The PKO Bank Polski Group pursues a product policy that ensures:
The scope of this policy at the bank and in the bank’s Group encompasses both the stage of formulating the product offering, its presentation to the customer, its purchase (i.e. signing the agreement) and the stage of using the product by the customer. The principles and mechanisms for pursuing the compliance policy and the appropriate labelling of products apply to the bank and the whole of the bank’s Group.
The Group make every effort to ensure that all products offered meet the requirements set out in the provisions of the law and the accepted market standards. These efforts focus on ensuring that:
These rules apply not only to the bank and entities from the Group, but also to companies to which the bank has entrusted the performance of specific operations related to product sales or handling.
As part of ensuring compliance of the products with the applicable regulations, the bank manages the misselling risk at the stage of creating and introducing the product, and then at the stage of offering the product to customers. Each product undergoes pre-implementation analysis for the risks it generates and the identification of target customer groups. The bank also identifies the groups of customers to which the bank should not propose the purchase of a given product because of its inadequacy to the customer’s needs or for other reasons (the so-called anti-groups). If there are any anti-groups, control mechanisms are implemented to mitigate the risk of misselling. The risk of misselling is also mitigated at the stage of undertaking sales activity – before proposing to a customer the purchase of a product it is assessed whether a given product is adequate to the needs of this type of customer (in order to eliminate the cases, for example, of selling unemployment insurance to pensioners or long-term investment products to elderly persons). Additionally, the bank always provides reliable and comprehensive information to customers so that they can make an informed choice of a specific product. The bank acquaints customers with the benefits as well as the risk arising from the purchase of individual products.
The bank considers any irregularities reported by the bank’s customers, in particular in the form of a complaint, within the deadlines arising from the provisions of the law. Depending on the findings, the bank takes steps to eliminate such irregularities, prevent their future occurrence and improve the quality of service (more information in the chapter Governance matters).
Similar solutions concerning managing the risk of misselling, in keeping with the principle of proportionality, are also in place in the remaining entities of the bank’s Group which produce financial products or are involved in the process of their sale, i.e. in: PKO Zycie Towarzystwo Ubezpieczeń, PKO Towarzystwo Ubezpieczeń, PKO Bank Hipoteczny, PKO Towarzystwo Funduszy Inwestycyjnych and in PKO BP Finat sp. z o.o.
Description of administrative proceedings pending or completed in 2019 | Status |
---|---|
THE BANK | |
1. Proceedings initiated by the President of the UOKiK ex officio for regarding the provisions of the model agreement as inadmissible. The violation allegedly committed by the Bank consists of using in model agreements, annexes to loan and mortgage loan agreements which are revalued/indexed/denominated in foreign currencies and appendices thereto, the contractual provisions concerning the method of establishing the buying and selling rates of foreign currencies, which in the opinion of the President of UOKiK may be considered inadmissible in the light of Article 385 § 1 of the Polish Civil Code. | The proceedings are pending.
On 23 December 2019, the Bank informed about its intention to end the proceedings with an obligating decision and requested a meeting with the representatives of UOKiK in order to discuss the Bank’s position regarding the liabilities. As at 31 December 2019, the UOKiK President had not taken any further steps in this matter. |
2. Proceedings initiated by the President of the UOKiK ex officio on the Bank applying practices breaching collective consumer interests. The Bank is charged with collecting higher instalments on loans and foreign currency loans than those arising from the instructions concerning Forex risk presented to the consumers before concluding agreements and transferring potential Forex risk to the consumers. | The proceedings are pending.
In a letter dated 14 March 2019, the UOKiK President asked the Bank 16 detailed questions in order to establish the circumstances that are necessary to resolve the case. The Bank gave the answers in a letter dated 10 May 2019. As at 31 December 2019, the UOKiK President had not taken any further steps in this matter.
|
3. Proceedings initiated by the President of the UOKiK ex officio for regarding the provisions of the model agreement as inadmissible. The violation allegedly committed by the Bank consists of using modification clauses authorizing the Bank to change the contractual terms in model agreements, which in the opinion of the President of UOKiK may be considered inadmissible in the light of Article 385 § 1 of the Polish Civil Code. | The proceedings are pending.
In a letter of 31 May 2019, the Bank commented on the allegations of the President of UOKiK. In a letter of 19 December 2019, the UOKiK President extended the deadline for completing the proceedings until 30 April 2020.
|
OTHER GROUP ENTITIES | |
No proceedings. |
In 2019, two court proceedings were conducted with respect to the bank. They were related to the application of unfair competition practices (one is before the Court of Appeal and the other one was pending before the Supreme Court and was completed). No new court proceedings were initiated in 2019 concerning anti-competitive or anti-market practices.
Description of court proceedings pending in 2019 | Status |
---|---|
The Bank is a party to court proceedings brought by the UOKiK President by a decision dated 23 April 2001 based on a motion by the Polish Organization of Trade and Distribution – the Employers Association against the operators of the Visa payment system, Europay and banks – issuers of Visa and Europay/ Eurocard/ Mastercard cards. The claims under these proceedings relate to the use of practices limiting competition on the market of banking card payments in Poland, consisting of applying pre-agreed ‘interchange’ fees for transactions made using the above cards as well as limiting access to this market for other entities. | The court proceedings are pending.
On 29 December 2006, UOKiK decided that the practices consisting of the joint establishment of an ‘interchange’ fee did limit market competition and ordered that any such practices be discontinued, and imposed a fine on, among others, the Bank, amounting to PLN 16.6 million. The Bank appealed against the above-mentioned decision of the UOKiK President to the Court for the Competition and Consumer Protection / Sąd Ochrony Konkurencji i Konsumentów – SOKiK). By the ruling of 21 November 2013, SOKiK reduced the fine imposed on the Bank to PLN 10.4 million. The parties to the proceedings filed an appeal. The Court of Appeal in Warsaw in its ruling dated 6 October 2015 reinstated the initial amount of the imposed fines set in the decision of the UOKiK, i.e. the fine of PLN 16.6 million (the fine imposed on PKO Bank Polski SA) and the fine of PLN 4.8 million (the fine imposed on Nordea Bank Polska SA). The Bank paid the fine in October 2015. As a result of a cassation appeal brought by the Banks, the Supreme Court in a ruling of 25 October 2017 annulled the contested ruling of the Court of Appeal in Warsaw and remanded the case. The fines paid by the Bank were reimbursed to the Bank on 21 March 2018. The case is currently pending before the Court of Appeal in Warsaw. The hearing was postponed without setting the date of the next hearing.
|
The Bank was a party to court proceedings brought by the decision of the President of the UOKiK in connection with the suspicion of applying illegal contractual provisions in model agreements for granting consumer loans, other than credit card agreements. | The proceedings have been completed.
