Objective 4

We develop ethical standards and corporate culture

An important part of developing a shared corporate culture is the Ethics Officer.

Ethics Programme

The ethics programme is an expression of our belief in business conduct of the highest ethical standards, and is a vital component of our Sustainable Development and Responsible Business Strategy. In August 2011, following completion of an internal and external consultation process, the Management Board formally adopted the Code of Ethics and the PGNiG SA Ethics Programme Management System. Specific organisational measures and procedures were planned as part of the system, and the Management Board called on all PGNiG Group companies to implement similar solutions.

In order to ensure that our conduct in all our dealings with our stakeholders is in full compliance with these ethical standards, a number of organisational tools were implemented, primarily educational. For example, a detailed programme of training on business ethics entitled ‘Ethical behaviour’ was prepared for employees at all levels, to encourage them to reflect upon the concept of ethics, and to help them better understand the ethics programme in the context of their day-to-day behaviour. To raise awareness of ethical standards among employees, the Ethics Officer maintains an ‘ethics blog’ on the PGNiG Info intranet page. The blog’s entries shed more light on the moral challenges of everyday work and provide examples of model behaviour, and is becoming increasingly popular among our employees.

The Ethics Officer’s responsibilities also include consulting with the Internal Audit Office on the consistency of the PGNiG SA Ethics Programme Management System with the PGNiG SA fraud management programme.

In 2011, the ‘ethics hotline’ was opened, allowing any of PGNiG’s employees to call the Ethics Officer with questions or queries regarding ethical rules and standards. The hotline’s number and voicemail are available to all employees, 24/7. Initially, the ethics hotline was aimed at employees of those PGNiG Group companies which did not have their own comprehensive ethics programmes in place.

Although no ethical infringements have been formally reported as yet, a number of individual consultations have been held, not only by telephone and email, but also in face-to-face meetings. These consultations particularly covered the individual moral dilemmas of employees at various management levels. The employees’ questions covered specific work behaviours, in particular in supervisor – worker relations, and therefore involved analysis of individual cases, together with the reporting person, in order to work out the best possible solutions.

In 2011, an awareness and training meeting on the Code of Ethics, the Ethics Programme Management System and behaviour in high-risk situations was organised for senior managers. The meeting was attended by the President of the Management Board, Heads of Departments as well as employment optimisation process consultants. In December 2011, the Ethics Officer was appointed Head of the Ad-Hoc Team to analyse and submit an opinion on employee appeals in the collective redundancy process at the Company’s Head Office, the ultimate goal of which was to develop recommendations on the matter for the President of the Board. As part of the consultation process with the Shareholder Oversight Office, guidelines were agreed for harmonisation of the PGNiG SA Ethics Programme Management System with the guidelines and procedures provided in the Rules of Best Practice for PGNiG Group Managers, adopted by the Management Board in 2009. The rules detail specific conflicts of interest in management-level decision-making processes, and describe model conduct whenever a conflict of interest arises. Finally, such cases are analysed by the Ethics Officer.

The Ethics Officer held substantial consultations with those responsible for implementing the ethics programme in PGNiG Group companies, as well as collecting and reviewing reports from their respective ethics officers. Following consultation and development of related materials and presentations, the ethics programme was finally prepared for launch at 17 PGNiG Group companies in 2011.

The six strategic companies (WSG, GSG, KSG, DSG, MSG, PSG) have already filled their own ethics officer or ethics ombudsman positions. The organisational and formal solutions applied vary, but all are fully in line with the guidelines of the PGNiG SA Ethics Programme Management System. Some of the companies also plan to revise their codes of ethics or other ethics-related documents, and three have held special meetings between the PGNiG SA Ethics Officer and their management boards and managers, discussing the guidelines and specific solutions.

Seven other PGNiG Group companies also have ethics officers who take an active role, particularly in ethics education for managerial staff, and in the drafting of appropriate codes and procedures, including for the appointment of the ethics ombudsman.

The PGNiG SA Ethics Officer is also involved in the ethical standards communication process at various external conferences and meetings. These include a lecture on business ethics delivered at the ‘Marketing and PR in the Power Industry’ conference, organised by PTPIREE (Polish Association for Transmission and Distribution of Electricity) and held in Serock for representatives of the power industry; a lecture at the ‘Flexible workers, socially responsible employers’ conference, organised in Zakopane by the Nationwide Oil and Gas Trade Union (Ogólnopolski Związek Zawodowy Górnictwa Naftowego i Gazownictwa), and a lecture for prospective CSR staff as part of the Responsible Business League agenda.

Full implementation of the ethics programme in the PGNiG Group requires consistent effort and cooperation from all employees in the long-term ethical education process. Benefits from the programme will be maximised in line with the increase in awareness of the need to promote ethical conduct and standards and to monitor compliance, and to get staff involved in awareness-raising campaigns. Only then will the Code of Ethics truly begin to shape employees’ conduct and behaviour within the organisation and society as a whole.