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Whistleblowing Procedure in PZU and PZU Życie.
System
In all Group companies, Polish and foreign alike, separate whistleblowing9 procedures are in place. Employees are advised of the prevailing standards of conduct, inter alia at onboarding training for new hires, during e-learning and during on-site and online training courses.
The Whistleblowing System functions in PZU and PZU Życie companies since 2009. It allows employees and entities cooperating with PZU to report irregularities of an ethical nature. Information may be transmitted in name or 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 of PZU’s ethical standards as cited above 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.
Whistleblowing Procedure
Employees learn about the “Whistleblowing Procedure in PZU SA and PZU Życie” 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.
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.
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 most convenient form and time 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
| Number of reported suspected irregularities in PZU and PZU Życie | 2021 | 2022 |
| PZU and PZU Życie | 140 | 100 |
Commentary to 2022: all reported cases were handled in accordance with PZU’s regulations, including the “Whistleblowing Procedure in PZU SA and PZU Życie SA”; reports included cooperation with intermediaries/ distributors; suspected activities that were not in compliance with standards of conduct or regulations.
Regulations in subsidiaries
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
PZU LAB, PZU Pomoc TFI PZU and PZU Finanse operate the “Rules for Classifying, Documenting and Reporting Irregularities Detected by the Internal Control System”. This regulation is supposed to provide for homogenous standards of conduct if irregularities are identified that affect the achievement of targets. Furthermore, the companies: LINK4, PZU CO, PZU Finanse, TFI PZU and Tower Inwestycje operate their respective whistleblowing procedures. In TUW PZUW, the rules for identifying, reporting and dealing with irregularities are regulated in the Whistleblowing Procedure in TUW PZUW and the Procedure for Categorizing, Documenting and Reporting Irregularities Detected by the Internal Control System in TUW PZUW.
In all of the PZU companies in the health segment a compliance regulation package has been implemented, comprising, among others, 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 “Whistleblowing Policy in Bank Pekao S.A.” is to create safe channels for communicating about practices observed in the bank that are inconsistent with the prevailing law, internal regulations, unfair and unethical or unjustified suspicions about their occurrence and ensure that the reported problems are accepted, analyzed and duly managed, while the person reporting them in good faith will be protected against vengeance.
In 2022, 24 breach reports were filed in the Bank Pekao via the whistleblowing mechanism. No such reports were filed in the Pekao Group
Alior Bank attaches great importance to properly organizing the whistleblowing system so that employees may easily and without any concerns 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 Policy and whistleblower protection 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 this purpose. A report can be made orally, in writing or by e-mail to dedicated e-mail addresses, or 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 rules out the application of any repressive or discriminatory means or any other unfair treatment against an employee who has submitted a whistleblowing report and it also ensures confidentiality if the whistleblower reveals his or her identity or if it is possible to ascertain his or her identity.
| Number of confirmed cases of irregularities related to violations of the code of ethics | 2021 | 2022 |
| Grupa PZU | 60 | 39 |
| – including PZU SA and PZU Życie | 39 | 22 |
Commentary to 2022: most of the cases notified were related to irregularities in the sales area.