By decision of 31 December 2013, the Bank’s activities were considered as practices violating the collective interests of consumers and a fine in the amount of PLN 29 million was imposed on the Bank by the President of UOKiK. The Bank appealed against this decision to SOKiK. By a ruling of 9 July 2015, SOKiK waived the entire decision of the President of the UOKiK. On 21 August 2015, the President of UOKiK brought an appeal against this ruling. On 31 May 2017, the Court of Appeal in Warsaw upheld the decision of SOKiK favourable to the Bank on annulling the decision in which the UOKiK concluded that the Bank breached the collective interests of the consumers by applying the so-called variable interest rate clauses, and in consequence annulling the penalty of PLN 17 million. As regards the second alleged malpractice of the Bank relating to the use of an information form, the Court of Appeal considered that the appeal was partly justified, and at the same time reduced the penalty imposed by UOKiK on the Bank from PLN 12 million to PLN 6 million. The penalty was paid on 17 July 2017. On 23 October 2017, the Bank lodged a cassation appeal against the judgment of the Court of Appeal. The cassation appeal was also brought by the President of UOKiK. In its decision dated 10 April 2019, the Supreme Court rejected both cassation appeals.
|
OTHER GROUP ENTITIES | |
No proceedings. |
[GRI 417-1] The PKO Bank Polski Group fulfills the requirements concerning correct labelling of the bank products and investment products by providing the customers with all the necessary information about them, especially at the pre-contract stage.
The scope of information provided about the products is specified by the applicable provisions of the law and the recommendations of the PFSA. The general rule is that the highest level of protection is available to retail customers – consumers. This information is formulated in such a way that it is understandable to the so-called “average consumer” within the meaning of the Act on counteracting unfair market practices – a consumer who is sufficiently well-informed, attentive and cautious. However, the scope of information provided to financial institutions and other professional recipients of financial products and services is narrower.
The bank performs its statutory information obligations:
a) in relation to deposit products, by:
b) in relation to investment products,
c) in relation to loan products, in accordance with the provisions of the Act on consumer credit and the Act on mortgage loans and supervision over mortgage brokers and agents, by:
d) in relation to insurance products, in accordance with the provisions of the Act on insurance agencies and Recommendation U of the Polish Financial Supervision Authority regarding good bancassurance practices, by:
The proper product labelling also applies to the bank’s advertising messages which support its sales activities and shape its brand image. All marketing materials published by the bank take into account the specific obligations arising from the commonly binding provisions of the law (e.g. the Consumer Credit Act – within the scope of advertising this type of loan) as well as market standards and the PFSA guidance formulated in the “Rules of advertising banking services”.
The bank makes every effort to ensure that the marketing communications about products clearly indicate to which product or service they relate, that they are formulated reliably and do not mislead their recipients, as well as to show the recipients how to access the complete information about the advertised product and about the benefits and risks related to it.
One of the bank’s priorities is to set the highest security standards. customer security in the process of using the bank’s and the bank Group’s products primarily includes security of the funds of customers, as well as physical security of customers in the bank’s facilities. The matter of security is regulated by the internal regulations of the bank, including the Security Policy at PKO Bank Polski and – in detail – the provisions regarding specific areas of security, i.e.: (i) protection of people and property, (ii) IT System security, and (iii) managing safety incidents.
The activities of the bank and other entities of the bank’s Group related to ensuring the security of customer funds apply to the assurance of security of the funds entrusted, as well as the funds invested with the use of the products offered. The initiatives implemented regarding the assurance of a stable and secure ICT infrastructure enabled the achievement of very high reliability indicators for the operation of the IT infrastructure applications.
Security of funds invested: The bank makes every effort to ensure that the products offered to customers do not generate the risk of a loss of funds. This is particularly important in the case of investment products. Therefore, within the framework of the obligations imposed by the MiFID, the bank informs customers before conducting a transaction on financial instruments as to whether the given product is suitable for them.
Security of entrusted deposits: With respect to deposit products, the main mechanism guaranteeing security of funds entrusted by customers is the stability of the bank’s financial result and the results of the other entities belonging to the bank’s Group. An additional mechanism is the bank’s involvement in the obligatory deposit guarantee system, operating under the Act on the bank Guarantee Fund, the term deposit guarantee system and special resolution.
The security of customer funds is also guaranteed at the bank by such procedural solutions that ensure the correct identification of the customer in every case of performing his instructions.
The most important threat to the security of customers using the Group’s products identified by the bank and PKO Towarzystwo Funduszy Inwestycyjnych are potential criminal activities of third parties targeted at customers using electronic channels of access to banking and investment services.
First, the bank uses the latest ICT security solutions guaranteeing secure access to funds held by customers, while the bank is constantly improving the quality of IT systems security, in particular regarding the applications used by the bank’s customers. This applies, among other things, to actively combating phishing websites pretending to be the bank’s websites, tracking the development of malware attacking the bank’s customers, developing mechanisms for detecting infected customer computers, improving the rules and extending the scope of monitoring of electronic transactions.
Second, the bank attaches a great deal of importance to informing and raising customer awareness of the safe use of electronic banking services, as well as payment cards, as security in this respect depends to a large extent on the user’s actions. These activities include in particular:
In 2019, the systems for incident, anomaly and advanced malware identification were improved and a large number of actions relating to incident handling were automated. The technology stack of solutions used for computer forensics purposes was replaced.
The specialist CERT unit operating within the bank’s structures executes a strategy of ensuring IT security of the services provided. Incident response operates 24/7/365. CERT PKO bank Polski is a member of an international forum of responders – FIRST, and belongs to the task force of European responding teams – TERENA TF-CSIRT and the related Trusted Introducer organization.
Joining the international organizations enables the bank’s CERT team to respond faster and more effectively to cybersecurity threats by operational collaboration and exchange of experience and knowledge with similar entities throughout the world. The membership is also confirmation of the high level of the services rendered and acknowledgement of the professionalism and skills in the area of ensuring IT security at the bank. As a result, the bank is perceived as an organization that complies not only with domestic, but also international cybersecurity standards.
Representatives of the bank also engage in the works of the Banking Cybersecurity Centre (BCC) operating within the Polish Bank Association. The purpose of BCC is to take comprehensive and long-term actions on several levels: intrasectoral, intersectoral (including cooperation with telecommunication, transport or power sector institutions), nationwide (cooperation with the state administration or law enforcement) and international, which are aimed at improving the safety of mobile and electronic banking and preparing crisis management tools (structures, procedures, information exchange mechanisms) in the case of e.g. a massive attack of cybercriminals on the banking sector.
As part of the exchange of information on threats, in 2019 the bank used information on malware, incidents or phishing attacks, including in particular data on trends and new threats, from CIRCL – the Computer Incident Response Center Luxembourg and NICP – the institutions participating in the NATO Industry Cyber Partnership, of which PKO Bank Polski is a member (as the only bank from Poland).
