The Bank operates in a responsible, transparent and sustainable manner, taking into account ESG criteria. In its ESG Strategy, the Bank pledged to strive to maintain the highest standards of corporate governance and develop an ethical approach to business.
Management
Business Ethics
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Best Practices for WSE Listed Companies
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In 2021, the Management Board of Bank Pekao S.A. adopted a resolution, also effective in 2023, for the Bank to adopt the Best Practices for WSE Listed Companies 2021 issued by the Stock Exchange. The Best Practices replaced the Best Practices of WSE Listed Companies 2016, which the Bank applied until June 30, 2021. The Best Practices are a set of corporate governance principles to which issuers of shares listed on the WSE’s Main Market have been subject since 2021, based on the provisions of the Regulations of the Warsaw Stock Exchange. The Best Practices take into account the current state of the law and the latest trends in the area of corporate governance, as well as the demands of market participants interested in increasingly better corporate governance in listed companies. The Best Practices also include requirements related to the ESG area, including issues of sustainability, diversity in the composition of company bodies and equal pay.
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Code of Conduct of the Pekao Group
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The current Code of Conduct of the Pekao Group adopted by a Resolution of the Management Board of the Bank of December 3, 2021 and by a Resolution of the Supervisory Board of the Bank of December 13, 2021 contains the most important principles to be followed by all employees of the Pekao Group, regardless of their position or basis of employment. The Code of Conduct contains statements of values, the Bank’s mission and vision for the business covering key principles and standards of conduct, shaping employees’ ethical choices and behavior. In the Code of Conduct, the Pekao Group expresses its support for sustainable economic and social development and environmental protection and climate change efforts. The Code of Conduct refers to the adopted ESG Strategy, which summarizes the Bank’s environmental, social and corporate governance approach and priorities, declaring the Bank’s development with high standards of corporate governance and an ethical approach to business.
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Preventing Corruption
Bank Pekao decisively combats all forms of corruption and situations that may contribute to corruption. The Bank does not tolerate any actions that may constitute corruption by the Bank’s employees or other persons or units having any relationships with the Bank. Employees who refuse to take part in corruptive practices or employees who disclose such practices or attempts at such practices by other persons/entities are fully protected. Moreover, the Bank does not tolerate offering, promising, demanding, giving or accepting any payments (facilitation payments) aimed at accelerating any issues by the Bank employees or other persons or entities having relationships with the Bank.
Corruption Prevention Policy of the Bank Pekao S.A. Group covers all aspects of the Bank’s operations. In accordance with its guidelines, the Bank has adopted a Corruption Prevention Program.
It consists of the following elements:
Corruption Prevention Policy of the Bank Pekao S.A. Group covers all aspects of the Bank’s operations. In accordance with its guidelines, the Bank has adopted a Corruption Prevention Program.
It consists of the following elements:
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Corruption Prevention Officer
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In the Bank Pekao’s Compliance Department, the functions of the Corruption Prevention Officer are carried out, to whom information about attempted corruption or activities that have the appearance of corruption should be reported. The Corruption Prevention Officer has the right to examine suspected or actual actions regarded as corruption and request a person that is suspected of corruption to submit documents, as well as to review such documents and report such circumstances in accordance with the applicable procedures. Detailed duties of the Corruption Prevention Officer, including the development, implementation and supervision of the effective Corruption Prevention Program, as well as the enforcement of the Bank’s internal regulations on corruption prevention, are set out in the Corruption Prevention Policy.
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Whistleblowing Procedure
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On December 26, 2023 the Whistleblowing Procedure at Bank Pekao S.A. came into force, which replaced the existing Whistleblowing Policy of Bank Pekao S.A. The Whistleblowing Procedure is an expression of the Bank’s commitment to promoting a corporate culture that supports ethical behavior. Its purpose is to create secure channels for signaling any unlawful acts or omissions or those intended to circumvent the law, violating the Bank’s internal regulations or ethical standards, covering both existing and potential violations that have occurred or are likely to occur at the Bank, including attempts to conceal such violations.
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Conflict of Interest Management
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The Bank applied the methodology for managing conflicts of interest that makes it possible to identify and assess compliance risk connected with a specific conflict, choose appropriate measures to prevent or minimize negative consequences, eliminate conflicts of interest and monitor them. The Bank defines circumstances in which conflicts of interest are most frequently identified, taking into consideration both areas potentially at risk of a conflict of interest and types of relations concerning the Bank, employees, entities from the Pekao Group and third parties, especially customers and trading partners of the Bank. The identified types of conflicts of interest and the measures to manage them that should be applied by Employees identifying conflicts of interest are included in the Conflicts of Interest Matrix.
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