The PGNiG Group conducts its business activities with due regard to human rights and in compliance with ethical standards and applicable laws.

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The primary document governing the area under analysis is the Code of Ethics (the PGNiG Group Ethical Standards Code), which has been adopted across the PGNIG Group. The organisation acts in a transparent manner, in accordance with applicable laws, free from any forms of bribery or corruption. Taking care to protect its image and reputation, the PGNiG Group pursues its objectives in this area through internal regulations. The organisation adopts rules of conduct that refer to human rights, labour standards, environmental protection, anti-corruption and legal compliance, set forth in such acts as the Charter of the United Nations. These rules are globally recognised, stemming from:

  • Universal Declaration of Human Rights;
  • International Labour Organization’s Declaration on Fundamental Principles and Rights at Work;
  • Rio Declaration on Environment and Development;
  • United Nations Convention against Corruption

It should be noted that ethics aspects are extensively defined at the PGNiG Group. They are governed by the following key documents:

  • PGNiG Group ethics and compliance management system,
  • PGNiG Group’s Code of Ethics;
  • Transparency Policy for Managers;
  • Anti-mobbing and anti-discrimination procedure;
  • PGNiG Group’s Anti-Corruption and Gift Policy.

The organisation has in place the PGNiG Group ethics and compliance management system, based on fundamental principles of ethics. The system provides a uniform framework and standards of employee conduct that is acceptable and expected across the Group. The Group’s priority is to maintain a situation where no human rights violations occur. In order to define clear rules of conduct, a Code of Ethics has been adopted, laying down the rules of adherence to ethical standards in everyday work and requiring the Group employees to respect human rights. The ethical standards defined in the Code are reflected in the documents supporting their implementation. The documents include the Transparency Policy for Managers, which is geared towards enhancing the corporate culture to ensure transparency at the PGNiG Group companies, and the anti-mobbing procedure, requiring employees to refrain from mobbing and discrimination at the workplace and specifying what steps need to be taken if a misconduct has been reported. The purpose of the organisation is to ensure that there are no instances of human rights abuse. The PGNiG Legal, Compliance and HR Departments are responsible for implementing and monitoring observance of human rights.

The PGNiG Group strives to build an organisation that is free from discrimination and violations of human rights. Therefore, it takes care to ensure that people can speak up on professional matters with due regard for their dignity and diversity of opinions. At the same time, it upholds the principle of equal employment opportunities by preventing any favouritism or abuse. It is worth noting that line managers will take commensurate disciplinary measures against anyone who fails to respect the principles of fair and polite interpersonal relations.

Compliance with anti-corruption rules is crucial to maintaining the image and perception of the PGNiG Group as an ethical partner in business and an ethical employer. The regulations and standards of conduct in place at the Group prohibit any action that involves corruption or bribery. PGNiG does not tolerate accepting, giving, promising or soliciting by its employees and associates of any undue financial or personal gains. Additionally, employees are obliged to avoid any situations which may lead to conflicts of interest with business partners and entities engaged by the Company. In order to maintain partnership-based relations with stakeholders, employees are required to enter in the register of benefits all gifts received or presented whose value exceeds PLN 50. The absence of any instances of corruption is the PGNiG Group’s continuing objective in this respect. Responsibility for delivering this objective and implementing the policy at the organisation rests with the PGNiG Corporate and Legal Support Department’s Compliance function.

Partnerships and good business relations with its suppliers are an important point of PGNiG’s business. The Company demonstrates its values and communicates its approach to partners by providing them with relevant documents. All trading partners can accessPGNiG’s anti-corruption policy at In addition, the PGNiG Group acts responsibly in its relations with operators selected through tendering procedures. Procurement procedures are prepared and carried out in accordance with the principles of proportionality, transparency, purposefulness, costeffectiveness, reliability, fair competition and equal treatment of contractors, with due regard to the Group’s interests. In addition, activities related to the preparation and execution of procurement procedures are performed by individuals who can guarantee their impartiality and objectivity. Contractors are selected based on internal procurement policies and manuals.

To raise the awareness of anti-corruption issues at PGNiG, a compliance training programme focusing on anti-corruption and ethics was introduced for all employees. The training is provided in the e-learning format. All new hires are required to complete the training and pass the final test. Moreover, every six months compliance with anti-corruption rules is reviewed across the PGNiG Group by means of declarations submitted by employees to the effect that no instances of corruption took place or, alternatively, providing descriptions of any such instances identified. In addition, basic rules concerning the submission of periodic anti-corruption declarations, as well as offering and accepting gifts, are clarified and refreshed by means of newsletters. Desirable attitudes and other provisions of the Code of Ethics are continually promoted and fostered by means of internal communication channels.

