code of conduct, whistleblowing, conflict of interest management, and procurement. Those issues are also discussed during in-house training in 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 and entertainment cannot be so frequent, excessive or generous as to represent an actual or perceived risk of corruption, or breach local statutory or executive regulations.
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 the policy 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 and Pekao Group, which have separate regulations in this respect in place.
Comment made during a dialogue session
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.
PZU takes a number of actions, not only within the organization but also outside it, to promote the awareness regarding prevention of corruption. In 2018 the PZU Group participated in different initiatives aimed at developing best practices in the area of anti-corruption activities. These activities were conducted as part of PZU’s cooperation with industry associations, including, for example, the Compliance Association Poland, Polish Insurance Association and the Warsaw Stock Exchange Compliance Committee.
In 2018 PZU received the “Ethical Company” award thanks to, among others, implementation of anti-corruption programs in the PZU Group.
PZU, PZU Życie and Tower Inwestycje have in place an Anti-Corruption Program which reduces the risk of corruption. The Program defines examples of corruption and division of responsibilities to effectively control the risk in the company. The Program defines 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 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 2018 PZU adopted a mechanism for automatic (using an internal HR system) collection of employee representations confirming familiarization with and application of the Anti-Corruption Program.
After implementation of the Anti-Corruption Program all PZU employees were obligated to familiarize themselves with it and comply with its provisions and submit pertinent representations confirming familiarization with and application of the Program.
Ethical issues are en element of onboarding training for the newly employed. Additionally, in 2018, corruption risk was the subject matter of training courses delivered as part of the 2018 Compliance Week organized by PZU and PZU Życie. PZU also organized meetings with an external expert devoted to the question of corruption. In Q1 2019 an e-learning course dedicated to the Anti-Corruption Program will be launched.
With regard to suppliers, the corruption risk is a constant element of the purchasing process in place in PZU and PZU Życie. Each potential supplier is subject to corruption risk assessment on the basis of a dedicated risk assessment questionnaire. In addition, in accordance with the Anti- Corruption Program, each cooperation agreement between the company and a business partner should comprise anticorruption clauses. One of the clauses is a confirmation of acceptance of the anti-corruption standards prevailing in PZU by the supplier. In accordance with the internal procedures, entities cooperating with PZU and PZU Życie are informed about the Anti-Corruption Program in place in the company.
PZU has implemented solutions imposing an obligation to identify and assess corruption risk as part of the ongoing compliance risk management. The 2018 corruption risk assessment confirms that the system solutions work correctly and that actions aimed at managing this risk are taken with due diligence.
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 2018 the company was also preparing for implementation of a new e-learning training on the Anti-Corruption Program.
Building on the general rules laid down in the Anti-Corruption Program, PZU and PZU Group companies, excluding Armatura Kraków SA 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 eliminating the conflict of interest 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 company which analyzes the report.
All business units of the PZU Group are analyzed for corruption risk. One corruption case was identified in the PZU Group.
One case of corruption was recorded in PZU in 2018. In the case in question the company conducted clarification activities, ended with recommendations for the substantive units. Based on the collected findings the company terminated its cooperation with the employee pursuant to Article 52 of the Labor Code and made a decision to report a suspicion of crime. No corruption cases were recorded in PZU Życie.
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