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In all Group companies, Polish and foreign alike, separate whistleblowing procedures are in place1 . Employees are advised of the prevailing standards of conduct, inter alia as the new hires are being onboarded, under e-learning sessions and during on-site and online training courses.
The Whistleblowing System, has been in place in PZU and PZU Życie. It allows employees and entities working with PZU to report irregularities that may be deemed to be in violation of laws, internal regulations or standards of conduct, including ethical standards adopted by the Company. Information can be submitted both by name and anonymously.
In each case, the applicable “Whistleblowing Procedure in PZU SA and PZU Życie” provides the reporting party with confidentiality, discretion and protection of personal data. An employee who reports a potential irregularity in good faith is not at risk of any sanctions; nor does he or she incur any consequences pertaining to his or her employment relationship due to that report. The Whistleblowing System supports the application 1) Irregularity – action or omission by persons related to the company that may be deemed to be in contravention with the law, internal regulations or standards of conduct, including the ethical standards adopted by the company leading or that may lead to jeopardizing the company with compliance risk. of PZU’s ethical standards and the management of the accompanying risks.
Reports transmitted by clients are subject to examination in accordance with separate internal regulations defining the organization of the complaints handling process. The process for handling complaints is described in Complaints and grievances.
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Whistleblowing Procedure
Whistleblowing Procedure PZU and PZU Życie have a Whistleblowing Procedure in place, under which employees may report behavior that may be considered to be in violation of laws, internal regulations or standards of conduct, including ethical standards adopted by the Company, resulting or likely to result in the Company’s exposure to compliance risks.
Employees learn about the procedure at mandatory training sessions on compliance available, inter alia, on the in-house educational platform. It is also discussed at training sessions for newly hired employees. Information concerning the standards of dignity, including precisely how to report irregularities is also regularly disclosed to external entities cooperating with PZU, among others, to agents and business partners.
Responding to irregularities is in the interest of PZU as it helps to prevent the occurrence of similar incidents in the future, minimizes the extent of losses, and allows the organization to maintain transparency in its operating rules and a high standard of professional relations. Whistleblowers and those affected can count on discretion, protection of personal data and full confidentiality of the information obtained.
Pursuant to the “Whistleblowing Procedure in PZU SA and PZU ŻYCIE SA”, all the information on irregularities may be reported via the following communication channels operated by the Compliance Department:
- dedicated hotline and fax;
- traditional mail to the address of the compliance unit;
- dedicated e-mail addresses;
- dedicated form;
- in person: directly to an employee of the compliance unit.
| Number of reported suspected irregularities in PZU and PZU Życie | 2022 | 2023 |
|---|---|---|
| PZU and PZU Życie | 110 | 119 |
| Number of confirmed cases of irregularities | 2022 | 2023 |
|---|---|---|
| PZU | 39 | 67 |
| – including PZU SA and PZU Życie | 22 | 28 |
Best practices of PZU and PZU Życie
Whistleblowing Procedure – Reports and Proceedings:
- thanks to the various forms of contact with the compliance unit, an employee may file a report in the form he or she likes like and at his or her convenience, 24 hours a day, 7 days a week;
- in accordance with the “Procedure” in force, Compliance Department employees run the proceedings on reported irregularities in PZU and PZU Życie. The person conducting a given case coordinates the actions taken during the explanatory proceedings; he or she also analyzes the factual circumstances and the legal status specified in the notification;
- the person overseeing the Compliance Department is notified in every instance of the outcome of the proceeding concerning cases of significant importance to the company’s interests, while if the notification pertains to that person – then the President of the Management Board of the company is notified. The execution of the recommendations given after completing proceedings is subject to monitoring by the Compliance Department and is reported to the company’s Management Board and Supervisory Board as part of regular reporting on compliance risk.
Regulations in subsidiaries
The entities belonging to the PZU Group have independent mechanisms for reporting information concerning the suspicion, possibility or occurrence of irregularities or abuse.
Employees of each of the entities become familiar with internal regulations on the whistleblowing procedure, and cases are handled by dedicated compliance units.
PZU’s foreign insurance companies also have whistleblowing systems in place. Breaches can be reported by e-mail, in writing or in person to a compliance unit employee.
In all of the PZU companies in the health segment, a compliance regulation package has been implemented, including a whistleblowing procedure.
Regulations in subsidiaries – banks
An expression of Bank Pekao’s engagement in promoting corporate culture that supports ethical behavior, in keeping with the law and the Bank’s ethical standards and procedures, is the “Whistleblowing Policy in Bank Pekao S.A.”. The purpose of the Procedure is to create safe whistleblowing environment for reporting actions or omissions in the bank that are inconsistent with applicable laws or designed to circumvent them, that violate internal regulations or violate ethical standards. The procedure is also intended to ensure that reported problems are received, analyzed and properly managed, the person making the report in good faith will be protected from possible retaliation.
In 2023, 10 breach reports were filed in the Bank Pekao via the whistleblowing mechanism. In the other Companies of the Pekao Group, there was one such a report.
Alior Bank attaches great importance to properly organizing the whistleblowing system so that employees may easily and freely transmit information or share their doubts. To this end, the Bank has introduced a “Policy of Irregularity Reporting and Whistleblower Protection”. The Policy defines the procedures reporting and examination of irregularities in the workplace, and the rules of protection of the whistleblowers against vengeful responses. The Whistleblowing and Whistleblower Protection Policy is supplemented by the Policy of Workplace Environment Free from Undesirable Conduct and a Procedure Defining Steps to be Taken to Report Undesirable Conduct in Alior Bank S.A. that provide detailed rules of actions to be taken by the employer if an irregularity in the workplace has been reported.
Alior Bank provides its employees with many communication channels available for whistleblowing. A report can be made by phone, in writing or by e-mail to dedicated e-mail addresses, including directly to the Members of the Management Board or of the Supervisory Board. The adopted whistleblowing system facilitates the maintenance of anonymity. The Bank absolutely prohibits any repressive, discriminatory or other unfair treatment to an employee who has reported a violation. It also ensures confidentiality in case the reporter has revealed his or her identity or the identity can be determined. The Bank has an information policy aimed at spreading awareness among employees about the rules for reporting violations and protecting whistleblowers.