The high organizational maturity in the area of handling cybersecurity incidents is particularly important in the light of the decision of the PFSA of 2018 concerning acknowledging PKO Bank Polski as an operator of a key service as defined by the Act on the national cybersecurity system.
The bank and the other entities of the bank’s Group fulfil the condition of ensuring the highest quality of direct service in their locations, among other things, by ensuring proper standards of comfort and safety. The sites of the bank and the Group’s entities use state-of-the-art technical solutions in the area of physical security of customers, employees, funds and protected information, including bank secret and personal data.
The security is provided in the form of:
Moreover, in the interest of the security of customers and employees, the bank holds training courses for all employees of its branches and agencies, including “Counteracting robberies and dealing with security threats”.
During the dialogue with customers regarding, among other things, the products offered, customer satisfaction surveys are conducted at the bank, which are divided into two main segments: the retail customer and corporate customer. The number of companies in the bank’s Group that conducted their own surveys increased in 2019.
In 2019, customer satisfaction and the level of recommendations of the bank were included in the objectives of the selected bank units responsible for the development of banking products and processes for the first time. Therefore, the principle that customer satisfaction is the key to designing and implementing the most important products and solutions offered to the customers by the bank was maintained.
With regard to retail customers, the bank continued two types of satisfaction surveys:
Both the Net Promoter Score (NPS) and customer Satisfaction Index (CSI) indicators are used in both types of survey.
In 2019, the bank developed the techniques for collecting customers’ opinions, using e-mail, text messages and IVR for the first time. At the same time, telephone messages remained the main source of knowledge on the level of customer satisfaction.
Relational research is still outsourced, although in 2019 the bank launched its own continuous relational customer satisfaction measurement, which is conducted daily. Transactional research is still conducted with the bank’s own resources through the Call Center.
Overall, in 2019, the bank held more than 220 000 interviews with retail customers using various methods. The plans encompass continually increasing the number of processes monitored for customer satisfaction (products and sales channels).
Customer satisfaction measurements were developed in 2019 in the other bank’s Group entities as well. PKO Życie Towarzystwo Ubezpieczeń carried out a regular campaign called “NPS Benefits”, i.e. a quantitative measurement of the level of recommendation of the process of payment of benefits for sixteen products of the company. Several hundred telephone interviews are conducted as part of this project every year. PKO BP Finat Sp. z o.o. also regularly measures the satisfaction of institutional customers of the most important business lines. As far as the frequency of customer satisfaction measurements is concerned, the most advanced Group company (after the bank) is KREDOBANK. The company conducts a number of activities focused on monitoring the level of satisfaction of retail customers. The basic measure of satisfaction in KREDOBANK’s surveys is the Net Promoter Score (NPS). In 2019, KREDOBANK conducted more than 2 500 interviews.
The year 2019 was the third full year of the operation of the customer Satisfaction Survey Programme (implemented also in PKO Leasing and PKO Faktoring) for the corporate customer segment. We continued to conduct telephone interviews with customers of corporate, strategic and international banking in order to better understand how they perceive their relationship with the PKO Bank Polski Group, the individual products and service channels. The customers respond well to this form of dialogue, as confirmed by the continued high Response Rate of 63%.
The purpose of the Programme is to respond to customers’ needs, both through contact with the individual entities and by developing long-term solutions. Since the programme was started, 99 initiatives have been completed, including 28 in 2019. The changes were implemented, among other things, in the area of digitization of further service processes (in particular, in the area of loans and opening of new accounts). Moreover, the hours of concluding Forex transactions were extended and changes were made to post-sales service at PKO Leasing (development of remote access/service channels, collective invoices, etc.).
The customer’s voice is an indispensable component of the operations of teams that apply agile work methods. Prioritization of work takes into account diagnosed needs of the customers, and the solutions prepared are verified with the users before their implementation as UX matrices, and after the implementation – through collecting feedback from the first customers using a given service. This allows fast response and optimum adjustment of solutions to the customers’ needs.
PKO Bank Polski operates in accordance with the bank’s internal regulations concerning the principles for conducting marketing activities. In marketing communications, the bank complies with the principles of ethics, which are described in the Appendix “General requirements for creating advertising messages regarding trading in financial instruments”. The bank’s internal regulations concerning the principles for conducting marketing activity define the features of the appropriate advertising message, as well as the list of undesirable actions. According to these principles, an advertising message in particular:
According to these principles, an advertising message in particular:
In addition to the bank’s internal regulations, in its marketing communications the bank follows:
In its marketing activities, the bank has mechanisms that prevent the creation of unethical and unreliable messages. Each time, the correctness of the communication is consulted with the units whose tasks include verifying the compliance of messages with the generally applicable laws. The principles of ethics in marketing communication and the mechanisms for preventing the risk of unethical communications also apply to materials prepared at the request of the bank by external entities (advertising agencies, event agencies).
The same standards apply to all customer groups. Each message must be formulated in a comprehensible, reliable, credible way, regardless of the customer to whom it is addressed.
Within the bank’s Group, entities have internal regulations and provisions which require them to design messages with the observance of ethical standards (this does not apply to entities that do not conduct active marketing activities). These standards coincide with those adopted by the bank. In addition, the bank’s subsidiaries, which have signed agency agreements with the bank concerning commissioning of marketing services, are required to apply the internal regulations on marketing communications in force at the bank.
With regard to their marketing activities, all the remaining subsidiaries of the bank have control mechanisms to prevent the risk of an irresponsible or unethical communication from the company. The marketing communication is appropriately approved by the company’s supervisory units respectively, or additionally – in the case of companies that have agreements with the bank concerning commissioning of marketing services for the bank’s Group – by the bank’s relevant departments.
In 2019, as part of the marketing activities conducted by the bank’s Group and the bank, no administrative proceedings concerning violation of the regulations regarding ethics in marketing communications were pending and no inconsistencies were noted in marketing communications. [GRI 417-3]
In accordance with the generally applicable regulations, including the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR) and the Personal Data Protection Act of 10 May 2018, PKO Bank Polski has internal personal data protection regulations.
These internal regulations apply to the principles of personal data processing at the bank, in particular the method in which they are processed, as well as the technical and organizational measures ensuring security of the data being processed.
Additionally, the bank applies internal regulations regarding in particular:
In the process of security management in the bank’s Group, Strategic Companies have been identified and Agreements introducing Security Standards have been signed with them. The Standards address the following issues: personal data protection, business continuity management, ICT security, counteracting money laundering, security incident management, outsourcing principles and security reporting principles.
Furthermore, the Group has a policy in place for counteracting money laundering.
