Compliance in the TAURON Group

Surely, in all your actions in all areas of life, you are committed to compliance - for example, with your principles, beliefs or your own value system.




What is compliance?

    It is aimed at adjusting the organisation’s activity to legal requirements, internal regulations as well as standards and guidelines applicable in business. These actions are intended to prevent financial and reputational losses.

The importance of the compliance function has increased as a result of the financial crisis. It revealed weaknesses in the functioning and transparency of financial markets. Therefore, there was a need to implement effective and efficient compliance systems in organisations.

Compliance Management System

In order to meet market standards, the TAURON Group has introduced and is developing the Compliance Management System to ensure that the organisation operates ethically, in accordance with the law and accepted regulations.

The Compliance Management System has been created taking into account the needs and specific character of the whole organisation, and covers the activities of all organisational units of the TAURON Group Companies.

Compliance management takes place in three areas: compliance with the law, compliance with internal and corporate regulations, and compliance with ethical standards.

Compliance Management System

What is the purpose of implementing the Compliance Management System in the TAURON Group?

The compliance system is designed to ensure balance in the organisation and:

    support employees in the proper performance of their daily tasks, prevent financial losses of the Company, loss of reputation, eliminate potential legal risks,
    eliminate potential legal risks.

Compliance in the TAURON Group is ensured through:

    preventive measures - to prevent non-compliance, detection activities - aimed at detecting, investigating and eliminating cases of non-compliance, analytical activities - consisting in the verification and analysis of identified cases of non-compliance.

Responsible Business Code

The culture of compliance at the TAURON Group covers all issues related to compliance, including the implementation of an ethical code in the organisation.

Why was the Code adopted?

The basis for the adoption of the Code was the belief that responsible and transparent business conduct, based on respect for the law and taking into account the needs of stakeholders, is a condition for sustainable development.

PRO values

The Code, referring to the Group’s corporate values - Partnership, Development, Boldness (Partnerstwo, Rozwój, Odwaga), sets out in a comprehensive manner the most important principles of conduct in the following areas:

What is the main purpose of adopting the Code?

In pursuing their business objectives, employees and business partners of the TAURON Group are obliged to take actions in accordance not only with the letter of the law, but also with good practices, values and principles contained in the Responsible Business Code.

The Code also provides guidance to facilitate verification of whether a given conduct complies with the law, internal regulations as well as the principles and values of the TAURON Group. The document also describes the TAURON Group’s whistleblowing system.

Every employee of the TAURON Group - regardless of the type of employment, seniority, position or function held - is obliged to act in accordance with the provisions of the TAURON Group’s Responsible Business Code.

Compliance Officer

The beginnings of compliance in the TAURON Group go back to 2014. At that time, the first Compliance Officer was appointed at TAURON Polska Energia S.A.

Currently, at TAURON Polska Energia, Aleksander Awdziejczyk is the Compliance Officer.

In developing the TAURON Group’s Compliance Management System, the Compliance Officer is supported by the Compliance Team at TAURON Polska Energia and by the Compliance Coordinators appointed in the TAURON Group Companies.

The structuring of the compliance system at TAURON Polska Energia through the separation within the company of the Compliance Officer reporting directly to the President of the Management Board with the ensured possibility of reporting to the Supervisory Board and the Audit Committee is in accordance with:

    Good practices of companies listed on the Stock Exchange 2016,The standards recommended for the compliance management system in the area of anti-corruption and the whistleblower protection system in companies listed on the markets organised by the Stock Exchange.
The tasks of the Compliance Officer include all activities aimed at ensuring the broadly defined compliance of the TAURON Group’s operations.

The tasks of the Compliance Officer and the Compliance Coordinators include:

   Promoting the culture of compliance in the organisation,

   Advice and ongoing assistance on compliance,

   Providing opinions and participation in the development of regulations created in the TAURON Group,

   Evaluation of external entities, including contractors,

   Examination of reported cases of non-compliance,

   Conducting information and education campaigns.


The Compliance Officer and the Compliance Coordinators carry out their tasks under the Compliance Plan. It defines the priorities and actions necessary to ensure the proper functioning of the Compliance Management System in the TAURON Group.

Training

Training

One of the priority tasks of the Compliance Officer and the Compliance Team at TAURON Polska Energia S.A. is to provide training courses for new and existing employees of the TAURON Group. They are aimed at building the culture of compliance in the organisation.

