Standards of conduct in PZU - specific regulations

Management rules for conflicts of interest

PZU conducts its insurance activities and endeavours to protect the interests of its clients. In our day-to-day business choices and decisions, we are guided by management rules of conflict of interest, and we constantly monitor and update them. We are aware of the existence of various forms of potential conflicts of interest in our economic activities. Typically, these are situations where there is - or may be – an incongruity between:

  • the interest of the PZU company or a person related to it and the interest of the client,
  • the interests of two or more clients of PZU,
  • the interest of a person related to PZU and PZU itself.

We base our actions on mutual trust and transparent communication. We carefully analyse every case of conflict of interest, in line with PZU Compliance Culture, in conformity with our value "we are fair".

Rules for managing gifts

PZU has adopted specific regulations that address the management of gifts. To ensure that good practices and market standards are applied in this field area, the PZU Group has clear rules for the acceptance and giving of gifts by company employees. Accepting or giving a gift is only allowed for the purpose of building business relations or in connection with showing courtesy in relations with a client or business partner if:

  • best business practices require it,
  • the gift is given under the applicable rules, in an open and unsuspecting manner,
  • the rules of ethics and transparency are observed.

Anti-Corruption Programme

PZU, as a conscious participant in the financial market, has implemented an Anti-Corruption Programme.

The Anti-Corruption Programme serves to maintain transparency in the relations between PZU and its business partners and to reduce the risk of corruption. The Good Practices of the PZU Group, along with the Programme, define the basic ethical standards adopted at PZU. They are intended to contribute to building mutual trust and respect between PZU and its business partners.

Furthermore, the Company has adopted an Anti-Corruption Policy, the purpose of which is to define standards of conduct for persons related to PZU and for business partners that serve to build an effective anti-corruption system within the organisation.

PN-ISO 37001:2017-05 certification

PZU SA and PZU Życie SA have obtained certification of the Anti-Corruption Management System under the ISO 37001, awarded by the Polish Centre for Testing and Certification S.A. in 2023.

The International Organization for Standardisation (abbreviated to ISO) is a prestigious, international organisation dedicated to the preparation of standards for distinguished institutions. It was established in 1946 in London, and its founding conference was attended by 65 delegates from 25 countries, including representatives of the Polish Committee for Standardisation.

Obtaining the certificate confirms the commitment of the Companies to systemic prevention and counteraction of corruption risks.

What is corruption to us?

Corruption is the direct or indirect requesting, accepting, giving or promising of an undue pecuniary or personal benefit, in return for acting or omitting to act in a certain manner, in connection with the performance of a function in PZU.

Our commitments

PZU declares that it conducts its activities in compliance with the provisions of the law and with integrity. We counteract all forms of corruption to which the activities we carry out may be exposed.

  • We use a system for identifying, mitigating and monitoring corruption risks as a part of our business tasks and cooperation with business partners.
  • We implement solutions that manage the risk of corruption and counteract its potential negative impacts.
  • We apply a transparent process for selecting business partners - we are guided in particular by an assessment of their service quality, price, technical parameters and suitability.
  • We oblige our employees to act with integrity and avoid factors that increase the risk of corruption.
  • We implement anti-corruption education in the mandatory training programme for employees of PZU.
  • We responsibly manage cases of conflict of interest that may undermine our credibility.
  • We have transparent rules for sponsorship and prevention activities.
  • We define rules for accepting and giving gifts or benefits.
  • We avoid transactions that, by their nature or the manner in which they are conducted in business negotiations, could raise questions or give the impression of impropriety or illegality.
  • Employees of PZU may not demand or expect bribes or other forms of unjustified enrichment from PZU business partners.

PZU makes it possible to report corrupt behaviour under its Whistleblowing System, which you can find information about here.
 

What do we expect from our business partners?

Any form or attempt of corruption, including blackmail or bribery and any other illegal practices, is unacceptable in business relations with PZU.

We expect business partners of PZU to abide by the rules that we ourselves apply.

In particular, a business partner of PZU:

  • should ensure that the actions it takes comply with the provisions of the law and ethical standards.
  • is obliged to act with respect to the values listed in the Good Practices of the PZU Group and the Code of Good CSR Practices of PZU Group Suppliers.
  • is subject to an assessment by PZU on the risk of corruption.
  • shall identify and report to the PZU instances of risk of conflict of interest in the relationship with the PZU in order to work out how to manage it.
  • shall not directly or indirectly offer, promise, give or request material or personal benefits to employees of PZU in order to obtain an expected decision, induce or omit a certain action.
  • shall not give pecuniary or personal benefits to employees of PZU, their relatives or relatives in infringement of the rules in force in PZU.
  • is obliged, in principle, to accept the anti-corruption clauses of PZU in contracts concluded with PZU.

Exemplary anti-corruption clauses of PZU

  • The [Business Partner] declares that it has familiarised itself with the basic rules deriving from the anti-corruption standards defined by the Company and undertakes to comply with them.
  • An infringement by [Business Partner] of the anti-corruption standards laid down by the Company may be considered an infringement of the contractual provisions and constitute grounds for termination of the contract.
  • The [Business Partner] agrees that all payments to the benefit of the latter shall be made upon a receipt by [the Company] of an invoice, or other document constituting the basis for payment.

Outsourcing Policy

The objective of introducing an outsourcing policy at PZU SA and PZU Życie SA has been to fulfil the requirements that result from the new Insurance and Reinsurance Act. It implements the Solvency II Directive of the European Parliament into the Polish legal order. The outsourcing policy lays down in a new way the process of managing the risk of contracts concluded with suppliers, within the scope of insurance activities and reinsurance activities. It defines new rules and new tools for risk management in outsourcing contracts, as well as rules for outsourcing within the PZU Group and for a cooperation in this area with the Polish Financial Supervision Authority. The solutions introduced are aimed at ensuring the compliance of PZU with legal requirements and the expectations of the supervisory authority. The regulation serves to increase the effectiveness of outsourcing risk management.

Code of Ethics for Advertising

The Code of Ethics for Advertising at PZU aims to ensure the highest quality of marketing messages from PZU, respecting the interests of the Client and other market participants and the trust placed in PZU by Clients.

It takes into accountthe Rules for Advertising of Insurance Services issued by the Polish Financial Supervision Authority.

Whistleblowing System

PZU has implemented a Whistleblowing System that enables employees and those working with PZU to report irregularities of an ethical nature, in particular those that constitute an infringement of the standards of conduct adopted at PZU and actions that are inconsistent with provisions of the law and internal regulations.

The Whistleblowing System supports the application within PZU of the standards laid down in the Good Practices of the PZU Group.

PZU makes it possible to report behaviour that potentially infringes the Good Practices of the PZU Group or regulatory requirements to: zareaguj@pzu.pl Reporting should be done in good faith.

Important! There are separate addresses for reporting potential client complaints in the processes implemented in PZU – here you can learn how to do it.

Reports to the Whistleblowing System may be anonymous. When a report is made by name, the identity of the person making the report shall be treated according to the confidentiality rules.

When making a report, please:

  • provide a clear and concise description of the problem (indicate as much detail as possible to explain the basis for your report);
  • send (if available) copies of any relevant, lawfully obtained documents such as e-mails, telephone records, text messages, activity logs, meeting notes, photographs, letters or scans relating to your report;
  • provide (if applicable) a list of names and telephone numbers of other potential witnesses who can provide evidence of the circumstances of the report.
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