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conduct in line with ethical rules, the law and internal procedures,
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mutual respect and openness in expressing views and opinions,
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It is based on compliance with the law and internal regulations, mutual trust, respect for beliefs and diversity of our employees, equal treatment and preventing any malpractice.
ENEA Group’s values
The ENEA Group has in place the Code of Ethics which defines the model conduct for all employees and introduces standards for relations with customers, business partners, shareholders, local communities and associates. Supervision over the implementation of its provisions is exercised by the Human Resources Management Department at ENEA S.A. Any identified cases of potential breach of the Code are objectively investigated by the Ethics Committee, which also deals with resolving any ethical doubts raised by the employees. The Committee operates on the basis of its rules and regulations, which define, among others, the procedures for reporting concerns and violations, as well as the handling of investigations.
Lubelski Węgiel “Bogdanka” S.A. has an internal Code of Ethics for GK LW “Bogdanka” S.A. which is consistent with the principles adopted for the entire Group. The units in charge of monitoring of compliance with its regulations are the Ethics Officer, who is also responsible for ethical education of employees, and the CSR Inspector.
3
reports to the Ethics Committee in 2020
0
confirmed violations of the Code of Ethics
Our day-to-day work values
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acting in compliance with our declarations with respect to quality, timeliness and reliability of services, performing employee obligations and performing the obligations set forth in social contracts,
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sharing knowledge and continuous upskilling, enabling employees to gain new experience,
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taking preventive and corrective actions in order to ensure a safe working environment, protection of the natural environment and protection of sensitive data, personal data and protected information.
Supporting diversity
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We are introducing clear and transparent principles of our joint cooperation and we also create an atmosphere which is favorable for all employees and associates. We strictly observe the principle of equal treatment irrespective of gender, age, origin, social status, health, sexual identity or beliefs, We consider diversity of our staff as value in itself but also as a driver of the organization’s development.
Our diversity policy has not been adopted as a separate document (Lubelski Węgiel “Bogdanka” S.A. is the only company with such a policy), but for years we have made efforts to ensure that diversity among employees, e.g. diversity of experience, knowledge or interests, is taken into account in our practices. The diversity issues are addressed in various documents, such as the ENEA Group Code of Ethics, internal collective bargaining agreements, Policy against mobbing, discrimination and other unacceptable conduct and the ENEA Group Compliance Policy.
So far, no diversity figures have been reported to the management boards and supervisory boards of the companies.
In 2020, ENEA S.A., ENEA Operator, ENEA Centrum, ENEA Wytwarzanie and ENEA Elektrownia Połaniec signed cooperation agreements with the State Fund for the Rehabilitation of the Disabled as part of the “Work – Integration” pilot program. It aims to increase its ratio of employment of people with disabilities on the open labor market. Within this initiative, the above companies declared their readiness to take action aimed at hiring the disabled and maintaining their employment – for a total of 25 FTEs for at least 18 months.
In 2020 Lubelski Węgiel “Bogdanka” in several of its departments, including the Communication Unit, Blasting Technique Department and the Cost Estimate Department, created jobs for people with disabilities resulting from workplace accidents.
Counteracting undesirable practices
We promote appropriate attitudes and point out to those unacceptable, inter alia, through e-learning and webinars and regularly announce where and how potential irregularities may be reported. All employees are obliged to monitor their surroundings in the context of the applicable regulations and standards and to report any situations that raise their concern. We react strongly to all identified irregularities.
The ENEA Group Breach Reporting Form enables notification of all irregularities, also anonymously and confidentially.
In our relations with Employees, Customers and counterparties, we abide by the applicable laws and the market’s strictest ethical standards, in particular in respect of counteracting corruption and avoiding conflicts of interest. We build an open and friendly corporate culture that reduces the likelihood of the emergence of any irregularities to a minimum.
Counteracting mobbing and discrimination
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We have formulated and implemented the Group-wide Policy against mobbing, discrimination and other unacceptable conduct, which identifies unacceptable conduct, the procedures for reporting it and handling the reports, as well as preventive measures. We provide full support to employees who feel they suffer from mobbing to have their case objectively investigated. If the allegations are confirmed, we apply corrective measures laid down in the Labor Code and the internal regulations.
Other regulations that are important for combating discrimination and mobbing include:
- ENEA Group Code of Ethics,
- ENEA Group Compliance Policy, which emphasizes, among others, the need for building a friendly working environment;
- Policy for reporting breaches and protecting whistleblowers in the ENEA Group (document adopted in 2020) – defines channels through which breaches may be reported, roles and persons responsible for their examination, and measures applied to protect persons reporting such breaches.
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The Human Resources Management Department is responsible for counteracting mobbing and discrimination. Additionally, special teams have been established in most companies to issue opinions in this area. Their task is to investigate all the allegations reported by employees and issue recommendations regarding alleged incidents of mobbing, discrimination or other behavior that is unacceptable in the workplace.
ENEA S.A. has cooperated with ENEA Centrum to prepare an e-learning training for the employees and webinars (for managers) entitled “Building a friendly working environment – prevention of mobbing, discrimination and other unacceptable conduct”. In 2020, the training was attended by employees of ENEA S.A., ENEA Operator, ENEA Wytwarzanie, ENEA Centrum, ENEA Oświetlenie, ENEA Trading, ENEA Serwis, ENEA Pomiary and ENEA Bioenergia. ENEA S.A. also passed a mobbing prevention audit, which allows it to use the “Company without mobbing” certificate issued by PCC Cert. It confirms the high degree of protection provided to employees and correct preventive measures and informational and educational activities.