Conducting business in compliance with applicable laws is among PGNiG’s top priorities. Therefore, there are transparent internal regulations in place at the Company, which provide guidance for the conduct of PGNiG Group companies and their employees and associates. The Group’s priorities are delivered through adherence to the Ethics and Compliance Management System in place at the PGNiG Group, which addresses and regulates key issues in the area, applying in particular to:

  • remits of the respective bodies responsible for managing ethics and compliance at the PGNiG Group;
  • the manner of coordination and exchange of information on any breaches of applicable laws, customary market norms, industry standards, good market practice, or standards of ethical conduct at the PGNiG Group;
  • responsibilities of the PGNiG Group companies in the management of ethics and compliance risks

Observance of human rights at the PGNiG Group is underpinned by the Code of Ethics (the PGNiG Group Ethical Standards Code), which has been implemented in order to harmonise and consolidate the ethical standards applied across the PGNiG Group. The core values, which are among the key rules of conduct set forth in the Code, are as follows:

  • responsibility – the foundation for all employees in their day-to-day work, regardless of the position held, and at the same time a challenge which motivates them to work for the common good and take care of the natural environment,
  • credibility – building a high-quality and dialogue-based culture of communication, inspiring the atmosphere of trust among all stakeholders of the Group, in a lasting and consistent manner,
  • partnership – building lasting and mutually beneficial relations based on trust, both within the PGNiG Group with its employees and trade unions, as well as outside the Group with its customers, local communities and other market participants,
  •  quality – ensuring top quality of the Group’s products and services, driven by the principle of continuous improvement through implementation of state-of-the-art technologies, streamlining of management processes, and building an ethical workplace across the PGNiG Group, as desired by our customers, employees and all business partners.

These values at the PGNiG Group serve as a compass in its activities and relations with local communities. They are treated as an overriding mission pursued for the benefit of the Polish society. The fundamental golden rules, which can be expressed with clear and simple messages such as ‘do good, avoid evil’ or ‘treat others the way you want to be treated’, are the foundation for building other important standards of conduct.

The provisions of the Code of Ethics are supported by the Transparency Policy for Managers, which introduces a higher standard of organisational culture, in particular in terms of preventing conflicts of interest among members of governing bodies and top management in Group companies, thereby protecting the legitimate interest of the PGNiG Group. The document:

  • defines a conflict of interest and methods of preventing situations which could lead to potential or actual conflicts of interest;
  • sets forth the disclosure requirements towards the company and the rules of conduct towards family members and other close persons;
  • determines sanctions for breaches of the Policy;
  • protect PGNiG’s interests in a proper manner.

Respect for employee diversity and employee rights is also an element of the PGNiG Group’s anti-mobbing and anti-discrimination policy. The Group takes measures conducive to building positive relations between the employees and the workplace, making every employee feel duly respected. The Group opposes any form of discrimination, mobbing, persecution or harassment, including any harassment of sexual nature. Provisions of the Policy are incorporated in the Work Rules of individual companies and in the PGNiG Group’s Ethics and Compliance Management System. The implemented provisions of the Policy:

  • define any unwanted behaviours which may take place both at the workplace and during business trips, employee travel and in any other locations where employees perform their work-related duties;
  • specify the measures to be taken to prevent mobbing, discrimination and sexual harassment, and describe the consequences of breaching the applicable regulations or creating conditions conducive to such breaches;
  • provide information on the actions taken to promote desired attitudes, to disseminate knowledge on mobbing, discrimination and harassment, and to monitor the practical application of anti-mobbing procedures;
  • indicate employee duties which are meant to ensure compliance with adopted standards, to avoid unwanted behaviour, and to react and intervene in situations where observed behaviour violates accepted social standards;
  • specify the procedures for reporting any suspected mobbing, discrimination or harassment, as well as the rules of proceedings conducted by the Commission.

The PGNiG Group operates in compliance with applicable anti-corruption laws. In this respect, the organisation is also guided by supranational regulations, such as the OECD Convention on Combating Bribery of Foreign Public Officials In International Business Transactions of 1999 and the US Foreign Corrupt Practices Act (FCPA). Every employee, irrespective of the position held, is required to comply with the applicable local, national and international laws, taking due account of the anti-corruption regulations adopted by the PGNiG Group in its Anti-Corruption and Gift Policy and Code of Ethics.