There are also polices in place that require notifying the customers about any violations of security of data collected in accordance with the applicable legal requirements, including the principle of data minimization. The customers receive unambiguous and clear information about the principles for the processing of information and the manner of using it in compliance with the law, including the General Data Protection Regulation. The customers are also informed about their rights, including the rights to access, change, withdraw, supplement and update information. In addition to the above, there are paths for filing complaints available to the customers, including the paths for expressing doubts about personal data security. Every employee is obliged to complete appropriate training in personal data protection. Such training is also organized periodically. Actions aimed at ensuring data security are taken with the participation of the Management Board. For this purpose, the best policies and system security solutions are implemented. Such solutions (in terms of both systems and policies) are constantly evaluated, audited and improved in accordance with the best market practices. Any irregularities are addressed in compliance with the law, which includes informing the competent authorities.
The risk of unauthorized access to customer information is managed in accordance with the Security Policy of PKO Bank Polski. At the same time, the Principles of protected information security at PKO Bank Polski regulate the issues of confidentiality of information and the maintenance of bank secrecy, as well as personal data security, including the liability of the bank’s employees regarding personal data protection.
In accordance with these principles:
Each of the other bank Group’s entities processing personal data, which is required to have appropriate regulations in this respect, has such regulations in place and applies them in practice. They are in line with the generally applicable regulations and standards applied at the bank and, to the extent necessary, contain specific regulations which are adequate to the specific nature of the particular entity’s business.
In accordance with GDPR, cases of breach of personal data protection resulting in a risk breaching personal rights and freedoms are reported to the President of the Personal Data Protection Office (UODO).
PKO Bank Polski does not tolerate corruption and counteracts all corrupt practices. Such phenomena as nepotism and accepting or offering any physical goods in order to influence decisions or actions taken are in conflict with the bank’s values of credibility and trust.
The bank has a number of internal regulations regarding the prevention of corruption, including accepting benefits, presents or gifts. They are primarily:
The bank applies internal anti-corruption rules intended to prevent the creation of an environment which is conducive to the offences referred to in Articles 229, 230a, 296a and 305 of the Penal Code (acts of corruption) by entities related to the bank, including, in particular, solutions ensuring:
[GRI 205-1] Within the bank’s Group, including the bank, the risks related to corruption are identified in particular:
These areas are subject to particular attention, the processes are regulated in detail, while decisions which have significant financial consequences are accepted, in principle, through the so-called “second hand” (they require dual acceptance).
The internal regulations of the bank on the prevention of corruption are very detailed. With regard to the bank’s employees and people acting on behalf of the bank, they include:
1. The prohibition to accept benefits, presents or gifts intended for personal use from customers and potential customers, as well as representatives of entities cooperating with the bank or seeking to start cooperation with the bank, which could:
This prohibition applies, in particular, to cash or cash equivalents, physical donations (presents and gifts) and other material benefits (in particular financing of travelling expenses, relaxation or training costs, participation in an event, or lending an asset, e.g. a car, for free use or use on terms that deviate from market terms), as well as the acceptance by any person involved in the procurement proceedings organized by the bank, of any gifts and benefits from entities which are bidders or potential bidders in these proceedings.
2. the exclusion of the possibility of circumventing the above prohibition, in particular by persuading other people (e.g. people living together in a household, family members or relatives) to accept the gift on their behalf under exceptional circumstances, it is acceptable to accept a benefit or gift in business relations, on the terms and conditions set out in the bank’s internal regulations regarding the acceptance of benefits, presents or gifts,
3. the prohibition to offer any benefits, presents, gifts or incentives to customers, trading partners, representatives of bodies of public administration and other entities, which are not a part of the bank’s offering of products and services, on behalf of the bank, in order to persuade those persons to behave in a particular way, especially to take steps which are inconsistent with the provisions of the law or good practices.
If a bank’s employee has doubts as to whether the acceptance of a benefit, present or gift is admissible in a given situation, he is required to consult his supervisor or the appropriate organizational unit at the bank, which manages compliance risk. Every new employee of the bank receives information on the principles regarding this matter.
Corrupt behaviour is treated as non-compliance and as such it should be reported to the bank’s Management Board and Supervisory Board. The risk of corruption is an element of the compliance risk assessment process.
In the remaining entities of the bank’s Group, each of the subsidiaries, the business of which is related to the risk of corruption, has the appropriate regulations on the prevention of corrupt practices. Every employee is required to read and apply these regulations. Each entity formulates appropriate regulations, taking into account the specificity of its activities and its own assessment of the areas of risk of corruption and bribery, which is why the bank’s Group does not have a uniform policy in this respect.
No critical events in this area were identified in 2019 and no corruption activities were identified in the bank’s Group entities which would result in disrupting the operations of the bank or of the other entities belonging to the bank’s Group.
The bank and the other bank’s Group entities also apply their anti-corruption activities to their potential trading partners. When joining the procurement procedure, the bidder declares that “he does not offer or provide any financial benefits to influence the decision on the selection of his proposal. He does not affect the choice of proposal in a manner which is in conflict with the law or good practices and does not take part in any agreements or arrangements with other third parties, which would have the objective of influencing their selection.”
The bank has an anonymous system for reporting breaches (the institution of the whistle-blower relates to all unethical or illegal acts). Additionally, under the internal regulations, each of the bank’s employees is obliged to report any suspicion of a crime having been committed in connection with the bank’s activities. A report regarding a member of the Management Board is addressed to the Supervisory Board, in other cases – to the President of the bank’s Management Board. Each matter is dealt with on the basis of the internal regulations. There is a requirement at the bank to submit regular reports to the Management Board about identified cases of fraud, including those involving corrupt activities.
In the case of a breach by an employee of the bank of the generally applicable provisions of the law and the bank’s internal regulations, including those regarding corruption, the bank applies the solutions specified in the provisions of the labour law. If a particular case is qualified as grounds for instituting disciplinary proceedings, such proceedings are conducted and – depending on their outcome – the bank applies the list of consequences provided for in the above regulations, including the right to terminate the employee’s employment contract.
Reporting persons are protected – nobody can be fired or punished otherwise for reporting a breach.
The bank holds preliminary and regular training for the bank’s employees on the reporting of breaches and cases of non-compliance (including those bearing signs of corruption) and gives them access to the necessary information and internal regulations in this area (also in an electronic form on the bank’s website). Every employee of the bank is required to undergo training regarding the principles for counteracting any corrupt practices.
Information on the notified breaches is reported to the Management Board and Supervisory Board of the bank.
Similar solutions are applied at the selected companies of the bank’s Group adequately to the scale and scope of their activities.
[GRI 205-3] No cases of corruption were confirmed in 2019.
