Counteracting corruption

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.

* _{Corruption – it is a direct or indirect demand, acceptance, provision or promise to provide a 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.
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.
Material benefit – this is a material benefit given or received by an employee in connection with his or her position or function in the company net of his or her salary and other benefits due in connection with acting in this function and souvenirs given customarily whose unit value is not subject to personal income tax..
Personal benefit – this is an immaterial benefit augmenting the standing of an employee, his or her loved ones or persons or organizations with whom or with which he or she closely cooperates or cooperated on a professional, business or personal footing}

According to the rules prescribed by this Program, companies conduct business in accordance with the law in an honest manner and 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 “Anti-Corruption Program in PZU and PZU Życie” defines the business areas in which corruption risk is potentially the greatest and specifies symptoms of unethical employee conduct. Mechanisms to identify and monitor corruption risk function in those areas of business that are particularly susceptible to corruption risk.

Mandatory regular and periodic corruption risk assessments – among other things, corruption risk self-assessment questionnaires conducted among employees, registered notifications of irregularities in specific areas, results of internal inspections and reports of non-governmental organizations dealing with corruption.

Trainings, publications, consultations are provided. All PZU and PZU Życie employees have been obligated to familiarize themselves with the Anti-Corruption Program and comply with its provisions and submit the pertinent representations in this respect. The training course pertaining to the Anti-Corruption Program is one of the mandatory training courses for all of the employees in these companies. PZU and PZU Życie employees submit declarations in the HR system that they have familiarized themselves with the “Program” and undertake to adhere to it and also that they are aware of the criminal liability for corruption. These actions are supplemented by anti-corruption training and campaigns executed in the corporate communication channels, attracting the employees’ attention to the corruption risk.

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 satisfactorily met the basic needs of the organization.

In 2022, all business units of PZU and PZU Życie were analyzed. In 2022, corruption risks did not materialize at a level that threatened PZU’s business in terms of operational and reputational risks.

In the PZU Group’s subsidiaries, areas of counteracting corruption are regulated under adopted anti-corruption programs and codes of ethics.