Integrated ESG
Report 2021

Other non-financial risks

GRI Indexes

Social risks

  • 102-15
  • GOV-1/C3

The PGNiG Group is aware of the risks related to HR management and enhancing employee competencies. The Group is also aware of succession-related risks and risks relating to transferring knowledge in key areas in the case of old age retirements. Ensuring that the employees are guaranteed safe and healthy working conditions is vital, too. Methods of managing key non-financial risks related to employee matters are listed below.

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Employee aspects
No. Identified non-financial risk Method to prevent risk materialisation Risk leve * 
1 Risk of a crisis situation related to COVID-19 and risk of losing business continuity.
  • Appointment of a PGNiG Group Crisis Management Team to prevent and fight COVID-19; one of the Team’s objectives
    was to maintain business continuity of the Company and the Group in the context of ensuring Poland’s energy security and
    supporting efficient communication, employee safety and customer service during the pandemic.
  • Employees worked in split teams. Where presence on site was not absolutely necessary for the sake of business continuity, employees were requested to work remotely. Employees who
    had to work from the office were provided with the safest possible working environment, social distancing measures were applied between employees, personal protective equipment was available everywhere on site, and air purifiers were used.
  • Internal communication was enhanced through the use of online tools and face-to-face training was replaced with online courses.
 medium
2 Competence gaps in key areas, including:
  •  loss of key employees.,
  • difficulties in acquiring new employee from the marketu,
  • limited number of
    candidates with narrow specialisations,
  • old age retirement.
  • Continuous improvement of competencies through various forms of training (mainly online training in 2021).
  • Implementation of a key roles identification system and description of key competencies at PGNiG with a view to identifying them and providing informed development opportunities..
  • Monitoring the HR situation of the heads of organisational units to ensure continuity of competence and knowledge.
  • Planning employee recruitment, using incentives to encourage employees to announce planned retirement in
    advance.
  • Provisions of Collective Bargaining Agreements governing the retirement programme, knowledge-sharing incentives
    etc.

 

 medium
3 Limitations related to human capital, including:
  • inability to hire employees with
    appropriate competencies.
  • limited availability of employees with
    specialist competencies on the market
  • rapid development of the industry and
    the labour market, resulting in increased
    demand for employees with similar
    knowledge.
  • Offering of attractive non-pay (fringe) benefits, implementation of modern remuneration and bonus systems.
  • Development of success plans – talent search, successor identification, and preparation of development and retention
    programmes for this group of employees.
  • Application of the Retention Policy to persons of key importance to PGNiG.
  • List of key roles, a competency model prepared to track and develop universal, management and technical competencies,
  • Provision of replacements for key roles.
  • Identification of challenges, referral programme.
  • This risk is mitigated through:
    • the Company’s recognition on the local market
    • a broad range of non-pay (fringe) benefits o the Company’s participation in job fairs,
    • recruiting candidates using alternative channels,
    • including: Career Office, OLX website, pracuj.pl,
    • the internally implemented employee recruitment procedure defining the rules and stages of recruitment process.
  • Monitoring pay rates offered on the market.
  • Offering staff incentives, also to improve their skills, and guidance developed on employee upskilling.
  • Policy on updating job descriptions and job evaluation.
 low
4 Risk of conflicts with trade unions.
  • Regular meetings with social partners. Providing periodic information on the condition and plans of a given company.
  • Accurate preparation of documents submitted for approval to trade unions, thus enabling efficient content review.
 low
5 Risk of different interpretations of labour,
tax and social security regulations (e.g.
court rulings, audit follow-up decisions, recommendations,
opinions/interpretations).
  •  Requesting competent authorities and institutions to issue opinions and interpretations.
  • Internal legal opinion obtained from the legal and compliance units.
  • Periodic training for employees and management staff on new labour law regulations, tax law and social security regulations.
  • Regular communication of changes via means of communication available to the Company (newsletter, email).
 low

 

* The risk level is the size of a risk expressed as a combination of its impact and the likelihood of risk occurrence
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OHS aspects
No. Identified non-financial risk Method to prevent risk materialisation Risk level *
1 Occupational risks for jobs determined on the basis of hazards identified for each job.
  • The Occupational Risk Assessment Team periodically reviews occupational risks using the Risk Score method (a quantitative approach).
  • The Hazard Identification and Occupational Risk Assessment Procedure, with the Risk Score Occupational Risk Assessment Manual and the Occupational Risk Scorecard Review and Archiving Manual as its integral part.
  • Executive order appointing the Occupational Risk Assessment Team.

