Anti-corruption

The elimination of breaches in this area is also expedited by appropriate provisions of internal acts of individual Group companies, such as the rules for awarding contracts (they include a requirement that persons performing activities in a procedure or who may influence its outcome or persons awarding contracts, in particular persons acting as managers of the contracting entity, members of the tender committee and experts, submit statements confirming the absence of any relations on their part with contractors participating in the tenders) or the work regulations.

An extremely significant component of the anti-corruption system is the building of a proper organizational culture within the Group, which is performed primarily by the ENEA S.A. Compliance Office. This objective is pursued, among other measures, through e-learning training for employees, promoting ethical and lawful behaviors, and through information campaigns aimed at continuous development of knowledge and awareness of employees regarding compliancewith legal and market requirements, but also with moral standards. The Compliance Office actively participates in drafting internal regulations and issuing opinions on them from the Compliance perspective, cooperates with the individuals involved in this area in ENEA Group companies and identifies and assesses potential risks of non-compliance, corruption and conflict of interest.

In 2022, the ENEA S.A. Compliance Office and the ENEA Group Compliance Officer, in their effort to continuously raise employee awareness of zero tolerance of any signs of corruption, created an information campaign in cooperation with the Department for Corporate Communication and Relations with the Socio-Economic Environment of the Group and an external advertising agency. As part of the campaign, the “Team of high principles #EneaJestFair” was established as a component of the educational campaign under the slogan “It is worth being fair, we all benefit from that!” The goal of the campaign is to promote good business practices, raise awareness of corruption prevention and build an organizational culture based on fairness. For the purpose of the campaign, the www.enea.pl/jestem-fair website was developed to inform about anti-corruption activities and regulations applicable at the ENEA Group as well as instructions for reporting potential violations. An animated movie with guidance on how to behave in corruptive situations was also created. Additionally, the topic of counteracting corruption was discussed in ENEA News.

Furthermore, the ENEA Group launched a new cycle of e-learning training dedicated, among others, to counteracting corruption; the training is mandatory for all employees. Moreover, all Members of the ENEA S.A. Management Board have completed anti-corruption training.

Effective as of 1 January 2022, ENEA Bioenergia employees took over the scheduling of deliveries of biomass and other additives used in the electricity generation process at the entrance gates to the Połaniec Power Plant. The exclusion of an external entity, i.e. a security company, from the delivery process, improved the control of suppliers.

ENEA Operator has implemented in its procurement process the obligation for individuals involved in the preparation of public procurement procedures and the contracting manager to submit declarations that they have not been convicted of a crime in connection with the preparation of public procurement procedures and the absence of conflicts of interest in connection with the preparation of the description of the subject matter of the contract, the estimation of the subject matter of the contract and the preparation of the list of contractors invited to participate in the procedure.