0
confirmed cases of discrimination or mobbing in the ENEA Group in 2019-2020
In 2020, the following documents were prepared and put into practice: Procedure for Reporting Breaches in Lubelski Węgiel “Bogdanka” S.A. and Compliance Policy of Lubelski Węgiel “Bogdanka” S.A.
In 2020, ENEA S.A. and ENEA Wytwarzanie updated their internal regulations on counteracting mobbing, discrimination and other unacceptable behaviors. Corresponding internal regulations will be subsequently updated in other Group companies, in line with the principle of a uniform policy in this area.
Members of the anti-mobbing team at ENEA Pomiary sp. z o.o. participated in a training course on “Counteracting Mobbing and Discrimination”.
Prevention of corruption
We consider it a priority to prevent and eliminate all corrupt practices and to prevent the occurrence of conflicts of interest. We believe in transparency in our relations with business partners and educating employees in the area of compliance.
Anti-corruption regulations
The key document governing issues related to preventing the acceptance of financial and personal gains is the Rules for Offering and Receiving Gifts in the ENEA Group, providing for an obligation to obtain consent to accept gifts with a value greater than PLN 200. Issues related to counteracting corruption have also been standardized in the ENEA Group Compliance Policy and the ENEA Group Code of Ethics.
Provisions that support the Group’s efforts aimed at counteracting corruption are also included in the following documents:
- Policy for reporting breaches and protecting whistleblowers in the ENEA Group (adopted in 2020),
- ENEA Group Procurement Policy,
- ENEA Group Code of Conduct for Contractors (adopted in 2020), defining the fundamental requirements for contractors in terms of their compliance with the law and with ethical and market standards.
The elimination of breaches in this area is also expedited by the application of pertinent provisions of the internal documents in all Group companies, such as the rules for awarding contracts (containing a requirement that members of management boards and tender committees must submit statements confirming the absence of any relations on their part with contractors participating in the tenders), rules and regulations for creating lists of qualified contractors, principles governing the conduct of emergency purchases and work regulations.
ENEA Group’s anti-corruption system
The Organization and Compliance Unit, which is part of the Legal and Organizational Department at ENEA S.A., is responsible for the implementation of anti-corruption regulations. Since December 2019, the department’s director has also been the Compliance Officer of the ENEA Group.
In 2019, we divided the legal service, administration and security management between separate units, which until now had been handled by a single department within ENEA S.A. This allowed for a more precise division of responsibilities and facilitated enforcement of anti-corruption standards.
The duties of the Organization and Compliance Unit include, without limitation, issuing opinions on internal regulations prepared by various organizational units and cells (rules and regulations, instructions, principles, procedures, etc.) in terms of their consistency with other internal regulations. Additionally, the Department:
- conducts periodic reviews of statutory and derivative acts,
- provides ethics and compliance-related information on the intranet, with particular emphasis on counteracting corruption,
- provides support in the interpretation of regulations in the compliance area.
In 2020, activities were completed on the adaptation of the ENEA Group’s anti-corruption system to the Standards recommended for the compliance management system on counteracting corruption and the whistleblower protection system in companies listed on markets organized by the Warsaw Stock Exchange. The Organization and Compliance Unit was responsible for the performance of this assignment.
Anti-corruption education
A particularly significant component of the anti-corruption system is the creation of a proper organizational culture within the ENEA Group. This objective is pursued, among other measures, by direct and e-learning training for employees, promoting ethical and lawful behaviors, and information available on the intranet. The Rules for Offering and Receiving Gifts and endeavors aimed at preventing conflicts of interest and corruption offenses are elements of the mandatory initial training in all Group companies. In addition, training courses on this topic are regularly updated and repeated, especially when a document that governs anti-corruption issues is amended or when a new one comes into life.
In 2020, the following documents were prepared and put into practice: Procedure for Reporting Breaches in Lubelski Węgiel “Bogdanka” S.A. and Compliance Policy of Lubelski Węgiel “Bogdanka” S.A.
Materials on the compliance system and the Code of Conduct for Contractors were uploaded to the enea.pl website. Moreover, the website was supplemented with a form for the reporting of breaches.
ENEA Centrum adopted the Rules for the development, adoption, amendment, withdrawal and publication of internal regulations at ENEA Centrum sp. z o.o., and a process for monitoring changes in the legal environment was developed.
The Contracting Rules and Regulations at ENEA Elektrownia Połaniec S.A. have been amended to contain an obligation to attach declarations of no conflict of interest to agreements signed with contractors.
Employees of ENEA Trading participated in various training courses on ensuring compliance with the EU Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) and on preventing manipulation in the financial instruments market.
ENEA Ciepło put in place instructions for counteracting the emergence of conflicts of interest and cases of fraud in connection with the execution of projects co-funded under the Infrastructure and Environment Operational Programme for 2014-2020.
The Extraordinary General Meeting of ENEA Pomiary amended the company’s articles of association by introducing the obligation to prepare and submit to the Supervisory Board and the General Meeting an annual report on the application of best practices, as referred to in Article 7(3) of the Act on the Rules for Managing State Property.
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In February 2020, an anonymous report was filed regarding alleged corruption cases in ENEA Bioenergia related to biomass supplies. To investigate the case, the company appointed a special team which, after its examination, presented its final report on the assessment of the situation to the supervisory units. The report was presented to the Security Department of ENEA S.A., the Management Board of ENEA Elektrownia Połaniec, the Supervisory Board of ENEA Bioenergia and the Management Board of ENEA Bioenergia. The document contained proposals for improvements in the process of handling biomass supplies with a view to minimizing the risk of undesirable incidents. At the same time, the team found no evidence to support the allegations of corruption.