MANAGEMENTEthics management and anti-corruption

System compliance

PSE has implemented and has been improving the Compliance System, which ensures that the company's actions comply with the law, internal regulations and ethical standards. In 2021, we assumed a new Compliance Policy, which additionally covered environmental impact, occupational health and safety and compliance with competition and anti-trust law. A new dedicated Anti-Corruption Policy has been created to emphasize the role of corruption prevention.

PSE employees are bound by the Code of Ethics, which is publicly available in the internal network (intranet). The Code of Ethics, along with the Compliance Policy, addresses human rights. The Code is an important element of the HR Policy defining the attitudes expected from the employees.

The PSE Code of Ethics includes diversity elements as well. 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.

Obligations of PSE employees and associates under the Compliance Policy

Transparent and non-discriminatory treatment of all PSE contracting parties and customers;
Reporting of suspected anti-trust or competition and consumer protection fraud (abuses) to the Compliance Representative;
Providing access to reliable and complete information on procedures of contract awarding to prospective contracting parties;
Not disclosing any information to contracting parties that may put them in a privileged position over other contracting parties;
Disseminating the principles of the Code of Conduct to PSE business partners and making its contents available to contracting parties;
Not disclosing or using commercially relevant information that is not information derived from publicly available sources or that is common knowledge, for purposes unrelated to the performance of official duties;
Treating other employees, business partners and external stakeholders with due respect;
Exercising self-restraint in public statements about PSE CG companies;
Non-discrimination and non-mobbing of PSE employees and associates;
Reporting the occurrence of misbehaviour to the employer (mobbing, discrimination, harassment, etc.) and other forms of disrespect for labour law standards;
Anticipating and avoiding situations in which the private interests of PSE employees and associates could conflict with those of the company;
Informing about possible conflicts of interest;
Abidance by the law and ethical principles.

GRI 2-15

The process ensuring the avoidance and management of conflicts of interest concerning members of the highest management body in PSE, mainly boils down to the prohibition of competition (in a separate and individualized form) applicable to these members resulting from the contract that forms the basis of their employment with the company. In addition, members of the highest management body in PSE are required to submit the statement on fulfilling independence criteria referred to in Article 9d section 1a of the Energy Law (this follows from the order, Article 9 [1] section 10 of the Energy Law) and on the observance of loyalty principles.

If a stakeholder is an external entity, then conflict of interest information is not disclosed to stakeholders.

GRI 2-16

Communicating critical issues

1.	Description of whether and how critical issues are reported to the highest management body	The Compliance Representative reports directly to both the Management Board and the Supervisory Board of the PSE.
2.	Total number of critical issues that were reported to the highest management body during the reported period	47
3.	Categories (types) of critical issues that were reported to the highest management body during the reported period	Potential conflict of interest – 33
4.	Categories	Mobbing and employee rights - 6; Discrimination and unequal treatment - 2; Ethics - 3; Notifications related to GDPR and data protection - 3

GRI 2-25

Negative impact mitigation processes

The main negative impact mitigation process in the area of ethics is conducting by the Compliance Representative of regular training of PSE employees and associates on the ethical standards in force in our organisation, codified in the PSE Code of Ethics, and raising awareness of the significant role of compliance in the company’s activities.

Moreover, free and anonymized access to the Compliance Representative by PSE employees, associates and our contracting parties also plays a significant role in mitigating negative influences in the area of ethics.

In the case of public procurement, the complaint process, i.e. appeal, is carried out on the basis of the rules set forth in the Public Procurement Law. The legal protection measures specified in the above-mentioned act are available to the contractor, a participant of a competition and other entity if it has or had the interest in obtaining a particular contract or a prize in a competition and suffered or may suffer damage as a result of a breach of the provisions of the Act by the Employer. The provisions of the act specify the appeal body and its composition and form, as well as the manner in which a filed appeal is to be processed.

GRI 2-26

Our organisation has a Code of Conduct for business partners, which is a set of basic principles that PSE follows in its business activities and that business partners are expected to follow. The document is made available on our company's website to everyone, not just those interested in starting cooperation with PSE.

Any irregularities or fraud can be reported by email to the following address: naduzycia.POIS@mfipr.gov.pl or using the form published on the website www.pois.gov.pl/strony/zglaszanie-nieprawidlowosci, as well as by contacting the Management Board Representative for Counteracting Corruption or the Compliance Representative (via snail mail, email: sygnal@pse.pl or zgodnosc@pse.pl, as well as by telephone). In 2023 we plan to launch a dedicated external platform for notification submission.

GRI 406-1

Total number of incidents related to discrimination, and corrective actions taken on this issue in 2022

Description	Number of incidents	Percentage of incidents
Discrimination and unequal treatment*	0	0

*No identified cases of discrimination in 2022. In turn, two cases of unequal treatment of employees were reported, for which investigations were initiated and conducted accordingly. Those investigations have not revealed the existence of circumstances bearing the prerequisites of unequal treatment of employees.

