MANAGEMENTEthics management and anti-corruption

Compliance System

PSE has implemented and is improving its Compliance System, which ensures that the company’s operations comply with the law, internal regulations and ethical standards. At the beginning of 2022, we adopted a Compliance Policy, which additionally covered environmental impact, occupational health and safety, and compliance with competition and antitrust laws. To emphasise the role of corruption prevention, a new dedicated Anti-Corruption Policy has been created. We are working to integrate the two scopes and strengthen the role of the ESG area in these documents, including by strengthening the role of the Representative for Sustainable Development. These updates are scheduled for implementation in the first half of 2024.

PSE employees are bound by the Code of Ethics, which is publicly available on 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 expected attitudes to the employees. In addition, for our contractors, we have posted the PSE Code of Conduct for Business Partners at 
www.pse.pl.

At our company, we have adopted the “zero tolerance” policy for all kind of fraud and misconduct, defined as both situations such as receiving monetary benefits from service providers, theft, disclosure of business secrets, and other unacceptable behaviour, such as mobbing and harassment. Each PSE employee is obliged to unconditionally comply with the “zero tolerance” principle for such behaviour.

The PSE Code of Ethics also includes elements of diversity. We comply with the law on non-discrimination in employment on grounds such as gender, age, disability, race, religion, nationality, political opinion, union membership, religion, as well as on grounds of the form or duration of employment.

We also periodically conduct educational activities to raise employee awareness in the area of compliance. Employees are sensitised to these issues as early as the initial training called Compass for the Start. In 2024, we plan to provide mandatory e-learning training again for all employees on the PSE Compliance Policy.

Whistleblowing is also an important part of the compliance system. In 2023, we implemented a full whistleblower protection system in accordance with Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law. The implemented platform for handling reports ensures that they can be delivered anonymously. To meet the needs of reporting persons, PSE provides multiple channels for reporting identified irregularities. Below we list opportunities for internal and external stakeholders to report them:

  • via the https://dajznac.pse.pl/ platform (for internal stakeholders),
  • directly to the Compliance Representative or the Anti-Corruption Representative,
  • by e-mail, sending a message to: sygnal@pse.pl (this can be done from the reporting person’s own or anonymous e-mail box),
  • by post (with a note: to the Compliance Representative or the Anti-Corruption Representative), by sending a letter signed with the reporting person’s name (with a return address) or anonymously to the registered address of Polskie Sieci Elektroenergetyczne S.A., ul. Warszawska, 05-520 Konstancin-Jeziorna.

Obligations of PSE employees and associates under the Compliance Policy

  • Transparent and non-discriminatory treatment of all PSE’s contracting parties and customers;
  • Reporting suspected abuses to the Compliance Representative;
  • Providing access to reliable and complete information on contract award procedures to prospecting contracting parties;
  • Refraining from disclosing any information to contracting parties that may put them in a privileged position over other contracting parties;
  • Disseminating the principles of the PSE Code of Conduct for Business Partners and make its contents available to contracting parties;
  • Refraining from disclosing or using for purposes unrelated to the performance of official duties commercially relevant information that is not information derived from publicly available sources or that is common knowledge;
  • Treating other employees, business partners and external stakeholders with due respect;
  • Exercising restraint in public statements about PSE Group companies;
  • Non-discrimination and non-harassment of PSE employees and associates;
  • Reporting the occurrence of misconduct 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;
  • Advising of the possibility of conflicts of interest;
  • Compliance with the law and ethical principles.

Preventing conflicts of interest 

The process for ensuring the avoidance and management of conflicts of interest for members of the highest management body in PSE, essentially boils down to the prohibition of competition (in a separate and individualised 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 a statement on meeting the independence criteria referred to in Article 9d(1a) of the Energy Law of 10 April 1997.

Information on conflicts of interest is not disclosed to external stakeholders.

Negative impact mitigation processes

The main process of mitigating the negative impact in the area of ethics is the delivery by the Compliance Representative of regular training to 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. 

In addition, free and anonymised 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. appeals, is carried out on the basis of the rules set forth in the Public Procurement Law. The remedies at law provided for iin this act are available to the contractor, competition participant and other entity if they have or had an interest in winning a contract or a prize in a competition and has suffered or may suffer damage as a result of a breach of the provisions of the act by the contracting entity. The provisions of the law specify the appeal body and its composition and form, as well as the manner in which a filed appeal is to be processed.

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 which business partners are expected to follow. The document is made available on our company’s website to everyone, not just those interested in engaging in cooperation with our company.

Identified irregularities can be reported by the business partner by contacting the Management Board’s Anti-Corruption Representative or Compliance Representative (including by post or email: sygnal@pse.pl or zgodnosc@pse.pl).

In 2024, we will also launch external reporting using the whistleblowing platform implemented at PSE.

In the case of transmission grid development projects subsidised with funds from the Operational Programme Infrastructure and Environment, irregularities or abuses may additionally be reported by email at naduzycia.POIS@mfipr.gov.pl, or using the form published at www.pois.gov.pl/strony/zglaszanie-nieprawidlowosci.

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 was one case of non-financial sanctions imposed, i.e. a letter of caution issued due to failure to meet the levels of electromagnetic fields in the environment for areas designated for residential development, i.e. on plot No. 81/11 in Gościszewo. A residential building was built in the operational right-of way of the existing line, which changed the land use of the area, which involves changing the electromagnetic field limits in the environment.
  • In terms of transmission operations, there was no case of non-compliance with laws and regulations resulting in fines or penalties.

Our anti-corruption efforts

PSE has an Anti-Corruption Policy and Anti-Corruption and Fraud Prevention Instructions in place.

In 2023, PSE continued its efforts to comply with the requirements of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law, which governs the protection of persons who report irregularities and breaches of which they have become aware in a work-related context. In order to implement these requirements, our company was carrying out work involving the adaptation of internal regulations to the legal environment prevailing in Poland at the time.

The company has a zero-tolerance policy for irregularities and abuses. In particular, “irregularities and abuses” are understood to include situations such as accepting financial or personal benefits from service providers, theft, and failure to keep company secrets. Each PSE employee is obliged to unconditionally comply with the principle of “zero tolerance” for abuses.

We have a whistleblower system in our organisation to report any situation that does not comply with company rules and policies. Irregularities can be reported openly or anonymously, among other ways by sending an e-mail to: sygnal@pse.pl. Any reporting 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.

In the case of transmission grid development projects subsidised with funds from the Operational Programme Infrastructure and Environment, irregularities or abuses may be reported by e-mail to: nadużycia.POIS@mfipr.gov.pl.

In 2024, we implemented software to handle whistleblower reports. We carried out an analysis of internal regulations, particularly with regard to the Whistleblowing Instruction, with a view to harmonising them and bringing them in line with EU requirements. We are also preparing to modify the internal anti-corruption system taking into account changes in the law, the company’s needs and requirements of the PN-ISO-37001 standard.

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

In 2023, our company did not report and was not a party to any proceedings related to the possibility of a corruption offence.

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