ETHICS

Conducting business in compliance with applicable laws is among PGNiG’s top priorities. To that end, in order to establish transparent procedures, the Company introduces internal regulations which provide clear guidance for PGNiG Group companies as well as its employees and business partners. 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.

Compliance with human rights at the PGNiG Group is underpinned by the Code of Ethics, 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:

• reliability,
• responsibility,
• partnership.

These core values underpin the PGNiG Group’s actions and are evident in relations with the local communities, which are considered as a manifestation of a sense of responsibility for the Group’s operations and the overriding mission delivered for the benefit of 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 Code sets out the following declared values:

• 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 us to work for the common good and take care of the natural environment.
• credibility – building high-quality and dialogue-based culture of communication, inspiring the atmosphere of trust among all our stakeholders, 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 our 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.

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 Transparency Policy for Managers:

• 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.

The principle of respect for employee diversity and employee rights is also manifested through the implementation of the PGNiG Group anti-mobbing and anti-discrimination policy.  The Group takes measures conducive to building positive relations among employees and creating a workplace where every employee feels duly respected. The Group opposes any form of discrimination, mobbing, persecution or harassment, including any harassment of sexual nature. 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, with due consideration given to the respective obligations, 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.