Ethics and anti-corruption

The structure of the Code’s issues follows directly from the guidelines for business in the area of ethics, including the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

The basis for responsible management activities in the area of ethics are the values adopted by the Polenergia Group, among others.

• Respect for and support of human rights
• Mutual respect and openness
• The welfare of the environment and local communities
• Integrity
• Responsibility and commitment

The Code sets out guidelines for conduct, key commitments and obligations of the employee and employer in the areas of labor standards and professional principles. The provisions address the issues of:

• Prohibition of all discrimination
• Culture of communication and conflict prevention
• Attention to respect for the environment
• Respect for the rights of local communities
• Anti-corruption
• Responsible dealings with contractors
• Employee accountability and reporting of violations

In 2022, compliance and anti-corruption awareness training was held for key managers of Group companies, a training process for all employees. Training for subcontractors is held before the start of each investment. During the implementation of investments, local communities have access to information points and are provided with information on contact persons.

Anti-corruption is an important area of corporate responsibility. As a member of the UN Global Compact, Polenergia Group pays special attention to the appropriate level of internal regulation of this area at the level of legal compliance and best practice regulation. Activities in the area of prevention of corruption incidents are particularly important by addressing them within the framework of the 10 Principles of the UN Global Compact.

The Anti-Corruption Policy is also being updated as part of the ongoing process of revising the entire ethics system and due diligence approach within the Polenergia Group over the course of 2022.

The new Policy applies throughout the Polenergia organization and applies to all Employees.

The purpose of the Policy is to:

• realize and complement the provisions of the Code of Ethics regarding the rejection of all forms of corruption and bribery;
• to define the principles of corruption prevention.

The Anti-Corruption Policy informs persons covered by its scope what corruption is, what types of corrupt behavior can be distinguished, possible ways to identify, prevent, report or respond to it.

As part of the activities related to the implementation of the new Policy in 2022, training sessions were held with key people for the area in the company and online training in the area of anti-corruption for all employees.