In the process of developing regulations, procedures and policies referring to human rights, the individual entities belonging to the bank’s Group draw from the achievements of international organizations and respect the fundamental principles set in the International Bill of Rights which is composed of the following three documents:
Depending on the size and specificity of a given entity of the bank’s Group, observing human rights is manifested equally in the internal provisions, the initiatives undertaken and in everyday practice. This applies, in particular, to the rights to:
Some of the bank’s Group entities have included provisions related to respect for human rights and the prohibition of discrimination in such documents as:
At the bank, references to respect for human rights are contained in:
as well as in strategic programmes such as:
Issues regarding forced labour and child labour are not directly reflected in the bank’s regulations, because:
The other entities from the bank’s Group consider that there is no need to formalize the issue of respect for human rights, although matters of respect for human rights are taken into account in the processes conducted, everyday practice and in the unwritten rules.
One of the most crucial elements/stages of the analysis is the identification of human rights in the context of the operations conducted. The bank’s Group operates in several countries where it provides financial services, which sets the scope of the human rights to be considered, and thus eliminates the challenges faced, for example, by manufacturing or mining companies. The countries in which the bank’s Group operates are characterized by a similar level of development, and thus also challenges related to employment – no cases of underage employment or forced labour were identified.
An immense task is the issue of observing the human rights in the supply chain, which in the context of the bank’s Group entities boils down to relations with suppliers and outsourcing of services (mainly banking services). The issues of compliance with human rights are reflected in the procedures and agreements signed with these entities.
Examples of activities conducted within the bank’s Group entities, in which respect for human rights is disclosed, are presented below:
The bank’s Group applies the same human rights standards across the entire supply chain in its business activities. In relations with external entities, special attention is paid to:
According to the assessment conducted in this report, there were no cases of breaches of human rights in the bank’s Group in 2019, and the actions taken are aimed at preventing their occurrence.
The Group entities monitor the risks accompanying the individual human rights and manage them at the firm’s level. These types of risks and the manner of their management have been discussed in detail in the chapters referring to individual human rights.
The basic internal communication tool is the Intranet portal of the bank which is regularly updated and contains information on benefits, privileges, rights and obligations of the bank’s employees. Additionally, the employees receive all types of necessary information via internal mail in the form of bulletins or information campaigns addressed to them (screen savers, posters, pop-ups).
On the intranet portal of the bank the employees may find the following documents referring in various ways to the human rights issues:
Human rights are communicated externally through the bank’s publicly accessible website, which contains information about the PKO Bank Polski Foundation, about the idea of the charity it pursues as a measure of respect for the environment, in particular for other people.
The bank verified its approach to the issue of observing human rights by making available the non-financial report to all potential stakeholders.
PKO Bank Polski treats responsibility for its business as an integral part of its business strategy. It supports customers whenever they have problems with timely repayment of their liabilities. In such situations, the bank adjusts its actions to the customer’s situation. The availability of the offer supporting CHF mortgage borrowers by mitigating the adverse effects of changes in the exchange rate was extended until 31 December 2020.
For many years, the Bank Polski Group, and especially PKO Bank Polski and PKO Leasing, has been actively involved in working with public sector entities. This cooperation also includes supporting their activities in the form of loans, for instance, with regard to the expansion and renovation of schools, hospitals, road projects and environmental protection. As at the end of 2019, loans to the sectors O, Q, R (see the table below) represented in total 8.4% of the bank’s loan portfolio for the corporate and public sectors. In the bank’s Group, the share was 6.8%.
GROUP | of which: BANK | |||||
---|---|---|---|---|---|---|
Section of the Polish NACE codes | 2017 | 2018 | 2019 | 2017 | 2018 | 2019 |
O. Public administration and national defence, mandatory social security, including LGUs | 7.2% | 5.3% | 4.8% | 8.2% | 6.0% | 6.6% |
Q. Healthcare and social welfare | 1.3% | 1.4% | 1.4% | 1.1% | 1.1% | 1.3% |
R. Cultural, entertaimen and recreational activities | 0.5% | 0.5% | 0.5% | 0.5% | 0.5% | 0.5% |
Sekcje O, Q, R total: | 9.0% | 7.2% | 6.8% | 9.8% | 7.6% | 8.4% |
PKO Bank Polski increases the education opportunities for young people, offering students and doctoral students preferential student loans with low interest rates. The bank offers forgiveness of a part of the loan for the best graduates.
At the end of 2019, the value of preferential student loans was PLN 648 million.
Since the beginning of its existence, the bank has been teaching Poles how to save. In 2019, the bank effectively responded to the needs of customers looking for valuable capital investment options, including:
The bank conducts consistent and multi-level financial education addressed to various customer groups. Its main goal is to reduce financial exclusion, build consumer awareness and act in the field of cybersecurity.
PKO Bank Polski actively increases the availability of its services to customers with special needs. It also initiates and jointly creates activities of other entities of the Polish financial sector intended to counteract exclusion from access to financial services.
The bank is continuously improving the standard of customer service, including the services for customers with disabilities. The bank’s policy in this area has been defined separately for the bank and for the Group entities.
The main areas of the bank’s activities encompassed by the policy with respect to persons with disabilities are:
The Group’s branches satisfy all the norms specified in the regulations regarding the adaptation of buildings to the needs of persons with disabilities. Additionally, the principles for choosing locations of the bank’s branches and arranging them in a manner that is friendly to persons with disabilities are set out in the internal regulations of the bank. The most important of these are:
– location along a main pedestrian route;
– availability of parking spaces.
By the end of 2019, 755 branches (i.e. 72% of the total number) had been adapted to the needs of persons with disabilities in accordance with the bank’s internal regulations.
New Format of Branches
A standard of the New Format of Branches (NFB) was updated in 2019, in which solutions and technologies were used to help serve customers at the branch, develop self-service channels and digitize sales processes. The NFB will also encompass the bank’s agencies, Brokerage Offices, ROD and ROK. This format takes into account the recommendations of the Integration Foundation, which at the bank’s request audited the space available for customers. The conclusions from the audit, including those regarding persons with disabilities, are taken into account at new sites for branches, as well as at the branches that are being relocated and modernized.
Dedicated rooms in the branches
The bank also provides the possibility of individual services adapted to the type and degree of a customer’s disability and if required, offers services in a dedicated, comfortable and safe room.
Providing services to persons with hearing impairments and deaf
The bank is also constantly raising the standard of service for the deaf and persons with hearing impairment using Polish Sign Language. In 2019, the possibility of using a free-of-charge online sign language interpreter was implemented (on smartphones in all branches and locations). All advisers have been trained to provide professional services to deaf customers. They received e-training and were acquainted with the principles and good practices applicable in the bank’s internal communication.
At the same time, a social media campaign was conducted with the aim of increasing the awareness of (prospective) customers about the bank’s activities aimed at breaking barriers and reducing social exclusion.
