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.

No cases of corruption were reported in the Pekao Group in 2022.

Corruption Prevention Policy of the Bank Pekao S.A. Group (hereinafter: “Corruption Prevention Policy”) 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:

1. Rules and procedures concerning:
   • cooperation with intermediaries,
   • gifts and entertainment,
   • recruitment process,
   • cooperation with counterparties,
   • donations and sponsoring (including donations to political parties),
   • mergers and acquisitions,
   • significant investments,
   • the Bank’s participation in public procurement procedures,
2. Training and information programs for Bank employees on preventing corruption,
3. Designing and supervising the implementation of inspection mechanisms aimed at preventing corruption, applying and monitoring the compliance with such mechanisms by other business units of the Bank in accordance with the Bank’s internal regulations,
4. Estimation of compliance risk for the “Anti-Corruption Process”,
5. Establishing safe and easily accessible communication channels to be used by the Bank’s employees and other persons to report attempted corruption or actions regarded as corruption in a confidential way,
6. Reporting the progress in the implementation of the corruption prevention program to the Management Board of the Bank in the form of a quarterly report on the operations of the Compliance Department;
7. Precise and fair registration of all transactions in the books and documents of the Bank and avoiding undisclosed or unregistered accounts, funds, assets or transactions.

A Corruption Prevention Officer has been appointed at Bank Pekao’s Compliance Department who is responsible for reporting information about attempted corruption or actions regarded as corruption. 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.

In 2022, both Bank Pekao and Bank Pekao Group companies analyzed the risk of corruption. Bank Pekao has defined the main areas of corruption risk associated with its activities, which are:

The corruption risk analysis for the major corruption risk areas supplements the Bank’s due diligence applicable to other types of risk in these areas. The following were cited as potential areas of corruption risk: cooperation with intermediaries and contractors, conclusion and renewal of contracts with contractors, the process of giving gifts and invitations, the recruitment process, donations and sponsorships, merger and acquisition transactions, and participation in public procurement procedures. No significant corruption risks were identified in the subsidiaries.

The Compliance Department, in accordance with the Bank’s internal regulations, identifies, evaluates, controls, monitors and reports on corruption risks at the Bank.

Includes due diligence on new business partners in a comprehensive form. Intermediaries are examined for corruption risks prior to the start of cooperation and periodically. The Bank provides employees, intermediaries or contractors with the opportunity to report information about attempted corruption or corrupt activities that have occurred – this should be reported to the email address: PrzeciwdzialanieKorupcji@pekao.com.pl. Information in this regard is retained for the attention of the staff analyzing the case and reported within the management information system.

The Corruption Prevention Policy is communicated to employees at each update. Each employee is also required to familiarize himself with the content of the anti-corruption training, which is mandatory for all employees and culminates in a test to verify the knowledge acquired.