Corporate Social Responsibility Code of Conduct

Since 2017, TAURON Capital Group has been applying the principles of the Corporate Social Responsibility Code of Conduct (hereinafter the Code) – a key document on TAURON’s ethical culture. This set of principles and values, which is an impulse to create our own organizational culture, serves us as the foundation for the functioning of the organization and the implementation of strategic goals.

The document was based on the mission, vision and corporate values of TAURON Capital Group.

It also describes the Fraud Reporting System in place at TAURON Capital Group.

The adoption of the Code by the Management Board of TAURON Polska Energia on April 4, 2017, was related to the Compliance Management System being developed by the Group. Since then, we have been constantly improving the culture of compliance, understood as a set of specific principles of conduct in compliance with the law, internal and intra-corporate regulations, and ethical standards, which, combined with our values, support the achievement of business goals.

Each employee of TAURON Group – regardless of the type of employment contract, seniority, position or function performed – is obliged to comply with the provisions of TAURON Group’s Corporate Social Responsibility Code of Conduct.

DUE DILIGENCE PROCEDURES

Due diligence procedures in place under the Corporate Social Responsibility Code of Conduct include a compliance management reporting system, as well as rules related to counteracting conflict of interest and other irregularities (deficiencies).

After the end of every quarter the Compliance Officer (Power of Attorney) prepares a written report for the Audit Committee with respect to the tasks completed, and after the end of each half-year, he/she draws up a written report for the Supervisory Board of TAURON Polska Energia S.A. with respect to the tasks completed.

In addition, after the end of every calendar year, by January 31, the Compliance Officer (Power of Attorney) prepares a written Compliance Report on the functioning of the Compliance Management System at TAURON Group. The report includes, among others, an assessment of the adequacy and effectiveness of the Compliance Management System adopted in the period covered by the report, the degree of the Compliance Plan implementation, indication of measures taken or proposed in cases of non-compliance or the risk of non-compliance.

In 2020, the graphic design of TAURON Group’s Corporate Social Responsibility Code of Conduct was updated, in line with the new Visual Identification System.

CONFLICT OF INTEREST

TAURON Group is operating in a transparent manner, respecting the provisions of law, the provisions of internal and intra-corporate regulations as well as the highest ethical standards, which translates into actions aimed at eliminating situations that may lead to a conflict of interest.
The basis for preventing conflicts of interest at TAURON Group is the principle set out in TAURON Group’s Corporate Social Responsibility Code of Conduct, according to which: “We avoid situations that could potentially cause a conflict of interest.” A conflict of interest in case of an employee of TAURON Group occurs when, acting in his/her own interest or in the interest of any entity, the employee simultaneously carries out activities against the interest of TAURON Group. We openly communicate (in accordance with the rules in force at TAURON Group in this respect) cases that constitute or may constitute a source of conflict of interest, and we take actions aimed at eliminating the adverse consequences of such situations.

In 2020, the Rules for Counteracting Conflict of Interest at TAURON Group were adopted. Their purpose is to: identify circumstances that constitute a conflict of interest or may cause it, define the rules for preventing, identifying and managing a conflict of interest, and increasing the level of awareness among employees in terms of identifying, avoiding and disclosing a conflict of interest.

In the event of receiving a notification of a conflict of interest, the Compliance Officer conducts a fact-finding investigation and also answers employee questions based on specific factual status.

Conflict of interest registers are kept in order to document circumstances or events that may result or result in the emergence of a conflict of interest at the subsidiaries.

In addition, it should be noted that a practical manifestation of counteracting conflicts of interest at TAURON Group is the submission by the members of the tender committees and experts, for the needs of the given purchasing procedure, of statements on not having a legal or factual relationship with a contractor, that could raise reasonable doubts as to their impartiality.

What’s more, in accordance with the Labor Regulations in force at TAURON Polska Energia S.A., one of the employee’s basic obligations is to inform the superior about taking up additional employment, commencing business operations or performing specific jobs (orders), the scope of which may lead to a conflict of interest between him/her and the employer.

