Corporate Social Responsibility Code of Conduct

Since 2017, we have been applying the principles of the Corporate Social Responsibility Code of Conduct - a key document on the TAURON Group’s ethical culture.

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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 prepared based on the mission, vision and corporate values of the TAURON Group. The Corporate Social Responsibility Code of Conduct defines the most important values and principles of conduct that should be followed by employees and stakeholders of the Group in the areas related to:

workplace

atural
environment

stakeholders

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

The adoption of the Corporate Social Responsibility Code of Conduct by the Management Board of TAURON Polska Energia on 4 April 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 the TAURON Group – regardless of the type of employment contract, seniority, position or function performed – is obliged to comply with the provisions of the TAURON Group’s Corporate Social Responsibility Code of Conduct. We also believe that our values and principles of conduct will be accepted by all the stakeholders and will become a mode to be followed in developing long-term relationships with all the stakeholder groups.

Due diligence procedures

Due diligence procedures in place under the Corporate Social Responsibility Code of Conduct include a compliance reporting system, as well as rules related to a conflict of interest.

The Compliance Officer (Power of Attorney) prepares a written report with respect to the tasks completed, after the end of every quarter – for the Audit Committee, and after the end of each half-year – for the Supervisory Board of TAURON Polska Energia S.A. In addition, after the end of every calendar year, the Compliance Officer (Power of Attorney) prepares a written Compliance Report on the functioning of the Compliance Management System in the 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.

Conflict of interest

The basis for preventing conflicts of interest at TAURON is the principle set out in the 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 the 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 the Group. We openly communicate (in accordance with the rules in force at TAURON 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.

Reporting of cases of violations of the Code’s provisions, including the above mentioned rules, takes place through the following communication channels:

  • in person, to the immediate superior or the Compliance Officer or the Compliance Coordinator,
  • in writing, to the following address: Compliance Officer, ul. Ks. Piotra ściegiennego 3, 40 -114 Katowice,
  • by phone at: + 48 32 774 22 22,
  • by email at: compliance@tauron.pl,
  • via the Abuse (Fraud) Report form available at the website.

In the event of receiving a notification of a conflict of interest, the Compliance Officer conducts fact finding investigations and also answers employee questions based on specific factual status. In 2019, actions were initiated to implement detailed rules for dealing with conflicts of interest in the TAURON Group. Their goal is to build awareness among employees with respect to preventing conflicts of interest, as well as to define uniform standards of conduct in counteracting such a situation that occurs or may occur in connection with the duties performed by employees and the operations of the subsidiaries.

In addition, it should be noted that a practical manifestation of counteracting conflicts of interest in the 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.

Furthermore, 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 tasks (executing orders), the scope of which may lead to a conflict of interest between him/her and the employer.

Document update by adding climate issues

In 2019, the Management Board of TAURON Polska Energia updated the TAURON Group’s Corporate Social Responsibility Code of Conduct with issues related to climate protection. According to the document, we are obliged to offset our impact by actions for environment and climate protection. On the other hand, the TAURON Group’s employees should identify potential threats, taking actions to prevent irregularities or failures posing a threat to the environment.

Actions taken and results achieved

One of the main tasks of the Compliance Officer and Compliance Coordinators in the TAURON 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 or procedures for verifying contractors.

The TAURON Group’s personnel, due to the e-learning platform, have access to two training courses on compliance topics covering the following issues:

  • verification of contractors – explanation of the importance of verification of contractors for the security of the Group and information when to apply for an assessment of a contractor’s credibility,
  • evaluation of external entities when organizing joint undertakings – explanation of the procedure for establishing cooperation with an external entity with respect to, for example, promotion or sponsorship and information to whom the application for an external entity evaluation should be submitted,
  • reporting fraud (abuse) – presentation of ways of reporting fraud in the Group and the ability of perceiving signals showing the possibility of fraud occurrence,
  • 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 it is unacceptable to do so,
  • counteracting corruption – showing what corrupt activities and unethical behaviors are, and who the TAURON Group’s Anti-Corruption Policy is applicable to.

By 31 December 2019, 77.63% of employees with access to the training platform had been trained on the Corporate Social Responsibility Code of Conduct in the TAURON Group, and 77.11% of eligible persons had obtained a positive result.

78.41% of employees with access to the e-learning platform had been trained on the Compliance Management System at TAURON Group by 31 December 2019, and 75.51% of eligible persons had completed the training with a positive result.

In addition to online training, we conducted 28 face to face meetings in 2019, as a result of which approx. 770 of the TAURON Group’s employees were trained.

Since November 2018, we have continuously conducted training courses for the managerial personnel of the following subsidiaries: Bioeko Grupa TAURON, SCE Jaworzno III, TAURON Ciepło, Spółka Usług Górniczych, TAURON Sprzedaż, TAURON Dystrybucja, TAURON Dystrybucja Pomiary, TAURON Obsługa Klienta, TAURON Wytwarzanie.

In order to develop the compliance culture in the TAURON Group, 19,900 brochures and 15,000 leaflets were also handed out in 2019.

18 messages related to the activities of the Compliance Officer were published via the Group’s intranet in 2019, regarding, for example, warnings against false, misleading decisions of the Patent Office, the procedure for accepting and giving gifts, the use of the split payment mechanism by the TAURON Group or invitations to the Compliance Day.

Compliance Day

On 30 September 2019, the first edition of the Compliance Day took place at TAURON Polska Energia, aiming to spread awareness among TAURON Group employees with respect to compliance management. The event was attended by the workforce of the TAURON Group’s subsidiaries and the Compliance Coordinators.

The event was composed of two parts:

  • an all-day consultation zone to enable mutual discussion and asking questions to the Compliance Team personnel,
  • practical workshops on, among others, the rules for verifying contractors (counterparties), standards for accepting and giving gifts, or a system for reporting fraud.

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