GRI 2-27

Compliance with laws and regulations

In the reporting year:

No proceedings for non-compliance with laws and regulations were pending against PSE, and no fines or penalties were imposed.
There were no fines or non-financial sanctions for non-compliance with environmental laws and/or regulations.
No cases of non-compliance with regulations were identified.

GRI 2-26

Our anti-corruption efforts

The PSE has successfully implemented the Anti-Corruption Policy and the Anti-Corruption and Fraud Prevention System Instructions.

In 2022 PSE carried out activities to comply with the requirements of the Directive (EU) of the European Parliament and of the Council 2019/1937 of 23 October 2019 on the protection of persons who report breaches of Union law, which regulates the protection of persons reporting irregularities and breaches about which they have obtained information in the context of their work-related activities. In order to implement these requirements, our company carried out works involving the adaptation of internal regulations to the legal environment in force in Poland at the time.

GRI 2-26

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 organisation has a fraud notification (whistleblower) system intended for reporting any situation that does not comply with company rules and policies. Irregularities can be reported openly or anonymously, among other things, to the generally accessible e-mail box sygnal@pse.pl. Any notifying person (whistleblower), whether from inside or outside the organisation, can be sure of complete anonymity. In addition, PSE employees are covered by legal protection and protection against retaliation, which is guaranteed by the company's policies and procedures.

For transmission network development projects that are subsidized with funds from the Operational Programme Infrastructure and Environment, irregularities and fraud can be reported by e-mail at: naduzycia.POIS@mfipr.gov.pl

We have also initiated works on adapting the whistleblowing software to the specificity of the company. We have carried out an analysis of internal regulations, particularly with regard to the Whistleblowing Instruction, with a view to harmonizing them and bringing them in line with EU requirements.

GRI 2-25

Negative impact remediation processes

A description of the approach to identification of and responding to complaints, including a description of the complaint mechanism the organisation has established or participates in	Direct cooperation of the Representative with the Management Board, among other things, through the opinion of the Representative for Counteracting Corruption in the proceeding on all contracts and applications to the Management Board. Contracting Party Credibility Survey during ongoing bidding and procurement procedures, and their update prior to their closing and selection of a supplier/contracting party. Ex-Ante and Ex-Post ad hoc inspections.
The description of the process conducted by the organisation (or under which it cooperates), whereby the organisation remedies the effects of the negative impacts that were the result of its activities or to which it contributed	Collaboration with stakeholders during establishment of mutual contractual obligations and during service provision.
The description of how stakeholders who are the target users of the complaint mechanism are involved in the development of the mechanism, its monitoring, operation and improvement	Participation in the creation of contractual provisions.
The description of how the organisation monitors the effectiveness of the complaint mechanism and other remediation mechanisms and examples of the effectiveness of these processes, including feedback from stakeholders	Audits

GRI 205-1

GRI 205-2

Communication and training on the organisation's anti-corruption policies and procedures in 2022

Total number of employees in the organisation (according to GRI 102-8)	2,825
Percentage of employees who have familiarised themselves with the organisation's anti-corruption policy and procedures	The policy applies to all employees. Hence, a parameter is not monitored among existing employees. It is monitored in relation to new employees.
Number of employees who have received anti-corruption training	168
Percentage of employees who have received anti-corruption training	6%
Total number of members of management bodies	5
Number of members of management bodies who have familiarised themselves with the organisation's anti-corruption policies and procedures	5
Percentage of members of management bodies who have familiarised themselves with the organisation's anti-corruption policies and procedures	100%
Percentage of business partners to whom anti-corruption procedure has been communicated	100%
Total number of suppliers (may be an estimate)	4862
Number of suppliers who have familiarised themselves with the organisation's anti-corruption policy and procedures	0
Have anti-corruption policies and procedures been communicated to other people working for the organisation?	Yes
If yes, to whom?	Employees on B2B contracts

PSE’s anti-corruption policy is not a document published or provided to the contracting party for reading. The contracting party/supplier becomes familiar with and accepts the contractual clause known as the “Anti-Corruption Clause”, which is an integral part of any agreement to which PSE is a party.

GRI 205-3

In 2022, our company neither reported nor was a party to any proceedings related to a possibility of a corruption offence.

Percentage and total number of business units analysed for corruption risks, and the risks identified in 2022

1	Total number of business units in the organisation	22
2	Total number of business units analysed for corruption risk	22
3	Percentage of business units analysed for corruption risk	100%

Confirmed corruption cases	2022

Dismissal or disciplinary punishment of employees	0
Total number and nature of confirmed corruption cases	0
Non-renewal of agreements with contracting parties due to corruption policy violations	0
Corrupt litigation brought against the reporting organisation or its employees during the reporting period	0
In total	0

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MANAGEMENTEthics management and anti-corruption

System compliance

Management principles – corporate governance and organisational culture

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