Corporate governance

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Best Practice Principles

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Compliance

Within the framework of building and implementing a compliance culture system at PKP CARGO Group, actions necessary to create a working environment based on respect for ethical standards and compliance with applicable laws and regulations are undertaken.

Compliance management system

A Compliance Department has been established at PKP CARGO Group, which is responsible for coordinating the compliance policy at PKP CARGO Group and for managing the areas of ethics and anti-corruption.

Within the Department, there is the position of Compliance Officer, reporting directly to the President of the Management Board with the possibility of reporting to the Audit Committee of the Supervisory Board, in accordance with the Good Practices of Companies Listed on the WSE.

The Compliance Management System is designed to:

• eliminate potential legal risks,
  investigate reported cases of non-compliance,
• provide preventive and proactive advice on the interpretation and application of compliance requirements,
• organise and conduct training and awareness programmes on compliance risks.

 

Code of Ethics

Ethics is the basis of an effective compliance risk management system and a system for prevention and detection of abuse in this area. The Code of Ethics adopted at PKP CARGO Group is based on values common to employees, i.e.: reliability, cooperation, good management, safety, professionalism, modernity, transparency, responsibility and respect.

The principles contained therein are binding for each employee regardless of his/her position and the nature of the tasks performed, as well as for customers, suppliers, competitors.

PKP CARGO Group has a Code of Ethics in force, containing a list of values and rules of behaviour which guide the Company in its relations with employees, customers, suppliers, competitors and the social environment.

Moreover, the above principles define its approach to minimising the company’s environmental damage in its operations. This document was created with the cooperation of the Company’s employees and customers. Work is already underway to implement the “PKP CARGO Group Code of Ethics” and the “PKP CARGO Group Anti-Corruption and Gift Policy”, as well as to appoint Compliance Coordinators in individual Group companies who will cooperate with the PKP CARGO S.A. Compliance Department. Coordinators in the companies will be responsible for explaining all ethics violations and corrupt activities and will be obliged to submit quarterly reports on their activities to the PKP CARGO S.A. Compliance Department, including the number of reported irregularities, conducted investigations, conducted trainings and an annual report on the functioning of the Group’s Anti-Corruption and Gift Policy and the Group’s Code of Ethics. The annual report will include, in particular, a summary of the violations reported and the corrective actions taken in relation to the violations identified. The above solution will contribute to the deepening of preventive actions and will allow monitoring the processes related to the area of ethics, counteracting corruption and other abuses in the entire PKP CARGO Group by creating an appropriate ethical culture. It is only possible through an appropriate policy of creating employee awareness and involvement of management bodies and senior management (eng. tone from the top).

Anti-corruption and gift policy at PKP CARGO Group

Preventing and combating fraud of a corrupt nature is one of the key activities of the Company in its relations with the business environment. PKP CARGO has adopted a policy of “zero tolerance for corruption” and any corruptive behaviour in all aspects of its operations.

The purpose of the introduced Policy is to determine the handling of corruption threats existing in PKP CARGO Group, including the ways of reacting and documenting cases of actual or potential corruption and shaping the awareness of Employees.

The rules contained in the Policy are binding both for the Company’s employees and all persons cooperating on the basis of civil-law contracts and other persons performing any activities on behalf or for the benefit of PKP CARGO Group.

The rules for accepting and giving gifts supplement the relevant provisions of the PKP CARGO S.A. Anti-Corruption Policy. The purpose of the Rules is to establish uniform standards for employees in offering and accepting Gifts, which may take the form of a gift or entertainment. A gift is an item of a specific value e.g. leather goods, a delicatessen basket, its value cannot exceed PLN 200.00 gross. Entertainment is understood as invitations to entertainment events, i.e. sports events, theatre performances, concerts or other cultural events, up to a value not exceeding PLN 500.00 gross.

The implementation and observance of the above rules is to ensure the elimination of situations in which the acceptance of gifts could affect business decisions at PKP CARGO Group. Giving and receiving gifts is forbidden during the submission of offers (orders, orders, etc.) and when the gift is cash or its equivalent.

In case of confirmation of the occurrence of corrupt activities or other violations, the Company shall take appropriate corrective actions to prevent future events of a similar nature Anti-Corruption and Gift Policy of PKP CARGO Group.

Reporting irregularities

The whistleblowing system in place at the Company aims to effectively prevent fraud and violations, protect the Company’s image and support operational risk management. Customers, Business Partners and persons outside the Company may report any irregularities through specially dedicated communication channels, i.e:

e-mail address: oznameni@pkpcargointernational.com

The PKP CARGO Group respects the right of whistleblowers to remain anonymous and to protect their personal data against any retaliatory actions.

The principles that PKP CARGO Group follows when dealing with signals of potential violations are:

• feedback communication,
• possibility to report by name or anonymously,
• reliability in explaining each signal.

The reporting channels in place at PKP CARGO Group are in line with good whistleblowing practices and the requirements set out in the Act on Public Offering and the Conditions for Introducing Financial Instruments to the Organised Trading System and on Public Companies and Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of whistleblowers.

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