-
2-15
-
2-25
A situation of potential conflict of interest that may impede the effective and objective performance of work for the PZU Group.
Any situation of potential conflict should be reported by the employee to the supervisor and the compliance unit of the PZU Group entity for discussion and clarification.
Rules for managing conflicts of interest of PZU SA and PZU Życie; Rules for acceptance and giving of gifts of PZU SA and PZU Życie.
-
2-15
Conflict of interest management
The “Rules for managing conflicts of interest” are in force in PZU and PZU Życie. This regulation aims to ensure professional, reliable and fair treatment of all clients and persons related to the company in a conflict of interest situation. According to this regulation an employee should report a potential conflict of interest to his or her boss and the compliance unit in a given company for that unit to be able to analyze that situation thoroughly from the standpoint of risk. When a potential or actual conflict of interest is identified, mitigating mechanisms are used to eliminate or reduce the conflict of interest and counteract its negative effects. There is also a conflict of interest register. The companies limit the possibility of a conflict of interest arising and counteract its consequences, especially by:
- informing clients using financial instruments about the adopted regulations on managing conflicts of interest;
- acting in the interest of the client and promoting fair and professional conduct among persons affiliated with the Companies, who participate in the honest product life cycle;
- limiting the scope of persons with access to certain information and resources;
- enforcing persons affiliated with the Companies to comply with restrictions on accepting and giving gifts in business relationships;
- limiting the possibility to represent the Companies’ interests by employees who are affiliated with persons in business relations with the Companies;
- limiting and monitoring the implementation by employees and the Companies’ Management Board members, in particular those responsible for investment activities, of certain transactions entered into on their own account, in particular by prohibiting transactions involving the disclosure or use of information on financial instruments that violate generally applicable laws;
- entering into non-competition agreements with employees with access to material, protected information on the Company.
In mitigating the conflict of interest risk, members of PZU’s corporate bodies are obliged to:
- avoid activities that may give rise to conflicts of interest;
- take necessary measures to identify conflicts of interest;
- obtain approval (from the Management Board or the Supervisory Board or the Shareholder Meeting, as appropriate) for membership on the supervisory or management boards of public companies other than PZU Group companies, and entities whose operations may potentially be deemed as competitive;
- strive to eliminate or reduce the negative impact of conflicts of interest on the operation of the PZU Group company and its relations with the remaining PZU Group companies, clients and other external entities;
- inform (the Management Board or the Supervisory Board or the Shareholder Meeting, as appropriate) of a conflict of interest or the possibility of a conflict of interest, and to refrain from taking part in discussions and voting on a matter in which a conflict of interest has arisen;
- to inform the compliance unit of the possibility of a conflict of interest and the measures taken.
Issues of possible conflict of interest for members of the management board and the supervisory board are also reviewed as part of an assessment of suitability prior to appointment to these bodies and as part of regular secondary assessment of suitability. An annual analysis of additional actions taken by members of corporate bodies is also carried out.
Other PZU Group companies also have regulations governing the management of a conflict of interest, adjusted to standards set out by PZU and adequate to their profile and scope of operations.
Managing conflicts of interest – accepting and giving gifts
The rules in PZU and PZU Życie regulate in transparent and very detailed terms the categories and types of gifts, including permissible and impermissible gifts and they prescribe the procedure for accepting or offering gifts and the rules for registering gifts. These rules are in force regardless of the position held or function discharged in the company. Rules of acceptance and giving gifts are in force in all the PZU Group companies.
Conflict of interest – training
Topics concerning conflicts of interest, potentially risky situations and the rules of conduct if they are detected, are part of the e-learning training course on compliance. Such training is obligatory for every new employee and also available for all PZU and PZU Życie employees. These topics are also discussed during on-boarding training courses for newly-hired employees. Furthermore, employees submit declarations on adhering to the “Rules for Managing Conflicts of Interest”.
Best practices of subsidiaries
Regulations at subsidiaries
Conflict of interest management rules apply to all PZU Group companies
Regulations in subsidiaries – banks
Conflict of interest management at Alior Bank Group is regulated in the Conflict of Interest Management Manual”. In this document employees will find responses to questions on how a conflict of interest is defined and how its potential and actual outcome are determined and how they should conduct themselves to avoid a conflict of interest. These instructions govern material elements such as the rules for employees to deal with relatives, accept gifts and invitations and conduct gainful activity outside the Group. This document also clearly specifies the rules pertaining to the official ties between relatives while emphasizing the elimination of the risk of nepotism. Alior Bank periodically reminds employees of situations in which conflicts of interest may arise and points out the rules of conduct in such cases.
The Pekao Group applies the Conflict of Interest Management Policy in the Pekao Group, which specifies the rules for managing conflicts of interest and defines the circumstances that trigger or may trigger a conflict of interest in the Bank’s operations.