Reporting problems of an ethical nature - “all of us have a duty to act in accordance with the highest ethical standards and the law. We are obligated to report all our doubts regarding problems of an ethical nature and activities in violation with the law and internal regulations. We acknowledge that this information is conveyed voluntarily and in good faith. In circumstances evincing doubts we may approach our immediate supervisor or report the same to the Whistleblowing System in operation in PZU Group entities.”
“Our STABILITY is a very important value provided to our clients. Everyone who has chosen PZU’s offer may be sure that it is starting cooperation with a secure and trustworthy company, an honest business which offers reliable products. The image of a stable company is not developed or bought fast - it represents years of hard work and millions of decisions. Stability is also important for PZU employees - for whom it stands for care about their professional development, career opportunities in the company, and secure forms of employment.”
“I would like to learn more about the development of ethical culture in the PZU Group. It was mentioned a number of times in the last year’s report. However, the issue itself seems to refer to a much broader spectrum, because nowadays ethical matters are rapidly growing in importance, especially in the world of finance. It seems to me that you are doing much more in this field than presented in the report. Please elaborate”. „The development plan of corporate culture and corporate governance”
Comment made during a dialogue session
“How does the PZU Group deploy a culture of ethics? What are the key challenges in this area and what will the Group focus its efforts on over the next one or two years?”
Comment made during a dialogue session
“The PZU Group is the largest financial group in Poland, comprising a diverse range of entities operating in many markets (insurance, banking, investment, health care and other). The development of a culture of respect, in the organization and on the part of cooperating entities, for the principles and requirements of business ethics, law, soft law and fair relationship with clients and consumers is a continuous process. For many years now PZU has been setting the highest market standards in Poland in this respect. A mature organization responds proactively to changes in its environment - both internal and external - by consistently adapting its resources and activities to current needs. The compliance area in the PZU Group is organized in a similar way - we exercise foresight about the future and adapt our activities to needs and identify potential gaps and threats that may have an impact on our organization’s compliance in the future; we also focus on continually raising awareness of our employees. It is only such a pro-active approach that can guarantee a culture of dedication to achieve a shared objective, while abiding by our values and ethics.”
The ethics management system in the PZU Group has been established and operates based on group agreements and practices. It is an integrated set of values, rules of conduct, tools, including procedures and regulations for employees and the personnel responsible for managing the system, 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 (the so-called Whistleblowing System),
- educational and communication activities addressed to employees and suppliers.
The Best Practice Collection is 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 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 members of 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.
The New Best Practices of the PZU Group were introduced in 2018. This document is a uniform model of the standards observed by all PZU Group entities, except for the Armatura Kraków Group and Ardea Alba in liquidation (formerly PZU Asset Management); and the Alior Group, and Pekao, which operate 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’s Best Practices describe the fundamental rules of conduct of employees, giving examples of many situations, e.g.:
- conflict of interest,
- handling sensitive information,
- receiving potentially inappropriate gifts,
- sales of a product with inherent compliance risk,
- investment of private funds in PZU shares,
- public provision of information or writing a blog,
- and many other.
|Values of the Group PZU
||Our promise to the client
||Our promise to the em-ployee
- Safe and trustworthy business operation
- An offer of reliable products
- Care for employee development and career opportunities in the PZU Group
- Secure forms of employment
- Transparent rules of communication
- Keeping promises
- Fulfilling obligations
- Clear operational principles of the organization
- Knowing clients’ needs and seeking new solutions
- Setting trends in the financial services market
- Thinking out of the box
- Actively seeking improvements in the company’s operations
- Being responsible for our clients at every stage of their lives
- Conscious choices thanks to educational and prevention activities
- Taking into account the potential impact of decisions on employees
- Involvement in socially responsible activities
Both Alior Bank and the other Alior 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.
PZU Group’s ethical culture is developed 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 ethical values which reflect the fundamental principles of compliance. The most important events in this area 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.
- 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.