During the training, the employees are familiarised with the issues related, among others, to:

the functioning of the Compliance Management System in the TAURON Group, the standards resulting from the TAURON Group’s Responsible Business Code, the Rules for Receiving and Giving Gifts in the TAURON Group, the rules of conduct set out in the Anti-Corruption Policy of the TAURON Group.

The training is in the form of:

direct meetings with employees, e-learning courses.

Contractor verification

The TAURON Group, with the aim of:

protecting against the risk of establishing cooperation with entities acting contrary to law, good practices and commercial practices, and in particular, reducing the risk of participation in tax fraud and money laundering, has introduced a contractor verification procedure.

Contractor credibility is assessed on the following information:

legal and financial characteristics, previous business activities, terms of the agreement, capital and personal relations.

The mechanism of contractor verification increases the probability of the TAURON Group exercising due diligence, mitigating the risk related to cooperation with unreliable contractors to a great extent.

Rules for receiving and giving gifts

In the TAURON Group, the Rules for Receiving and Giving Gifts apply.

The implementation and observance of the rules is intended to ensure that the situations in which receiving gifts could have an impact on business decisions made by the TAURON Group Companies are eliminated.

The general principle obliges all employees to refrain from receiving gifts from customers or other employees which could result in influencing the recipient, or which could create an obligation to act in a specific way, or to refrain from performing the entrusted official duties, or which could influence current or future business decisions of the TAURON Group Companies.

A gift is any given or received benefit having a value for which the recipient does not pay, e.g:

money,
loans,
tickets,
leather goods and office supplies,
trips, invitations,
use of resorts,
gift vouchers.

An employee may only receive a gift if all the criteria are jointly fulfilled:

the gift is symbolic and customary in business relations,

is given openly,

its value is less or equal to PLN 200 gross,

is consistent with a legally permissible purpose, such as promotion, advertising,

does not impose any obligation of reciprocity or preferential treatment on the parties,

complies with applicable laws, internal and corporate regulations of the TAURON Group Companies,

does not violate the principles of decency and good manners,

its number or the frequency of receiving is not excessive,

has an impact on building positive business relations for the TAURON Group Companies.

Any doubts about the appropriateness of receiving the gift should be consulted with the immediate superior or with the Compliance Officer at TAURON Polska Energia by sending an e-mail to compliance@tauron.pl.

 

In the case of the TAURON Group Companies, the Compliance Coordinator appointed in the respective company should be contacted.

Anti-Corruption Policy of the TAURON Group

The TAURON Group has the Anti-Corruption Policy which aims to define uniform rules and standards of conduct which will make it possible to identify, prevent and mitigate the risk of corrupt behaviour as well as other abuses in the companies.

To whom does the Anti-Corruption Policy apply?

To all! Regardless of the position and type of employment, up to contractors cooperating with the TAURON Group Companies. There are no exceptions to this Policy! The rules of the game are the same for each of us.

The TAURON Group has conducted an anti-corruption campaign under the slogan We play fair! (Gramy fair play!)

What were the objectives of the campaign?

providing information on the policy of zero tolerance towards corruption and other abuses, promoting fair play rules (fairness and transparency in action), indicating dirty tricks (e.g. theft, misappropriation, counterfeiting), providing information on possible ways of reporting abuse.

What did the campaign include?

training for employees, posters, brochures, gadgets, anti-corruption film, e-learning.

Conflict of interest

Rules of Conflict of Interest Prevention in the TAURON Group

The TAURON Group operates in due observance of law, internal and corporate regulations and the highest ethical standards. In order to eliminate irregularities, the company has implemented Rules of Conflict of Interest Prevention.

A conflict of interest shall be understood as a situation actually occurring or likely to arise in which an employee’s personal interests (in particular, business, financial, family interests) may interfere with the impartial and objective performance of his/her official duties or the interests of the company or the TAURON Group.

The implementation of and compliance with the rules described in the regulation is intended to:

identify circumstances that constitute or may give rise to a conflict of interest, define rules for preventing, identifying and managing a conflict of interest, raising awareness among staff regarding identifying, avoiding and disclosing conflict of interest.

TAURON Group employees are obligated to report any potential or actual conflict of interest.

Rules of conduct for inspections in the companies of the TAURON Group

The TAURON Group is bound by the Rules of conduct in cases of inspections in the companies of the TAURON Group.


