Whistleblowing system

In all Group companies, both Polish and foreign, separate whistleblowing procedures are in place.

In PZU and PZU Życie and in other PZU Group companies, employees are informed about prevailing standards of conduct, among others during on-boarding training on compliance and e-learning courses.

Entities cooperating with PZU and PZU Życie are obligated to provide pertinent information about the existence or functioning of a document regulating the ethical issues and standards of conduct in the given company.

All advice pertaining to ethical and legal aspects of conduct are provided anonymously, in full compliance with confidentiality principles. In 2018, 570¹ requests for advice were submitted in total. The level of satisfaction of the persons who took advantage of the services is high. All reported cases were carefully analyzed.

In all Group companies there are independent mechanisms for reporting information on existence, suspected existence or possible existence of irregularities, abuses and concerns regarding existence of irregularities.

In accordance with the Whistleblowing Procedure prevailing in the companies, all such information about irregularities or abuses can be reported through the channels operated by the Compliance Department using:

• dedicated hotline and fax;
• traditional mail to the address of the Compliance Department;
• dedicated e-mail addresses;
• dedicated Internet form;
• in person: directly to an employee of the Compliance Department.

The above mechanisms are available, among others, to employees, agents and other entities cooperating with the company on the basis of civil-law agreements.

In principle, in the remaining PZU Group companies, the system has been based on the solutions in place in PZU.

In accordance with the prevailing procedure, proceedings with regard to irregularity notifications are conducted by the Compliance System Team in the Compliance Department and, if they are absent or excluded, such proceedings are conducted by the Compliance System Team Manager. In the case of absence or exclusion of the aforementioned persons, the proceedings are conducted by the director of the Compliance Department.

The person conducting the proceedings analyzes the factual circumstances and the legal status specified in the notification and established in the proceedings.

PZU also has in place a Whistleblowing System which enables employees and entities cooperating with PZU to report issues of importance for the company’s legal and financial interest and irregularities of ethical nature.

Despite the independence of the breach notification systems, the structures operated efficiently and effectively. Reports summarizing the risks and breaches are presented to the management boards of individual Group companies. In 2018, in the entire PZU Group, there were 10 identified breaches of the rules of conduct pertaining to ethics and human rights. One case occurred in the Pekao Group, two in Link4 and eight in Alior Bank. As a result of these cases, the following sanctions were applied: disciplinary talk, transfer of the employee to a different entity, termination of the employment contract.

In Bank Pekao, the whistleblowing system is defined by the Whistleblowing Policy. It provides for the possibility of lodging anonymous (or non-anonymous) notifications of practices inconsistent with the applicable laws or internal regulations. All notifications are examined and processed properly. The Policy has not been implemented in the Bank’s subsidiaries, but some of them have developed internal procedures regulating this issue. These included, among others, Centralny Dom Maklerski Pekao, Pekao Bank Hipoteczny and Pekao Investment Banking.

In the Alior Group, the whistleblowing process and guarantee of anonymity for the whistleblowers are laid down by the Compliance Policy. The Bank ensures the possibility to use different communication channels. An employee may choose the way for reporting their comments and concerns in the way they find fit. Notifications can be submitted orally or in writing to the Regulation Compliance Department, by email to the dedicated address etyka@alior.pl, and by sending a message by mail or email from publically available websites, making it possible to send messages without specifying the sender’s address or in any other manner selected by the whistleblower. Notifications of breaches are forwarded to the Bank’s Management Board member responsible for the current functioning of the whistleblowing procedures. This role is discharged by the President of the Bank’s Management Board. If the notification pertains to the Bank’s Management Board member, the Bank ensures the possibility of reporting the case directly to the Chairperson of the Bank’s Supervisory Board to their email address. The operation of the etyka@alior.pl mailbox, coordination of verification of the reported breaches and the follow-up action is the responsibility of the Regulation Compliance Department.

Alior Bank has in place also a Policy of workplace free of undesirable behaviors, which additionally regulates the question of reporting irregularities in the case of undesirable behaviors such as mobbing, discrimination, harassment and sexual harassment.

In all Health Area companies a compliance regulation package has been implemented, comprising, among others, a whistleblowing procedure.

PZU’s foreign companies have whistleblowing systems in place. In Estonia and Ukraine a Whistleblowing Procedure has been implemented. Breaches are reported by email or in writing to the direct manager. In Lithuania each employee may anonymously report a breach or abuse via the Intranet. Upon receiving a notification, the abuse prevention manager carries out an inspection based on the received information and submits the results of the investigation to the company’s Management Board.

¹ Data for PZU and PZU Życie