Prevention and Detection of Corruption and Bribery

W There is zero tolerance for any form of corruption in the PZU Group. The organization’s implemented solutions define the method of corruption risk management, including identification, mitigation and monitoring. The Group’s entities have in place internal  regulations to prevent corruption, including, inter alia, rules for accepting and giving gifts, conflict of interest management, and ethical principles to be followed by members of the company’s statutory bodies. Depending on the entity, they have been included in one or more documents as part of anti-corruption programs and codes of ethics in place. The issues are also discussed during internal employee training.

The rules for Group employees to accept and give presents and the rules for registering them have been strictly defined. Gifts and entertainment, of small value only, may be offered or accepted only for the purpose of building business relationships or in connection with showing courtesy in relations with a client or business partner. Under no circumstances can money or its equivalent be offered or received. Giving and receiving gifts cannot be so frequent, excessive or generous as to represent an actual or perceived risk of corruption, or breach local statutory or executive regulations.

In 2023, PZU and PZU Życie in 2023 obtained certification of the Anti-corruption Management System in accordance with ISO 37001 awarded by the Polish Center for Testing and Certification. The certificate confirms the companies’ commitment to systemic prevention and counteraction of corruption risks.

In keeping with the rules prescribed by this Program, companies conduct business in accordance with the law in an honest manner, and they counteract any and all forms of corruption which may be linked to their business. In turn, their employees are obligated to act ethically and in compliance with the law in favor and on behalf of PZU and to avoid factors increasing corruption risk. Employees are prohibited from proposing, promising, giving or demanding any material or personal benefits in order to manipulate a pending decision, including the usage of gratification. The AntiCorruption Program has identified areas of activity that are particularly vulnerable to corruption. These include:

The areas have mechanisms in place to identify and monitor corruption risks, such as:

• systemic activities undertaken by the PZU Compliance Department, including systemic corruption risk assessment and anti-corruption education;
• operational activities undertaken in business units in areas particularly vulnerable to risk, in particular, among others:
  • measures to reduce the risk of corruption in the area of cooperation with business partners and clients, i.e., purchasing processes are conducted so that the principles of fair competition are observed, and
  • measures to reduce the risk of corruption in the human resources area, among other things, the system of bonus remuneration for employees does not provide an incentive for illegal activities and ethical standards.

Non-compliance with the provisions of the Program constitutes a breach of employee duties and is subject to the labor law sanctions. Corruption is also an act that may be subject to civil liability or criminal liability if the act has the features of crimes that are referred to in the Criminal Code.

PZU has mechanisms in place to identify and monitor corruption risks.

Corruption risk assessment is part of PZU’s systemic compliance risk management, as part of the implementation of the provisions of PZU’s AntiCorruption Program, and it is conducted once a year. Aggregated assessment results are presented to the PZU Management Board. The implementation of the assessment aims to increase the value of PZU by consciously managing the magnitude of estimated corruption risks and preventing the adoption of risks at levels that could threaten the security of the company. In addition, the results of the assessment form the basis for the measures taken to strengthen the control mechanisms in PZU regarding these risks.

PZU and PZU Życie employees submit declarations in the HR system that they have familiarized themselves with the Anti-Corruption Program and undertake to adhere to it and also that they are aware of the criminal liability for corruption. The training courses pertaining to the AntiCorruption Program are among the mandatory training courses for all of the employees in the companies. They are conducted in the form of e-learning for newly hired employees during onboarding and as an annual refresher course for all employees. The actions come with anticorruption training, publications, consultations and campaigns via the corporate communication channels. They attract the employees’ attention to the corruption risk.

Board members are provided with information about the Anti-Corruption Program in the form of training material upon taking office. They also make declarations in the HR system that they are familiar with the Anti-Corruption Program and that they agree to comply with it.

The policy has been communicated and is available to PZU affiliates and business partners.

All persons affiliated with PZU, i.e.: board members, employees, associates, intermediaries, are obliged to comply with the Policy and act with integrity and honesty, in accordance with the law, ethical standards and the provisions of the document. The same obligation is placed on PZU’s business partners.

In the event of a violation of the Policy or anti-corruption regulations, PZU will take legal action under relevant internal regulations or laws.

Investigations into cases of suspected crime, including corruption, are handled by the Security Department, and those investigating reported incidents of corruption are separate from the chain of management structures involved in the case. The Security Incident Investigation Manual does not require reports on all investigations, including corruption cases, to be submitted to Members of the Management or Supervisory Boards. If materials are collected in the case that indicate that a crime has been suspected, it is referred to the Legal Department for formal and legal analysis and subsequent notification.

If a significant event occurs, the Board Member overseeing the Security Department is informed. Oneoff matters may be submitted to a Board meeting. The Security Department submits an annual report to PZU and PZU Życie Management Board Members on security at PZU Group companies in the areas of crime risk, information security, including cyber security, physical security and business continuity.

At PZU, corruption risk management is built into the Company’s business operations. The organizational arrangements adopted meet the basic needs of the organization. Lines of responsibility for corruption risks remained clearly assigned at every stage of the management process, from identifying corruption risks to mitigating and monitoring them. The organizational arrangements adopted are satisfactory given the basic needs of the organization.

¹ Corruption – it is a direct or indirect demand, acceptance, provision or promise to provide an undue material benefit or a personal favor in exchange for taking or not taking an action in connection with a function in PZU. Gratification is a form of corruption. It involves making small and unofficial payments or some other types of benefits to procure the accelerated execution of a routine activity, which the party delivering the gratification has the right to receive.

² Bribe – a form of corruption that involves giving or receiving a present, loan, fee, award or some other material or personal benefit to or from another person as an incentive for a dishonest or illegal action or breach of trust in the course of the company’s business activity.