The regulations set out in the PGNiG Group’s Anti-Corruption and Gift Policy:

  • define the obligations of PGNiG S.A. and other Group companies, as well as of their respective employees and contractors, with regard to preventing corrupt practices, and provide the employees and contractors with information and guidelines on how to identify corrupt practices and what to do in the event that such practices are identified;
  • provide guidance on accepting and offering gifts, presents or invitations to entertainment events, as a supplement to the relevant provisions of the Code of Ethics; the Policy provides specific guidance regarding participation in entertainment events and on accepting and offering gifts in the course of procurement proceedings;
  • define corruptive practices and specify prohibited action which can entail the risk of criminal liability; furthermore, pursuant to the Criminal Code, the Policy sets forth the minimum and maximum sanctions imposed on employees for accepting, soliciting, providing or promising anything of value (including any financial and personal gain);
  • set forth the rules applying to procurement procedures, which should allow to track the sources of information concerning the subject matter of the procurement contract, identify the persons responsible for defining the terms and conditions for participation in the procurement procedure, including the evaluation criteria and form of contract, and to define the duties of members of the contract award committee and their personal responsibility; the Policy presents recommendations on how to communicate with bidders in keeping with the principle of equal access to information for all parties;
  • provide a number of recommendations on how to monitor compliance with the Policy and take preventive measures to mitigate the risk of occurrence of corruptive practices or conflicts of interest.

One of the overriding principles of the PGNiG Group is to act in a fair and ethical manner. PGNiG and the PGNiG Group entities are respected for their fairness, both in their management practices and in dealings with trading partners and customers, and it is essential that this reputation be maintained. It is therefore critical that the PGNiG Group as a whole as well as each person employed by and each entity cooperating with the Group are committed to preventing and fighting any form of corruption.

The PGNiG Group’s Code of Ethics refers to the UN Convention Against Corruption as a basis for actions, recognised by the Group. The PGNiG Group’s policy provides for an unconditional obligation to comply with the applicable anti-corruption regulations in its operations, taking into account the applicable international regulations and anti-corruption regulations enacted in other countries where the PGNiG Group operates.

As a responsible business partner, the PGNiG Group evaluated all its business units in terms of the potential occurrence of corruptive practices. The identified risk was considered to be very low, as no such corruptive practices have been observed over the past five years. This conclusion was also underpinned by the internal regulations in place at the Group, which clearly define the rules of business conduct, effectively preventing any corruptive practices, as well as the system of employee training which raises awareness among employees in this area and keeps their knowledge thereof up to date. The assessment revealed that all Group business units are subject to the risk of corruption to the same extent. Therefore, the preventive measures applied by the Group are uniform in terms of their nature and scope with respect to each unit.

Assessment of organisational units for corruption risks

Organisational unit Percentage of organisational units assessed for corruption risks as at
2021 r. 2020 r.
PGNiG 95% 95%
PGNiG Group 91% 91%
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Anti-corruption training

Training is an essential element of PGNiG Group’s anti-corruption framework. In the previous reporting period, the PGNiG Group held training aimed at disseminating knowledge of and good practices in building a corruption-free organisational culture. In 2021, measures were taken to inform all employees of the adopted anti-corruption policy and procedures. The Group also organised a more in-depth training on the subject for a selected group of employees.

Percentage of members of governing bodies to whom the adopted anti-corruption policies and procedures were communicated and who received anti-corruption training in 2021 at the PGNiG Group

Organisational unit Percentage of members of governing bodies to whom the adopted anti-corruption policies and procedures have been communicated: Percentage of members of governing bodies who have received anti-corruption and anti-bribery training:
PGNiG 100% 100%
PGNiG Group 100% 70%

Percentage of employees to whom the adopted anti-corruption policies and procedures were communicated and who received anti-corruption training in 2021 at the PGNiG Group, by employee category:

Organisational unit Percentage of employees to whom the adopted anti-corruption policies and procedures have been communicated Percentage of employees who have received anti-corruption and anti-bribery training in 2021:
senior executive 100% 20%
middle management 100% 8%
other employees 100% 30%
PGNiG Group
senior executive 100% 63%
middle management 100% 32%
other employees 100% 27%

In 2021, the PGNiG Group held a mandatory e-learning training programme on ethics and anti-corruption. The training covered important topics related to workplace mobbing as well as procedures applying to whistleblowers. The Group will also hold separate training for management staff in this area.

PGNiG Group companies inform their business partners of the anti-corruption rules applicable at the PGNiG Group, The anticorruption policy is available on the Group’s corporate websites at: .

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Corruption-related reporting

The PGNiG Group condemns using any form of corruption in its business. All PGNiG Group companies seek to completely eliminate any instances of corruption that may occur at the Group.

Number of confirmed corruption incidents in 2021

Organisational unit Number of confirmed corruption incidents
PGNiG Group 0
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Total number of incidents of discrimination

Organisational unit Number of confirmed discrimination incidents in 2021
PGNiG Group 0

No incidents of discrimination were identified at PGNiG or the PGNiG Group.

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