In 2019, the bank participated in a joint initiative of the Polish banking circles realized by the Polish Bank Association with support from the Polish Association of the Deaf on updating and expanding the generally available glossary of terms of banking products and services in Polish Sign Language. The glossary was published on the Internet in the fourth quarter.
Providing services to the blind and visually impaired
The bank also makes it easier for blind and visually impaired customers to use financial services – the number of ATMs with a panel equipped with the Braille alphabet and an audio module is steadily increasing. At the end of 2019, of 3 058 ATMs, 2 191 (72%) were equipped with audio modules. Information on the location of such devices can be found on the Bank’s website and in the Dostępny Bankomat [Available ATM] interbank service.
Fingerprint signature
The bank makes it possible for people who are unable to sign documents on their own because of their disability to take advantage of a fingerprint option.
Electronic Authorization by a Text Message
The bank is developing a system of Electronic Authorization by Text Message in the entire network of the bank’s branches, which enables authorizations of declarations of intent without a hand-written signature, by typing a code sent by the bank in the form of a text message. At present, more than 20 types of orders can be authorized with a text message.
In addition, the bank is testing the possibility of signing an order on an electronic pad and receiving a document copy by e-mail. This project will be developed in the current year.
The IKO application, telephone service and electronic banking have been designed and are developed with account taken of the needs of persons with disabilities.
In 2019, the bank took part in the STOP Barierom [STOP Barriers] social campaign coordinated by the Neuron Plus foundation, whose aim is to support the availability of public and commercial services in a broad sense to persons with disabilities. At the same time, branches and regional offices organized educational meetings for persons with disabilities aimed at improving their knowledge of the banking world and personal finance management.
In addition, in 2019:
The bank’s employees actively participate in the works of the interbank Group for serving persons with disabilities at the Polish Bank Association. For example, they took part in the preparation of interpretation guidelines for the banking sector for the “Act on providing accessibility for persons with special needs” prepared as part of the “Dostępność plus” [Accessibility plus] government project.
The bank’s Group entities, including the bank, affect the local communities through:
The bank’s Group is an important employer, because it provides jobs for 28 000 people. The bank as such employs 23 700 persons, of whom more than half work in branches dispersed throughout Poland. By offering a salary level exceeding the national average, these jobs have a positive impact on the income levels of local communities.
The bank and other entities of the bank’s Group form standards in the relations between employees and the employer, as well as between employees, through their organizational culture and the pursuit of employment policies.
By its social activity described below, which includes organizing charity events and sports events, the bank activates the local community and strengthens interpersonal relationships.
BANK’S GROUP | BANK | |||||
---|---|---|---|---|---|---|
2017 | 2018 | 2019 | 2017 | 2018 | 2019 | |
Central taxes, including | 2 929 | 3 403 | 3 477 | 2 586 | 2 924 | 2 978 |
Corporate income tax | 1 264 | 1 611 | 1 525 | 1 080 | 1 343 | 1 339 |
Tax on certain financial situations | 932 | 950 | 1 022 | 894 | 883 | 931 |
Personal income tax | 301 | 310 | 316 | 269 | 277 | 281 |
Flat-rate personal income tax | 248 | 326 | 371 | 243 | 323 | 366 |
Flat-rate corporate income tax | 76 | 77 | 29 | 75 | 77 | 28 |
Tax on goods and services (VAT) | 109 | 129 | 214 | 25 | 22 | 33 |
Local taxes, including: | 86 | 66 | 91 | 21 | 21 | 20 |
Tax on vehicles | 40 | 23 | 55 | 0 | 0 | 0 |
real estate tax | 33 | 30 | 24 | 15 | 14 | 13 |
Fee for perpetual usurfuct | 9 | 10 | 9 | 6 | 6 | 6 |
Other taxes and fees | 4 | 3 | 3 | 1 | 1 | 1 |
Total taxes: | 3 015 | 3 469 | 3 568 | 2 607 | 2 945 | 2 998 |
As part of their operations, the Bank and other entities of the Bank’s Group support the state budget and local budgets. According to data published by the Ministry of Finance, PKO Bank Polski was the biggest CIT payer in Poland in 2018. For the year 2019, the amount of taxes of entities of the Bank’s Group operating in Poland totalled PLN 3 568 million, of which PLN 3 477 million were central taxes and PLN 91 million were local taxes. The Bank’s subsidiaries paid UAH 314 million of central taxes to the Ukrainian budget and UAH 105 million in respect of local taxes.
Additionally, in 2019 a dividend was paid for the year 2018 in the amount of PLN 1 662,5 million to the shareholders, including the state budget and the portfolios of Open Pension Funds.
Involvement of the bank in pro-social activities
[GRI 102-12] For many years, the bank has been initiating and implementing social projects combining business objectives with initiatives for all stakeholder groups. In accordance with the slogan of the current Strategy, the bank develops relations with the community, actively performing activities for and with the community. It supports educational, civic, cultural and sports events and projects. The bank is a socially responsible institution for which freedom and attachment to tradition are natural values. Therefore, it conducts activities that consolidate awareness and national identity, supporting the development of national heritage and popularizing the ideas of modern patriotism. The bank implements this mission, among other things, through sponsorship and patronage of institutions and events.
Both the bank, as a part of its sponsoring activities, and Fundacja PKO Banku Polskiego (the Foundation), as a part of its charity activities, verify every partner and beneficiary of the support provided. No negative impact on the bank’s image was identified in 2019 in these areas. Care for the rationality of the sponsorship and charity policies pursued is achieved through the synergy of activities. In the Foundation, the Programme Council consisting of representatives of the bank takes care of this. The bank and the Foundation implement projects jointly or separately in the most important programme areas in terms of image, such as culture, tradition, education and sport. Furthermore, the Foundation performs activities, the objectives of which are social welfare, protection of life and health and ecology. On the one hand, such a division of commitment to programme areas strengthens the bank’s image-related benefits, while on the other, it broadens their range.
Objectives
The sponsorship activities of the bank are aimed at promoting the bank’s image as a reliable financial institution, socially involved, modern and open to its customers’ needs. Another objective of sponsorship activities is to present the bank as a financial market leader setting new trends and development directions for other institutions with the same profile.
An important aspect of the bank’s sponsorship activities is its commitment to projects inspired by history, promoting patriotic attitudes and the cultural heritage of our country. The bank joins in and supports cultural events, such as exhibitions and concerts organized for anniversaries of important historical events or commemorating the achievements and attitudes of outstanding Poles. In 2019 the bank celebrated its 100th anniversary, which was communicated during some of the official events and in media releases associated with projects.
