GRI 102-11, 102-16, 102-17, 103-2, 205-1, 205-2, 205-3, 406-1

The PGNiG Group conducts its business activities with due regard to human rights and in compliance with ethical standards and applicable laws. 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 has adopted the rules of conduct based on the principles set forth in the Charter of the United Nations relating to human rights, labour standards, environmental protection, anti-corruption and compliance with law. The principles are universally accepted and derive from:

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

It should be noted that ethical issues are broadly defined at the PGNiG Group. Such issues are governed by the following key documents:

  • Ethics and compliance management system at the PGNiG Group;
  • 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 for 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. With the goal in mind, the PGNiG Group Code of Ethics has been adopted to provide clear guidance on the rules of conduct. The Code set forth the rules of adherence to ethical standards in everyday work and requires 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. The anti-mobbing procedure requires employees to refrain from mobbing and discrimination at the workplace, and specifies what steps need to be taken if a misconduct has been reported. The Organisation’s objective is to create an environment where human rights violations are non-existent. The Legal, Compliance and HR Departments are responsible for implementing and monitoring observance of human rights. 

A key issue influencing the PGNiG Group’s image and perception is compliance with anti-corruption policies and procedures. The regulations and standards of conduct in place at the Group prohibit any action that involves corruption or bribery. The PGNiG Group 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 achieving this objective and implementing the policy at the Organisation rests with the PGNIG Corporate and Legal Support Department’s Compliance function.

Due diligence policies and procedures

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.

The PGNiG Group operates in compliance with applicable anti-corruption laws. It should be noted that in this respect the Group 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 adopted under 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. Furthermore, the Policy also 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. At the same time, 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.
Selected ethics indicators
As a responsible business partner, 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 across the Group are uniform in terms of their nature and scope. 
Risk of corruption (GRI 205-1)

PGNiG Group 2019
Total number of business units assessed for corruption risks
Percentage of business units assessed for corruption risks

Anti-corruption training (GRI 205-2)

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 2019, 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. 

PGNiG 2019
Number of Management Board members (all Poland-based)
Percentage of Management Board members
Total number and percentage of members of governing bodies to whom  the adopted anti-corruption policies and procedures have been communicated:

At the PGNiG Group, all members of the Management Boards of Group companies were informed about anti-corruption policies and procedures, and in 2019 33% of them participated in anti-corruption and anti-bribery training organised for members of governing bodies.

Total number employees to whom the adopted anti-corruption policies and procedures have been communicated
Number of employees informed
Percentage of employees informed
all (newsletter)
all (newsletter)
PGNiG Group
at most Group companies all managers were informed via internal communication channels
at most Group companies all employees were informed via internal communication channels

In 2020, the PGNiG Group plans to hold an e-learning training cycle on ethics and counteracting corruption. In addition, the planned training will cover material topics related to mobbing as well as the procedures applying to whistleblowers. The Group will also hold separate training for management staff in this area.

Total number of business partners to whom the adopted anti-corruption policies and procedures have been communicated:

  • PGNiG Group companies inform their business partners of the anti-corruption rules applicable at the PGNiG Group, and the anti-corruption policy is available at the Group's corporate websites. 
Corruption-related reporting (GRI 205-3)

Number of confirmed corruption incidents
PGNiG Group

Total number of incidents of discrimination (GRI 406-1)
No incidents of discrimination were identified at PGNiG. 
One discrimination case was reported at the PGNiG Group (at GSP). In accordance with the Code of Ethics in force at the Company, the case was analysed in detail after having interviewed the persons involved, and was examined as soon as possible by the authorised Ethics Coordinator. Based on the Coordinator’s recommendation and after hearing the person indicated in the report, the Employer took disciplinary steps against the employee accused of discriminatory practices. Educational activities for management staff were carried out to further increase the awareness of ethics and anti-harassment issues at the workplace. In another step, the Employer planned staff training as well as a review of internal policies and their further elaboration in the areas under analysis. The aim of the planned measures is to increase sensitivity and knowledge regarding these matters.
System supporting management processes (GRI 103-2)
The PGNiG Group’s key business areas are managed through the implemented and applied QHSE Policy, which defines objectives and directions of operations and ensures maintaining the highest standards of quality, OHS and environmental protection in order to meet the requirements and expectations of our stakeholders. The QHSE Management System complies with the following standards: ISO 9001:2015, ISO 14001:2015, OHSAS 18001:2007 and good HSE practices applying to exploration for and production and tankless storage of hydrocarbons, as well as to the processing and transmission of gas. 
The QHSE system is the main pillar which serves as a basis for making management decisions concerning operations. Thus, it is possible to rationally manage the key aspects affecting the economic and financial performance and pursuit of business objectives. The integration within a single system of areas which are critical to the proper operation of the PGNiG Group makes it possible to counteract developments with an adverse effect on processes.
The person responsible for the System’s effective operation is the Management Board’s Representative for the QHSE Management System, supported by Representatives of respective Directors at PGNIG S.A. Branches. The Management Board’s Representative is authorised to represent PGNIG S.A. in contacts with external stakeholders with regard to the QHSE Management System. The policy is reviewed periodically to evaluate its usefulness and relevance.
Organisational unit
System (IMS, EMS, QCS, OHSMS, EMAS etc.)
Certified (Yes/No)
Certifying entity
Certification date
Recertification date
QMS – ISO: 9001:2015
EMS – ISO:14001:2015

OHSMS − BS OHSAS:18001:2007
Jul 20 2018
Jul 19 2021

Mar 11 2021
PGNiG Central Measurement and Testing Laboratory
MS compliant with PN-EN ISO/ IEC 17025:2005+Ap 1:2007, PN-EN ISO/IEC 17065:2013
Exalo Drilling
QMS – ISO: 9001:2015
EMS – ISO:14001:2015
OHSMS − BS OHSAS:18001:2007
Jun 20 2018

Mar 13 2017
Jan 26 2020
Mar 18 2011

Mar 18 2017
Mar 17 2020
PGNiG Technologie
Oct 22 2007
Dec 5 2007
Sep 23 2016
Sep 23 2016
IMS – ISO: 14001:2015
Feb 1 2017
Jan 1 2020
QMS – ISO: 9001:2015
EMS – ISO:14001:2015
OHSMS − BS OHSAS:18001:2007
Sep 3 2018
Sep 2 2021







Through its QHSE Policy, the PGNiG Group undertakes to:

  • identify, supervise and ensure the effectiveness of processes;
  • build lasting relationships with the PGNiG Group Customers;
  • identify and ensure compliance with applicable laws and other requirements;
  • implement norms and standards that follow from good practices, to promote safe solutions;
  • identify various risks, including near misses, in order to prevent accidents at work, occupational diseases, incidents and failures;
  • identify and mitigate environmental impacts;
  • perform work in a safe, planned, organised and supervised manner;
  • effectively strive to improve occupational health and safety in a sustainable manner;
  • build a competent, informed and committed workforce.