| Ethics aspects |
| No. |
Identified non-financial risk |
Method to prevent risk materialisation |
Risk level* |
| 1 |
Risk of corruption and bribery. |
- Compliance with the principles set out in the PGNiG Group AntiCorruption and Gift Policy, the PGNiG Group Code of Ethics, the PGNiG Group Ethics and Compliance Management System and the Transparency Policy for Managers. In particular, these documents support and regulate the management of the above risks.
- Information and education activities addressed to employees to improve their understanding of pertinent regulations and values and to raise their awareness of potential consequences of violations, including ethics and anti-corruption training.
|
medium |
| 2 |
Loss of the Company’s reputation and image as a reliable and trustworthy organisation may have far-reaching negative legal consequences. |
- Legal regulations adopted by the Group, i.e. the PGNiG Group Anti-Corruption and Gift Policy, the PGNiG Group Code of Ethics, the PGNiG Group Ethics and Compliance Management System.
- Making employees aware of the applicable regulations, availability of documents, obligation to know the regulations in place and staff training.
|
low |
| 3 |
Risk of a corrupt employee using the Company’s assets to the Company’s detriment, including the following violations:
- fraud (misrepresentation concerning the provision of a service),
- theft of property,
- obtaining and unlawful use of any information constituting trade secrets, commercially sensitive information,
- personal data or classified information,
- tampering with reported data in order to avoid disciplinary measures or to obtain a bonus,
- conflict of interest,
- bid rigging,
- cybercrime,
- disclosure of contact details of prospective PGNiG Group customers,
- misappropriation of the PGNiG Group’s assets
|
- Application in practice of regulations in force, such as:
- Code of Ethics,
- Rules of personal data protection,
- Rules of preventing fraud and anti-corruption guidance,
- Compliance Programme,
- Instruction on the protection of trade secrets,
- Instruction on contract awards and expenditures,
- Investment project execution procedure,
- Rules for calculation of contractual penalties,
- Contract and agreement templates
- eB2B procurement platform,
- Institutional control,
- Functional control.
|
low |
| 4 |
Offering or accepting a gift without reporting it in the register of benefits. |
Increasing employee awareness through appropriate communication of anti-corruption regulations, including the use of regular reminders in the form of emails of the need to comply with anti-corruption regulations. Obliging employees to:
- report any gifts accepted or offered,
- report any instances of corruption identified,
- submit declarations on the absence of any instances of corruption.
|
low |
| 5 |
Poor employee awareness (regardless of position) of the need to monitor and report any instances of corruption (including suspected corruption). |
- Preparation of newsletters to support internal communication,
- Provision of training to improve awareness and knowledge,
- Introduction and application of appropriate internal regulations.
|
low |
| 6 |
Data leak or loss. |
- Operation of the Information Security Management System (SMS) certified for compliance with the PN-EN ISO/IEC 27001:2017-06 standard. Compliance with the Principles of Information Security Policy (ISP) and the ICT Security Policy (ICT SP).
- Application of the Crisis Procedure and Business Secret Procedure.
|
medium |
| 7 |
Risk of labour rights violations. Any act or behaviour related to or directed against an employee, such as unequal treatment, discrimination, workplace harassment etc |
Compliance with the provisions of the Code of Ethics on the prevention of workplace harassment, definition of preventive measures and rules of handling harassment reports. All newly hired
employees must read and sign the Notice on legal provisions governing equal treatment in employment (Art. 941 of the Labour Code) and read the company’s Work Rules.
- Training and education on employee rights, especially among managers.
|
medium |