 

 medium
2 Occupational accidents or diseases caused by poor work organisation, non-compliance with procedures or use of inadequate protection measures. Risk of temporary production stoppage due to a severe or fatal accident.
  • Operation of QHSE Management System.
  • Regular OHS training.
  • Awareness and Behaviour Improvement Programme.
  • Identification of near misses.
  • Ongoing supervision during the performance of high-risk work.
  • Choice of adequate safeguards against hazards.
  • Taking active and proactive measures to improve working conditions.
 medium
3 Inadequate working conditions – OHS rules are not provided at the workplace,
which increases the risk of occupational accidents, constituting violation by the employer of employee rights.
  • Regular OHS training for employees.
  • Implementing and updating procedures and regulations to ensure that adequate working conditions are maintained – implementing the QHSE system.
  • Internal audits (including cross-audits), inspections and checks.
  • Ongoing supervision during the performance of high-risk work.
  • Identification of near misses.
  • Awareness-building through training, campaigns, drills, HSE meetings.
  • Dialogue with employees.
  • Investing in human resources and equipment.
  • Continuous improvement of the Integrated Management System.
  • Developing OHS staff competencies – training courses, industry meetings, also at the PGNiG Group.
  • Activity of the OHS Committee.
  • Up-to-date inspections and oversights.
 low
4 Acts of employees and subcontractors resulting in violations of OHS laws. Reviewing and consulting contracts with subcontractors in terms of security certificates and safety clauses. low
5 Employees unable to respond to emergencies.
  • Developing an OHS hazard reporting system including allocation of responsibilities and supervision of the hazard identification process in occupational risk assessment.
  • Fire alarm drills.
  • Additional rescue training for staff.
 low

 

* The risk level is the size of a risk expressed as a combination of its impact and the likelihood of risk occurrence

The Group also identified the following significant risks and risk mitigation measures relating to other social aspects.

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Social aspects
No. Identified non-financial risk Method to prevent risk materialisation Risk level *
1 Image risk – negative reception of PGNiG’s and the entire Group’s business, communication or marketing activities by stakeholders, including local communities
– bad publicity in traditional and social media.
  • Internal rules governing contacts with the media and use of social media by employees.
  • Building lasting media relations.
  • Ongoing monitoring and contact with key journalists.
  • Quick analysis and response to negative publicity.
  • Ongoing social media monitoring.
  • Internal regulations on crisis communication.
  • Good practices with respect to field business operations, including dialogue with stakeholders concerning new projects.
 medium
2 Risk of exploration work causing inconvenience to local communities
  • Use of new technology solutions. Development projects.
  • Fair analysis of the location of planned work, cooperation between organisational units responsible for the design of exploration work (land surveyors, geologists, drillers) and identification of its environmental impact (environmental protection
    units), cooperation with local authorities.
  • Education and information initiatives intended to provide project updates.

 

 medium
3 Risk of conflicts with local communities causing obstacles to upstream activities.
  • Fostering cooperation through sponsorship, image building and CSR projects and events.
  • Cooperation with local authorities.
  • Education and information initiatives intended to provide project updates.
  • Interviews with local communities, open/one-on-one meetings, negotiations and mediation.
 medium
4 Negative reception of the Company’s CSR activities by the social environment of the PGNiG Group – negative assessment of PGNiG’s actions (expectations not met satisfactorily, needs not responded to). This hampers field operations and brings
up the costs of communication with local communities and stakeholders.
  •  Operations of the Sponsorship Committee.
  • Activities coordinated with the Foundation.
  • Channels in social media allowing quick and interesting communication.
 low

 

*The risk level is the size of a risk expressed as a combination of its impact and the likelihood of risk occurrence

Ethical risks and management approaches

  • 102-15

The PGNiG Group identifies potential non-financial risks related to ethics and analyses risks which may materialise in the future. The table below shows how the organisation manages the risks, preventing them from materialising.

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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 Anti-Corruption 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 breliable and trustworthy organisation may have far reaching negative legal consequences.
  • Legal regulations adopted by the Group, i.e. the PGNiG Group AntiCorruption 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

 

* The risk level is the size of a risk expressed as a combination of its impact and the likelihood of risk occurrence
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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 Anti-Corruption 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 breliable and trustworthy organisation may have far reaching negative legal consequences.
  • Legal regulations adopted by the Group, i.e. the PGNiG Group AntiCorruption 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

 

* The risk level is the size of a risk expressed as a combination of its impact and the likelihood of risk occurrence
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