ACTIONS TAKEN AND RESULTS OBTAINED

The year 2020 was characterized by a further growth with respect to building a comprehensive Compliance Management System at TAURON Group. The current epidemiological situation in connection with the SARS-CoV-2 virus had a significant impact on the tasks performed. Some of the tasks planned to be performed according to TAURON Group’s Compliance Plan for 2020 had to be adapted to the changing environment or postponed to be implemented at another time. The above mentioned the situation had an impact, in particular, on the tasks that required in person meetings with employees, such as training sessions or conducting investigative (fact finding) proceedings. Due to the restrictions on gatherings in place, the role of online media has increased significantly (e.g., Skype, Teams). The tasks performed so far in the classic for have been almost completely replaced by the electronic form. For this purpose, among others, electronic registers (e.g., database of credibility ratings) have been developed.

Due to an increase in the efficiency of the work performed, the aforementioned changes should be viewed as positive.

One of the main tasks of the Compliance Officer and Compliance Coordinators at TAURON Capital Group is to periodically organize and conduct training courses on compliance issues. The above activities are aimed at increasing employee awareness with respect to, among others, preventing fraud, reporting irregularities, rules on accepting and giving gifts, procedures for verifying contractors preventing conflict of interest.
Due to the prevailing pandemic, in addition to e-learning training, TAURON Capital Group conducted a number of online meetings and training sessions in 2020, with approx. 5,300 employees taking part therein.

In 2020, 129 messages related to the operations of TAURON Group’s Compliance Area were sent via the Group’s intranet and mailing sent to the employees, regarding, e.g. the introduction of the Procedure for counteracting money laundering and financing of terrorism at TAURON Group, the introduction of the intra-corporate regulation on counteracting conflict of interest at TAURON Group, the adoption and application of the Rules of conduct during inspections (audits) at TAURON Group and the invitations to this year’s Virtual Compliance Day.

It should be mentioned that two e-learning training courses on compliance issues have been posted on the e-learning platform dedicated for TAURON Group’s personnel, i.e.:

1. training on TAURON Group’s Corporate Social Responsibility Code of Conduct,
2. training on TAURON Group’s Compliance Management System, covering the following topics:
   • verification of contractors – presentation why the issue of verification of contractors is so important for the security of the Group and when to apply for an assessment of the contractor’s credibility,
   • evaluation of external entities when organizing joint undertakings – presentation of the procedure for establishing cooperation with an external entity with respect to, for example, promotion or sponsorship and to whom the application for an external entity evaluation should be submitted,
   • reporting irregularities – presenting the available channels for reporting fraud at TAURON Capital Group and building awareness regarding warning signals about the possibility of a potential fraud being committed,
   • rules on accepting and giving gifts – building awareness about the type of gifts that can be received or given and defining the conditions in which their acceptance or giving is unacceptable,
   • counteracting corruption – showing what corrupt activities and unethical behaviors are, and who TAURON Group’s Anti-Corruption Policy is applicable to.

As of December 31, 2020:

• 16% of employees with access to the e-learning platform were trained on the Corporate Social Responsibility Code of Conduct at TAURON Group, and 75.97% of eligible persons completed the training with a positive result;
• 79.69% of employees with access to the e-learning platform were trained on the Compliance Management System at TAURON Group as of December 31, 2020. 79.25% of eligible persons completed the training with a positive result.

As part of Virtual Compliance Day 2020, 5 panel sessions on specific topics were carried out:

1. “Integrity and changes to the rules of liability of members of corporate authorities (officers) following the amendment to the Code of Commercial Companies” – the panel was dedicated for the Members of the Management Boards of TAURON Group’s subsidiaries,
2. “Mobbing – the legal and psychological aspects” – the panel was dedicated for the Members of the Ethics Committee of TAURON Group and the personnel of TPE S.A. Human Resources Area,
3. “News from the compliance industry. Integrated implementation of ISO 37301 (Compliance), 37001 (Anti-Bribery) and 37002 (Whistleblowing) standards in response to the need for a holistic approach to compliance management” – the panel dedicated to TAURON Group’s Compliance Coordinators,
4. “Get to know Compliance at TAURON Group … and find out what we do?” – the panel dedicated for the employees hired by TAURON Group in 2020 as well as for all interested parties.
5. “AML vs. the obligations of TAURON Group’s Subsidiaries” – the panel dedicated for the personnel of CUW – R TAURON Obsługa Klienta sp. o.o. and TAURON Ubezpieczenia sp. z o.o.

SEE ALSO:

Policy of Compliance with the Principles of Ethics and Counteracting Mobbing and Discrimination

Anti-Corruption Policy