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.