The bank implements sponsorship projects at both the national and local level and focuses on the following areas:
Principles of sponsorship policy
The bank’s sponsorship policy is governed by specific principles and a several-stage process of reviewing and accepting offers that are submitted. An important stage is its expert assessment, made on the basis of the following parameters:
Offers that are accepted are sent to the Sponsorship Committee, which guarantees that the proposals under consideration will be considered with due regard to the facts and comprehensively.
In 2019, the bank received 888 new applications, of which 270 were accepted. Overall, 317 sponsorship projects obtained financial support in 2019 (in addition to 270 new projects, 47 projects initiated in the previous years were continued).
Examples of support in the most important areas
The bank supported 37 running events throughout Poland in 2019 as part of the “PKO Bank Polski. Let’s Run Together” programme. The following should be noted in particular: PKO Bieg Niepodległości (the Independence Run) in Warsaw, PKO Bieg Powstania Warszawskiego (the Warsaw Uprising Run), PKO Bieg Konstytucji 3 Maja (the Constitution of 3 May 1791 Run) in Warsaw, PKO Białystok Półmaraton (the Białystok Half Marathon), PKO Bydgoski Festiwal Biegowy (the Bydgoszcz Running Festival), PKO Nocny Wrocław Półmaraton (the Wrocław Night Half Marathon), PKO Poznań Półmaraton (the Poznań Half Marathon), PKO Półmaraton Rzeszów (the Rzeszów Half Marathon), and the runs in the PKO Grand Prix Gdynia series. As part of the “Let’s Run Together” programme, free of charge running training as part of the “BiegamBoLubię” [IRunBecauseILikeTo] campaign are organized at nearly 100 athletic stadiums throughout Poland. The activities are managed by professional trainers and they are open to all those who want to ensure their good physical condition and well-being. Apart from the running events, the bank also supported other prestigious sports events, such as Cavaliada – a series of International Show Jumping Contests and the Sail Szczecin Days of the Sea 2019. PKO Bank Polski is the main partner of the Polish Extra League (Ekstraklasa). As part of this cooperation, a number of initiatives were taken, including social media channels, cooperation with the “Magazyn GOL” TV programme, player escorts for matches and a number of contests. By engaging in long-term cooperation with Ekstraklasa, the bank wants to contribute actively to development of the league and young football talents in Poland. One of the events that support this objective is the election of the PKO Bank Polski Young Player of the Month, i.e. the best Polish football player under the age of 21. At the beginning of the year, Official Ekstraklasa Cards – the images of payment cards with various football clubs – were presented. It is the only such product on the market, which was very well received by the customers and the media. The cards provide a number of benefits for football fans, e.g. their holders may win invitations to matches of their favourite teams (also to the special Fan’s Couch located near the sideline). In the second half of 2019, the bank launched the Partnership Programme for the Ekstraklasa clubs – a project aimed at supporting development and innovation in sports marketing. This new initiative will allow the clubs to obtain significant extra funds from the promotion of bank products among their fans. It is the first project in the history of Polish football, which may so significantly improve the financial stability of football clubs.
Support for the Polish National Foundation (PFN)
The bank is one of the founders of the Polish National Foundation (PFN), the mission of which is to “promote our successes in science, extensive culture, wonderful history and unique nature”. According to the PFN’s by-laws, each of the founders was obliged to make contributions to the Foundation’s founding fund and make annual payments towards the organization’s activities for 10 years (starting from 2017).
Principles and objectives of the charity activities
The Foundation substantively and financially supports projects of importance to the development of Poland, implemented for and in consultation with the local communities, serving the purpose of building civic society.
The scope of the Foundation’s activities is specified in the Foundation’s By-laws, while the principles of cooperation between the bank and the Foundation are governed by the agreement Grants awarded by the bank based on the resolutions of the Management Board constituted the main source of financing of the Foundation’s statutory objectives in 2019. Additionally, the bank transfers to the Foundation a part of the profit generated on noncash transactions concluded with charity cards Inteligo Visa payWave “Dobro procentuje” [Good pays interest](130 000 customers of the bank hold such cards). The support is designated to one of the four charity initiatives, selected by the customer.
Programme areas
In 2019, the Foundation received 1 114 applications for granting monetary donations for social activities. 592 projects were approved. 86 applications remained to be considered in 2020. The donation is transferred under a donation agreement concluded and between the Foundation and the project partner.
The Foundation also transfers donations in kind to non-governmental organizations, in the form of IT hardware and furniture withdrawn from use from various banking units. In 2019, furniture was donated to 60 organizations.
Examples of support in the most important areas
Own projects
The Foundation also implements its own projects, including:
The bank (within the scope of sponsorship activities) and the Foundation (within the scope of activities for public benefit) conduct pro-social activities on behalf of the remaining entities from the bank’s Group.
Moreover, in 2019, some of the subsidiaries carried out a dozen or so projects on their own initiative, which were addressed to local communities.
KREDOBANK conducts its own pro-social activities focusing on the following objectives:
In 2019, KREDOBANK was also involved in projects initiated by its employees, including:
The Foundation encourages the employees of all the Group’s entities to become involved in work for local communities. The involvement of the employees in charity activities is steadily increasing (1 583 registered volunteers at the end of 2019, i.e. 141 more than a year before). Volunteers not only join the projects initiated by the Foundation, but often initiate them themselves.
On 3-4 December 2019, gifts were collected for the residents of Homes for Single Mothers from all parts of Poland (“Let’s not wait – help”). The residents received food with long use by dates, cleaning products and cosmetics, new clothes for children, toys and books. It was reported to the Foundation that the employees of more than 80 units from all parts of Poland participated in Christmas charity events and provided aid to 26 institutions.
The Aid for a Start project (financed from funds raised during the PKO Bank Polski charity campaign “Pomaganie przez zbliżanie” [Helping by getting close] aimed at supporting the process of gaining independence by and providing equal chances to persons brought up in children’s homes, institutions and foster care) was conducted with the participation of 52 volunteers from all parts of Poland, who identified the needs and selected the persons who would receive support, at the same time helping them complete formalities and properly account for the aid received. As a result of the work of the volunteers, 128 persons received support in the process of starting an independent adult life.
Since 2017, the Foundation’s own project “Busola na start” [Compass for a start] has been in operation. Due to the need to provide systemic aid to foster care wards in the process of their professional stimulation, the bank offers them the possibility of apprenticeship/internship with an opportunity to obtain long-term employment. The professional guardians (the bank’s employees) not only care for the professional development of the young people but are also their guardians/mentors in the process of gaining practical life skills. Each of the guardians is also a volunteer.
The bank did not record any significant receipts from State aid in 2019. The bank and two subsidiaries were granted property tax relief totalling PLN 188 000.* In the majority of cases, the final beneficiary of this aid was the lessee of the real estate to which the relief was related.
*The information does not cover receipts between the bank’s Group entities.
