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Reputational risk associated with the identification of PZU’s activities with violations of compliance with international sanctions, compliance risk associated with inadequate implementation of Polish, EU and international laws governing the area of international sanctions into business and operational processes and failure to implement them correctly.
There are dedicated procedures in place at PZU that define the standards for managing sanctioning risk at PZU and PZU Życie. PZU designates a dedicated business owner of the area, who is responsible for the entire process, monitoring its quality and effectiveness, reporting, as well as for adhering to the prevailing procedures. The business owner of the process is responsible for, among other things, implementing solutions for the Company’s compliance with sanctions, supporting business units in the sanctions risk management process, protecting the Company’s interests, including its legal interests, financial interests in business dealings with other entities at home and abroad, and image in the financial market. The Security Department, owner of the Countering Money Laundering and Terrorism Financing area, has also been responsible for the area of international sanctions compliance since August 2022.
PZU and PZU Życie have a “PZU SA and Życie SA sanctioning policy” in place.
Sanctions policy
A Sanctions Policy has been implemented in PZU and PZU Życie. Under the Policy PZU and PZU Życie:
- do not cooperate with sanctioned entities,
- do not conduct transactions for sanctioned entities,
- use sanction clauses in contracts in which it identifies sanction risks,
- analyze sanction risks in the case of planned cooperation with entities subject to sanctions risks.
In addition to these measures, PZU and PZU Życie make every effort to ensure that the mechanisms implemented at the Companies for managing the risk of violating the international sanctions regime are effective, adequate and proportionate. Legal, financial and reputational risks are taken into account when performing a risk analysis. In view of the current geopolitical situation and the current legal status, PZU is constantly taking steps to introduce improvements and partially automate the process of managing the risk of violating the international sanctions regime.