In our organisation, we have implemented and have been improving the compliance system ensuring that the company's actions comply with the law, internal regulations and ethical standards. In 2021, a new version of the Compliance Policy was created, which additionally covered environmental impact, health and safety and compliance with competition and anti-trust law. In addition, a new dedicated Anti-Corruption Policy has been created to emphasise the role of corruption prevention.
MANAGEMENT (G)Ethics management and anti-corruption
PSE employees are bound by the Code of Ethics, which is publicly available in the internal network (intranet). The Code is an important element of the HR Policy defining the attitudes expected from the employees. In addition, having our contracting parties in mind, we have posted the Rules of Conduct for Business Partners in the external network (on the website).
The implemented and applied PSE Code of Ethics also takes into account elements of diversity. We comply with the law on non-discrimination in employment based on, among others, gender, age, disability, race, religion, nationality, political views, trade union membership, religion, and based on the form or duration of employment.
We have adopted a zero-tolerance policy on all types of fraud and inappropriate behaviour, which includes situations such as accepting material benefits from service providers, theft and failure to keep company secrets, as well as other forms of unacceptable behaviour such as mobbing and harassment. Every PSE employee is required to unconditionally adhere to a zero tolerance policy regarding fraud and inappropriate behaviour.
Our employees can report any fraud anonymously to an e-mail address provided on the home page of the intranet site, as well as using the contact phone number of the Compliance Representative. We have also started work on launching a dedicated external reporting platform. We have planned an educational campaign on this topic for 2022.
Total number of incidents related to discrimination, and corrective actions taken on this issue in 2020
We operate a regular “Compass Towards a Start” programme dedicated to new hires. Its component is the compliance system, including ethical behaviour. In 2021, mandatory e-learning training was provided to all new PSE employees, separately on the Code of Ethics and on the Compliance Policy.
A conference on corruption prevention, values and ethics of our company is planned for PSE contracting parties in 2022. Implementation of the plan will depend on the epidemiological situation.
Our anti-corruption efforts
In 2021, the anti-corruption and anti-fraud system in place at PSE was supported by a new internal regulation – the Anti-Corruption Policy. The basic premise behind the introduction of this document was the need to send a message both inside and outside the company (contracting parties, suppliers and contractors): “Zero tolerance for corruption and fraud”.
Actions taken in 2021 to prevent corruption in PSE
A service provider has been selected for the delivery of software to handle reports from whistleblowers. Thus, outsiders as well as employees, partners and other parties will gain a tool for anonymous reporting of irregularities in the area of corruption and compliance. Until the aforementioned reporting platform is introduced, a dedicated e-mail address (email@example.com) will remain one of the company's channels for reporting irregularities. The information on the reporting channels, together with the telephone number of the Management Board Representative for Counteracting Corruption, has been published on the official PSE website under the subsection „System przeciwdziałania zagrożeniom korupcyjnym i nadużyciom [A system for prevention of corruption and fraud threats]. PSE also publishes a permanent announcement with the contact details of the Representative for Counteracting Corruption on the intranet site (PSE's internal website). The way and opportunity to communicate irregularities that one has witnessed is also part of the information for new PSE employees as part of a training course called “Compass Towards a Start”.
For transmission grid development projects that are subsidised with funds coming from the Operational Programme Infrastructure and Environment, irregularities or fraud may be reported by e-mail at naduzycia.POIS@mfipr.gov.pl or by using the form published on the following website: www.pois.gov.pl/strony/zglaszanie-nieprawidlowosci.
All members of the Management Board of PSE S.A. have accepted the Anti-Bribery and Anti-Corruption Policy of PSE.
The introduction of the Anti-Bribery and Anti-Corruption Policy has been communicated to all PSE employees.
As part of every contract we conclude (a new one or an annex), through the relevant contractual clauses, PSE requires our business partners to familiarise themselves with the Anti-Bribery and Anti-Corruption Policy. In addition, PSE requires our contracting parties to always confirm in writing that they are committed to the prevention of corruption offences and that their actions are not and will not be affected by such fraud.
The company has also undertaken work in 2021 to broaden the scope of the contracting party credibility testing, also in the context of corruption risks. Agreements, draft internal regulations, agreement annexes and Requests to the Management Board are reviewed for potential irregularities or abuse.
In 2021, our company neither reported nor was a party to any proceedings related to a possibility of a corruption offence