In 2019, three subsidiaries obtained revenues from the sale of products and services to public entities as part of the public procurement scheme amounting to PLN 7.5 million.
For many years, the bank has been financing and providing banking services to public entities, including:
The bank is also a member of Fundacja Polska Bezgotowkowa [Cashless Poland Foundation], which promotes the development of non-cash payments.
The bank maintains the position of a leader on the market of servicing the public sector: it services the budgets of 9 voivodships and 9 voivodship cities The share of loans provided to local authority units as at the end of 2019 was 16.5%.
Public sector customers appreciate the long and extensive experience of PKO Bank Polski in the cooperation with public sector customers, its wide distribution network, comprehensive offer of cash management products, and the latest technological solutions offered by the bank, which are adapted to the changing market environment and guarantee the safety of deposits. In connection with the amendment to the Act of 22 March 2018 on court bailiffs, which entered into force on 1 January 2019, a special type of account addressed to this group of customers and satisfying the requirements of the Act was added to the bank’s offer.
The agreements concluded by the bank with public sector customers in 2019 include:
In February 2019, PKO Bank Polski with a consortium of foreign banks arranged and placed on the euro market the third and fourth issues of the Polish green treasury bonds (green bonds). The consortium of banks with the participation of PKO Bank Polski sold 10-year and 30-year green bonds with a total value of EUR 2 billion. 10-year bonds were sold for EUR 1.5 billion with a yield of 1.057% (i.e. 35 bp above the mid swap rate), and 30-year bonds were sold for EUR 500 million with a yield of 2.071% (77 bp above mid swap). More than 200 investors took part in the transaction.
It should be noted that PKO Bank Polski also participated in the previous two issues of green bonds, including the first ever issue of the Polish treasury green bonds (in 2016), which was also the first such transaction in the world.
Green bonds are debt instruments used for raising funds for the financing of investments aimed at mitigating the adverse effect of human activity on the natural environment. The range of products financed is very wide: from transport infrastructure through energy efficient construction and renewable energy sources to waste management.
Operational risk related to outsourcing banking activities to external entities
The bank conducts banking activities with the support of external entities as a result of which it is exposed to operational risk arising from outsourcing services to other entities.
In accordance with the bank’s internal regulations regarding operational risk management, contracting for the performance of activities for the bank to external entities other than agents and intermediaries (outsourcing), cooperation with agents, brokers and online brokers, risk management related to outsourcing activities to external entities at the bank applies to all stages of outsourcing, starting from planning the outsourcing of activities, through the selection of the entity that will perform the activities, the conclusion of the outsourcing contract, monitoring cooperation and ending the cooperation.
As part of the operational risk management related to outsourcing services to external entities, the bank, in particular:
Operational risk management related to outsourcing services to external entities in the bank’s Group also takes place at PKO Bank Hipoteczny, which applies the bank’s best practice in outsourcing-related operational risk management, as the bank’s wholly owned subsidiary. The procedures implemented at PKO Bank Hipoteczny correspond to the standards applied at the bank.
Cooperation of KREDOBANK with agents and partners has been regulated in the internal regulations of KREDOBANK. Establishing cooperation with external entities to entrust to them the performance of activities on behalf of KREDOBANK is preceded by conducting an assessment of risk related to entrusting these activities.
The task of the bank’s Procurement Department is to punctually supply the materials and services needed of the required quality. In addition to the bank’s interest in a broad sense, the Procurement Department oversees the compliance of the procurement processes at the bank with the principles of ethics, including the principle of treating all participants equally. When selecting suppliers, the bank also takes into account certain criteria other than the price, including compliance with business ethics, aiming towards transparent relationships with suppliers. The procurement policy is developed based on best market practice. The main regulatory provisions are the Principles and Procedures of purchasing goods and services at the bank.
Relations with suppliers are built on the basis of honesty, transparency of action, mutual respect and professionalism, including, in particular, through:
Payment terms in contracts with suppliers vary according to the supplier’s standard contracts and individual arrangements. The standard term at the bank is 30 days (more than half of the analysed contracts), but, in many cases, the term is shorter (usually 14 days). In the bank’s Group, the payment terms are shorter which is due to the subsidiaries: 14-day payment terms are prevalent (60% of contracts) and a large percentage of payment terms are regulated in individual contracts with suppliers, depending on the type of contract and the company’s policy.
The bank and the other entities from the bank’s Group approach the issue of settling their liabilities to suppliers in a timely manner with due care and diligence. In 2019, as in the previous year, the value of invoices paid late, on which default interest was charged, constituted a marginal percentage of all the invoices paid and it decreased significantly in the entire bank’s Group. The list does not include payments, a possible delay in which was agreed with the supplier, because the collection of this information would be excessively laborious.
GROUP | BANK | |||||
---|---|---|---|---|---|---|
2017 | 2018 | 2019 | 2017 | 2018 | 2019 | |
Share in total value of invoices (%) | 0.024 | 0.114 | 1.053 | 0.001 | 0.039 | 0.003 |
Suppliers who are interested in starting cooperation with the bank may register at the ‘PKO Zakupy’ procurement platform on their own. Every such supplier must be approved by an employee of the Procurement Department. The suppliers who have been approved may take part in procurement proceedings.
The impact on suppliers regarding socio-environmental issues takes place at the stage of each enquiry sent by the bank or any of the other entities of the bank’s Group. In accordance with its wording, when joining the procurement procedure, the suppliers must declare that they are guided by the overriding principle of respecting the law across the supply chain, a sense of justice and social responsibility and they understand the influence exerted by their activities on the natural environment, their surroundings, the other party, their employees, co-workers, subcontractors and business partners, and they are guided by ethical principles.
A later part of the statement contains detailed declarations regarding:
Suppliers receive a survey from the bank once a year, which provides valuable information on the procurement process. The survey results and the comments collected are consolidated in an anonymous form, aggregated and analysed. The survey allows the bank to review its procurement policies regularly in order to improve the process of procurement of goods and services.
In 2019, the bank conducted the procedure of renewal of its CIPS (Chartered Institute of Procurement and Supply) certificate obtained in 2016, which confirms that the organization has implemented the highest procurement standards. The CIPS Corporate Certification is globally recognized confirmation that an organization has achieved the highest global quality in the area of procurement. It also certifies its compliance with the principles of ethics and global trends in Corporate Social Responsibility (CSR). Therefore, the Certificate is proof that PKO Bank Polski is a reliable and solid business partner for its customers and Suppliers and that it strives to continuously improve its operating processes. PKO Bank Polski is the first financial institution in Poland to obtain this prestigious certificate.
[GRI 414-1] In 2019, all new suppliers (417) were verified in terms of social criteria.
[GRI 414-2] No negative social impact was noted in the supply chain.