Implementation of and compliance with the rules described in the regulation help to streamline the course of action in the event of an inspection. It also ensures adequate protection of the TAURON Group’s interests.

The rules define the duties and the manner of conduct of TAURON Group employees during the inspection.

The Rules also make it necessary to:

  1. appoint Inspection Teams in Group companies,
  2. designate permanent premises in each of the Group’s companies to be used for inspection purposes.

These Rules are applicable to all Employees, members of management and supervisory bodies of TAURON Group Companies as well as proxies and authorised representatives.

TAURON Group Human Rights Respect Policy

Pursuant to the provisions of the Polish Code of Responsible Business, the TAURON Group is guided by the rule of equal treatment of employees and does not tolerate discrimination on any grounds, in particular with regard to age, gender, race, nationality, religion, sexual orientation, appearance, fitness or different opinions.

The TAURON Group also has a Human Rights Respect Policy, which aims to set out rules concerning respect for human rights and actions taken to prevent human rights violations as well as to support a working environment in which human rights are respected.

The introduction of the Human Rights Respect Policy in the TAURON Group contributes to raising awareness of human rights and promoting their protection.

The policy sets out rules dedicated to the respect and protection of human rights concerning, among other things:

prohibition of bullying and discrimination, prohibition of harassment and violence, prohibition of slavery and forced labour, prohibition of the employment of children and minors, freedom of association and employee involvement, compliance with conditions of employment and remuneration, occupational health and safety rules, rules on cooperation with stakeholders, in particular contractors and business partners, rules on local communities, reporting of violations, including those that appear to constitute human rights abuses.

In accordance with the provisions of the Human Rights Respect Policy, each employee, contractor and external entity/business partner is required to:

respect, promote and ensure the protection of human rights, refuse to participate in any event that may constitute a violation of human rights, bullying and discrimination or unfair treatment.

Every employee should be alert to the signs and circumstances that could potentially suggest a situation of unfair treatment. If such concerns arise, employees should raise them through specific communication channels.

New employees are also made familiar with the subject of respect for human rights and the possibilities for reporting violations in this respect.

In addition, in order to ensure compliance with ethical principles, the TAURON Group has an Ethics Committee established to investigate circumstances of potential violations of the principles. In accordance with TAURON’s regulations, anonymous reports submitted to the Ethics Committee are forwarded to the Compliance Officer at TAURON Polska Energia S.A. for investigation.

Compliance Awards 2019

The jury of the Compliance Awards 2019 competition awarded the TAURON Group in the category of the Compliance Idea of the Year for the Anti-Corruption Campaign of the TAURON Group. Compliance Awards 2019 is a nationwide competition organised by Instytut Compliance, in which awards are granted in three categories: the Compliance Officer of the Year, the Compliance Idea of the Year, the Compliance Advisor of the Year. A decision on granting the award is made by the members of the Competition Jury, who sit on the Programme Committee of the “Compliance” magazine. The TAURON Group’s anti-corruption campaign entitled Play with us for honest attitudes in our company - learn about the Anti-Corruption Policy of the Group (Graj razem z nami o uczciwe postawy w naszej firmie – poznaj Politykę antykorupcyjną Grupy) has been appreciated for its innovative and unconventional character.

Whistleblowing System

The TAURON Group has the Abuse Reporting System as defined in the TAURON Group’s Responsible Business Code and the TAURON Group’s Compliance Policy.

This system enables employees to report violations of the Code and illegal activities through established communication channels.

Every employee who:

becomes aware of illegal activities or those in violation of the Code, or who is in doubt about compliance with the law or the rules set out in the Code, should consult his/her superior or the Compliance Officer or the Compliance Coordinator or the Ethics Committee of the respective Company.

External entities, in particular contractors and other stakeholders of TAURON Group Companies, in the case of identifying irregularities in the TAURON Group’s operations, have the option to use the Fraud Notification Form.

The reporting channels in place at the TAURON Group are compliant with good practices in the area of whistleblowing and the requirements defined in the Polish Public Offering Act.

The TAURON Group shall ensure the protection of persons reporting corrupt activities or other abuses against any form of retaliation.

In cases of confirming the occurrence of corrupt activities or other abuses, companies take appropriate corrective actions to prevent similar events in the future.

Contact

In all matters concerning compliance the Compliance Team at TAURON Polska Energia S.A. can be contacted:

E- mail: compliance@tauron.pl