We promote appropriate attitudes and point out to those unacceptable, inter alia, through e-learning and webinars. All employees are also obliged to monitor their environment in the context of the applicable standards. We react strongly to all identified irregularities.

Mobbing and Discrimination Counteracting

We have formulated and implemented the Policy against mobbing and 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 law and the internal regulations.

The HR Department as well as special opinion-making teams operating in some companies are responsible for counteracting mobbing and discrimination. 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. In 2019, the members of such teams participated in training dedicated to mobbing and discrimination.

In 2019, ENEA S.A. in cooperation with ENEA Centrum prepared e-learning training for the employees and webinars for the management staff entitled “Building a friendly working environment – prevention of mobbing and discrimination and other unacceptable conduct”. Also in 2019, ENEA S.A. received the “Company without mobbing” certificate issued by the Sanduro Anti-Mobbing Center. It confirms the high degree of protection provided to employees.

Prevention of corruption, bribery and conflicts of interest

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.

At the Group level, these matters are regulated inter alia in accordance with the following documents:

• Rules of Offering and Receiving Gifts in the ENEA Group
• ENEA Group Procurement Policy,
• Rules for conducting sponsorship activities in the ENEA Group,
• ENEA Group Compliance Policy,
• ENEA Group Code of Ethics.

There is the Organization and Compliance Unit operating within the ENEA S.A. Legal and Organizational Department, which monitors compliance of the companies with the law and internal regulations and, among others, prepares educational materials on the topic of preventing corruption.

All newly-recruited employees, as part of their orientation training, undergo compliance training, which places particular emphasis on anti-corruption issues. Moreover, training on this topic is held in the Group every three years or when the document regulating anti-corruption issues is amended or when a new one is introduced. In connection with an update of the ENEA Group Compliance Policy and the Rules of Offering and Receiving Gifts in the ENEA Group, such training was conducted in 2019. It took the form of e-learning sessions, while direct meetings were organized for employees having no access to the ITC system (work crews). Additionally, on the International Anti-Corruption Day, which is December 9th, a new corruption prevention training was launched on the e-learning platform, which is mandatory for all Group companies.

In 2019, an amendment was also adopted to the Rules of circulation of information on external inspections for the ENEA Group and activities performed by law enforcement agencies in the ENEA Group Companies. The amendment clarified the matter of responsibilities of units involved in external inspections and activities of law enforcement agencies conducted in the ENEA Group.

Selected activities undertaken by the ENEA Group companies in 2019

ENEA S.A. started implementing the Standards recommended for the compliance management system on counteracting corruption and the whistleblower protection system, adopted by the Management Board and the Supervisory Board of the Warsaw Stock Exchange. The Company incorporated provisions on compliance with the fair competition principles and the adopted anti-corruption standards into a number of its internal regulations. It also introduced new regulations, such as the Contractor Review Procedure.

ENEA Bioenergia adopted three model agreements: On confidentiality and prohibition of unfair competition (signed by all employees) O On prohibition of competition during the employment relationship and On prohibition of competition after termination of the employment relationship (signed by employees whose positions entail specific risks).

ENEA Serwis Sp. z o.o., in order to implement post-audit recommendations, continued supplementary compliance training emphasizing corruption prevention, which started in 2018. It was attended by employees designated by managers of the company’s organizational units. In addition, the company decided to conduct additional compliance and conflict of interest training for all of its employees, including members of work crews.

Identified deficiencies

In 2019, an investigation procedure was conducted in ENEA Serwis in the matter of two identified corruption cases. As a result of inspections and investigation, in one of the cases employment contracts with three employees were terminated. In the other identified case, the employees were subject to disciplinary procedures and underwent repeated corruption prevention training. The remedial plan was effective, which was confirmed by the routine inspection processes.