We are a big company, employing over 41,000 people. For such a large organisation, setting out shared values for an exceptionally diverse group of employees is a great challenge. We undertook this challenge, spent hundreds of hours working on it, with the help of hundreds of employees from the entire Group. Therefore, we are especially proud of the fact that we have in place since 2016 a key document related to our organisation's ethical culture - PGE Code of Ethics. This set of rules and values, constituting the basis for creating our own organisational culture, serves as a foundation for our organisation's operations and the achievement of strategic objectives.
At PGE Group, we are committed to observing the law and ethics rules. We conduct our everyday business and work in accordance with this commitment. PGE Group is a place for those who value ethics rules and the law.
We believe that ethics have much greater impact on the observance of law than the law itself. Even the best legal system is useless when confronted with a lack of an ethics culture in the organisation. Illegal activities may be explained by errors of individual employees, but the person breaking the rules had to have the opportunity to do it. A solid ethical culture may help companies in trouble caused by the actions of individual employees.
We are certain that all values - even corporate ones - start and end with the human being. Corporate values thus also come from us - individual people, employees. Therefore, the observance of corporate values most importantly depends on the personal values of each one of us.
We believe that all of our employees identify with the values and rules instilled in the Code.
Code of Ethics values and rules in everyday work
The Code specifies the attitudes and behaviours that are expected of all employees and managers. The Code streamlines and collects in one place rules that employees should follow inside and outside the organisation, in contacts with business partners or co-workers (link)
First of all - awareness
To ensure that the Code is known, understood and respected, we are holding workshops across PGE Group for employees and management. First, we invited colleagues from inside the Group, who became internal trainers for the Code of Ethics. Training the trainers, numerous meetings and discussions to explain objectives, materials, exercises and all other doubts. Finally, the time, involvement and hearts of our internal trainers dedicated to best prepare and conduct training. Currently, we have approx. 100 internal trainers. Trainers conduct training across all business lines and segments.
Workshops are conducted in a very active fashion, where participants talk about what makes honest behaviour easier or more difficult; they learn about PGE Group's rules and present their own perception of them.
In addition, in the course of active discussion, they present attitudes that personify our values: Partnership, Development, Responsibility, and propose to introduce specific organisational solutions at their unit or across the entire Group. These conclusions then serve as basis for implementing the best initiatives. These workshops were connected with training in PGE's Good Procurement Practices, conducted by the Purchasing division.
Every new employee within the Group undergoes individual adaptive training shortly after starting work at PGE Group companies, where he/she finds out about the existing Code, the law and the obligation for employees to react to any potential irregularities. New employees get a chance to learn the details of the Code at adaptive group training called "Turn on the power" (approx. 650 people). These training sessions are conducted entirely by Group employees.
The Code of Ethics has been distributed throughout the Group in print form, also in English. Furthermore, posters and flyers presenting PGE Code of Ethics values and rules have been put out at locations - facilities and offices.
Additionally, other training was conducted at the Group, in particular training related to combating corruption and preventive counter-intelligence measures.
Secondly - communication
The Code of Ethics is available to Group employees on the Group's Intranet as well as in paper form. It is also available at the Group's website. The content of the Code has been expanded upon in numerous thematic publications in PGE Group's internal publication "Pod parasolem" and on the Intranet. This content is presented to employees in a cascading manner where they have a chance to discuss values with their superiors and ask them questions.
In communications related to the Code of Ethics, employees' personal responsibility for their actions is emphasised in accordance with PGE Group's ethical values and rules expressed in the Code as well as internal regulations, which further detail our processes and procedures.
Thirdly - counteracting violations every day
Adopting the Code and clearly communicating the rules contained therein has a straightforward objective: support PGE Group's Strategy as the most effective and flexible energy group in Poland and minimise the risk of non-compliance, which could result in penalties or sanctions being imposed or reputation being lost as a result of a failure to adapt to regulations and standards that are stated in law or constitute best practices in this area.
In order to implement rules from the Code of Ethics, the following tasks were completed in 2017:
- Training was conducted for PGE Group employees by the Group's internal trainers. Over 36,000 of PGE Group's staff participated in this training. In the first training cycle, dealing with the Code of Ethics, as of December 31, 2017, 97% of PGE Group's workforce was trained.
- In addition, training was conducted on protection of information, as well as anti-corruption training and a series of lectures by officers from the Central Anti-Corruption Bureau and the Internal Security Agency.
- A training process for new employees was implemented at the Group's companies, focusing on the Code of Ethics, at the adaptive stage, directly after hiring. Adaptive training is conducted by compliance coordinators or internal trainers.
- In 2017, an array of internal communication campaigns was conducted to build amongst employees knowledge and awareness of compliance. These campaigns involved workshops, the distribution of the "PGE Group's Code of Ethics" brochure, posters, flyers and publications on the Intranet and the internal employee magazine "Pod Parasolem."
Rules for cooperation
At the end of 2017, PGE Group adopted the Code of Conduct for PGE Group's Business Partners ("Code of Conduct"). According to the Code of Conduct for PGE Group's Business Partners, we work only with those suppliers and other business partners that conduct business in a fair manner. Relations with our business partners are based on mutual trust, respect and professionalism. Purchasing and procurement are done based on transparent and objective rules, in accordance with the existing law and clearly defined internal procedures.
With a view towards ensuring the highest standards of doing business, we as PGE Group want to work with business partners who respect the law, identify with our rules and apply them in every-day business.
The Code of Conduct also sets out the minimum requirements for PGE Group's business partners as regards respect for human rights, working conditions, environmental protection and fairness in doing business.
We require the entities with which we cooperate to observe the same fairness standards that we obey. We have a standard set of contractual provisions for suppliers, subcontractors and business partners relating to workplace safety, fire safety, waste management, asset protection and environmental protection requirements.
All companies that have adopted the Code of Conduct for Business Partners publish it on their websites. Information on procurement procedures being conducted in accordance with rules contained in the Code of Conduct for Business Partners should be included in the Terms of Reference as well as in other procurement-related documents (e.g. template agreements). Business partners should read the code and submit a declaration on compliance in the course of the procurement procedure.