Anti-corruption

The methods of preventing corruption in the Enea Group have been detailed in more technical regulations, such as:

• The Rules for Offering and Receiving Gifts in the ENEA Group which contain detailed guidelines and restrictions on offering and receiving gifts, including the nature of the gifts, value thresholds, relevant approvals and the extremely important idea of ’own judgment’ which covers a list of questions an Employee should answer before accepting or offering a gift, so as to determine whether or not it is appropriate (even if permitted by law).
• The Policy for reporting breaches and protecting whistleblowers in the ENEA Group which comprehensively regulates the matters associated with reporting suspected violations, including corruption. The main purpose of the policy is to ensure that signals of possible violations are received, thoroughly analysed and properly managed, and that the person who reports them in good faith is protected from possible retaliation.
• The Anti-corruption Policy of Lubelski Węgiel Bogdanka S.A. which sets out legal and ethical standards allowing for conducting business in a responsible and transparent manner. Counteracting corruption is also an important element of documents such as: the Code of Ethics of Lubelski Węgiel Bogdanka Capital Group, Procedure for Reporting Breaches in Lubelski Węgiel “Bogdanka” S.A., Guidelines on Offering and Receiving Gifts at Lubelski Węgiel “Bogdanka” S.A. and Compliance Policy of Lubelski Węgiel “Bogdanka” S.A.

Detailed provisions contained in internal regulations adopted by individual Group’s companies (e.g. procurement regulations and work regulations) also aim to reduce the risk of malpractice.

Reconstruction and update of the tab dedicated to Compliance issues on the Enea Group’s intranet – four thematic modules have been created:

• a Compliance knowledge base designed to serve as a source of information about corruption, conflict of interest and fair competition; it also contains guidelines on how to proceed if you believe that a breach has occurred;
• Compliance regulations, i.e. a set of internal compliance-related regulations, e.g. ENEA Group rules for accepting and offering gifts;
• information about campaigns and training courses conducted by the Compliance Office (e.g. the #EneaJestFair campaign) as well as e-learning training programmes and useful links;
• information on organisational units within the Enea Group and links: to the Enea Group Breach Reporting Form and the form used when reporting gift acceptance or offering.

In 2023, Enea Operator updated the Rules for ENEA Operator sp. z o.o. awarding contracts which are applicable to contracts co-financed by the European Union. The modifications concerned, among others, the provisions on percentage thresholds in line with the Compliance Policy. Moreover, an appendix (containing the statement to confirm lack of conflict of interest in sales of assets in a tendering procedure) was added to the Rules for disposal of redundant assets at ENEA Operator.

In 2023, the LWB Group introduced the Anti-Corruption Policy and Conflict of Interest Management Policy. In addition, LWB Group updated the ethics regulations binding in LWB and in the LWB Group – the Code of Ethics of the Lubelski Węgiel Bogdanka Capital Group came into force in December that year. Furthermore, LWB follows the Compliance Policy of Lubelski Węgiel “Bogdanka S.A.” and Procedure for Reporting Breaches in Lubelski Węgiel “Bogdanka S.A.”.

MR BOGDANKA introduced the Anticorruption Policy of MR BOGDANKA sp. z o.o. The document regulates, inter alia, the company’s approach to corruption and conflict of interest, prohibits offers and requests of material or personal benefits or their promises in connection with the performance of professional duties, and prescribes that, in dealings with business partners, care must be taken to ensure that relationships are fair and transparent, and that they remain formal.

RG Bogdanka adopted the Anti-Corruption Policy of RG Bogdanka sp. z o.o. so as to establish uniform rules on handling identified cases of fraud, prevent and counteract corrupt activities carried out to the detriment of RG Bogdanka as well as activities incompatible with the principles of conducting business ethically and in Compliance with the principles of fair competition. The Policy also aims to ensure transparency of the company’s actions towards its business partners. RG Bogdanka applies anti-corruption clauses in contracts to which RG Bogdanka is a party.

Enea Innowacje implemented a number of new processes and policies. The company is part of the ENEA Group Compliance System and must comply with its requirements – one of these is to train all Employees on the application of the ENEA Group Compliance Policy and the Rules for Offering and Receiving Gifts at ENEA Group. In addition, the company appointed a person responsible for reporting, implementing recommendations and maintaining regular contact with the Compliance Management and Legal Services Division of the Enea Group.

Enea Pomiary supplemented the Contracting Rules for ENEA Pomiary sp. z o.o. with a provision requiring that contracts should include a clause referring to the ENEA Group Code of Conduct for Contractors, in which the contractor declares that it has familiarised itself with the Code and undertakes to abide by it.

In 2023, proceedings were still pending in Enea Logistyka regarding the acceptance of financial benefits by a company’s Employee¹⁾. Enea Operator commissioned an external law firm to conduct an ownership audit in Enea Logistyka with regard to the irregularities investigated. No corruption incidents were reported in other companies of the Enea Group.

¹⁾ In 2022, only completed proceedings were reported

Percentage of the members of management bodies and Employees of selected Enea Group’s companies who were informed about the anti-corruption policy and procedures, and who took part in anti-corruption training.

¹⁾ Exclusive of RES special purpose vehicles.
²⁾ The difference between the total number of the company’s Employees and the number of the company’s Employees employed as at 31 December 2023 who took anti-corruption training is due to the fact that one person was simultaneously employed by another Group company (in each of these companies on a 1/2-time basis) and took all mandatory training there.