Responsible management principles

BGK has three basic values, by which all employees are guided in their activities. These include:

• openness, which means honest, respectful communication, readiness for change, and courage to seek new solutions;
• teamwork, which means focusing on achieving a common goal thanks to the cooperation of people with diverse competences.
• responsibility, which means acting with full awareness of the consequences of one’s decisions and their impact on the organisation and sustainable socio-economic development of the country.

The Bank conducts all activities in an ethical manner, with a particular emphasis placed on compliance with applicable laws, as well as on the principles of corporate social responsibility and transparency.

Until 2020, the Code of Ethics of BGK was in effect, which in particular covered the gift policy, the policy on management of conflicts of interest, reporting breaches, preventing corruption and fraud, and relationship marketing. In 2021, we adopted a new Code of Ethics of BGK, which continues to refer to issues related to the gift policy, the policy on management of conflicts of interest, reporting breaches, preventing corruption and fraud, and relationship marketing. In addition, issues related to accepting and giving gifts and managing conflicts of interest have been addressed in detail in the relevant Policies. The Code and the Conflict of Interest Management Policy are published on the Bank’s website.

The Code of Ethics applies to all the Bank’s employees, regardless of their job title. In addition, the Bank has internal regulations which provide detailed rules on the breach reporting system.

All BGK’s employees are subject to mandatory annual training in ethics, completed by a test. Initiatives to build a culture of ethics in the organisation are undertaken, e.g. an ethical awareness survey for employees and a number of activities promoting ethical issues (e.g. publication of expert texts) are carried out. Ethics is also included in the onboarding training of new employees.

The Bank also conducted an assessment of compliance with ethical principles in 2021, which took into account, among other things, issues related to gift policy, conflict of interest, diversity policy, work culture, reporting breaches, and social responsibility. The Bank was assessed positively in that area.

In addition, a survey on knowledge of internal regulations regarding ethical issues was conducted among representatives of selected units in the Bank. In their self-assessment, the respondents indicated a very good or good knowledge of these regulations among the employees of a given unit.

In 2021, no legal action was taken against BGK for anti-competitive behaviour or monopoly practices.

In accordance with the Conflict of Interest Management Policy applicable as of 2021, a conflict of interest is defined as a situation where an employee or a member of the Bank’s governing body makes decisions or takes conscious actions on behalf of the Bank in a way that will or may bring a gain (financial or personal) to them – the employee– or their related persons, also where the interest of an employee or a member of the Bank’s governing body affects or may affect their assessment of the situation, decisions made or performance of the entrusted tasks.

If a conflict of interest is identified, the Bank is required to manage the conflict to ensure fair and professional care for the Bank’s interest.

BGK also operates a gift policy which defines standards of conduct that help minimise the risk of conflict of interest related to the acceptance and presentation of gifts.

For new employees, the Bank organises training courses on identifying potential conflicts of interest and how to deal with such situations.

At BGK, a breach means each activity identified by the reporting person as carried out in violation of the applicable law, the Bank’s internal regulations, adopted rules or ethical standards.

Potential and actual breaches may be reported:

Upon the receipt of the notification, an investigation is initiated. The appointed member of the Management Board or the Supervisory Board designates the unit responsible for carrying out the investigation. This can be:

• The Compliance Department – if the breach involves non-compliance with the law and ethical standards (non-compliance incident),
• The Security Department – if the breach involves internal fraud or concerns actual or potential violations of anti-money laundering and terrorist financing regulations,
• The Employee Relations Manager – if the received notification is indicative of potential mobbing or discrimination (the Employee Relations Manager also intervenes when the case is reported directly to him/her).

The investigator is obliged to keep bank secrecy, professional secrecy and business secrecy, to keep confidential and protect the personal data of persons reporting the actual or suspected breach.

Three reports on mobbing or discrimination were recorded in 2021, all of which were found to be unfounded following an investigation.

BGK strives to conduct its business based on fair and ethical principles and does not tolerate any form of corruption or similar malpractice. In particular, it does not accept any actions that violate the impartiality and transparency in the performance of tasks assigned to individual employees.

Any form of corrupt practices and misconduct, most of all fraud, embezzlement, falsification of documents, transactions, reports, records and any other information, as well as making false statements and using the Bank’s assets, including information, for personal purposes, are prohibited.

Corruption prevention is addressed by the provisions of the Code of Ethics, especially the Conflict of Interest Management Policy and the Gift Policy. The Code of Ethics also provides for control mechanisms: appropriate division of duties (functional and technical – the RBAC model was implemented in IT systems), training, information barriers (limitations) and periodic testing (controls).

The Bank also has a whistleblowing process in place, offering different active reporting channels, including one that ensures complete anonymity for the person submitting the notification.

The Security Department cooperates with law enforcement authorities and state security services. No corruption incidents were found in 2021. In addition, in 2021 The Security Department did not receive any reports in this regard.

The risk management system in place at BGK is organised on three independent levels. The first level (first line of defence) comprises the BGK’s operational risk management. The second level (second line of defence) comprises risk management by employees at positions or in organisational units established specifically for that purpose (independent from risk management under the first line of defence) and the compliance function. The third level (third line of defence) comprises operations carried out by the Internal Audit Department.

The internal objective of risk management at BGK is to maintain stability and security of banking operations as well as to maintain a high quality of assets and achieve anticipated financial result within an acceptable risk level.

The risk management is based on:

• risk management strategy at BGK approved by the Supervisory Board of the Bank;
• risk management policies, principles, and procedures related to risk identification, measurement or assessment, monitoring, control and reporting, developed in written form and approved by the Supervisory Board or Management Board of the Bank;
• capital management policy and internal capital assessment at BGK approved by the Supervisory Board of the Bank;
• corporate governance principles, principles of selection, remuneration and monitoring of employees performing crucial functions for the Bank and the policy governing variable remuneration components of persons holding managerial positions endorsed by the Supervisory Board or the Management Board of the Bank.

The risk management system in place at the Bank comprises the following tasks:

• risk identification, which comprises the determination of: risk types, their sources (risk factors), significance and relationships between individual types of risk;
• risk measurement/assessment, which comprises the determination and enforcement of risk quantification methods and stress test performance;
• risk monitoring, which comprises the monitoring of risk levels, review of relevance and accuracy of the applied risk assessment methods and the evaluation of efficiency of the tools used;
• risk control, including risk mitigation, which comprises the determination and enforcement of risk control mechanisms (including a limit system, ensuring independence between first-level risk management and second-level risk management, insurance, risk transfer, financing plans);
• risk reporting, which comprises provision of information on the risk profile, identification of possible threats, and provision of information on the measures adopted.

The composition, scope of activity, and competences of the Bank’s governing bodies and the corporate object of the Bank are defined in the Act on BGK, the Bank’s Articles of Association, and the governing bodies’ rules.

In accordance with the Risk Management Strategy at BGK, the risks identified in the Bank’s operations are subject to risk management procedures. The Strategy also defined the general acceptable level of risk, whereas detailed risk levels in relation to specific material risks have been specified in risk management policies applicable to those risks. Moreover, to facilitate and increase the efficiency of risk management, each organisational unit of the Bank is required to include in its organisational rules information on the types of risks that affect its operations.

With effect from 12 January 2022, changes in the organisational structure in the area of risk management were introduced. The Industry and ESG Risk Division was established, which will be entrusted with the management of one of the strategic areas of the Bank’s development – the ESG risk. The Industry and ESG Risk Division includes the ESG Risk Office, which will prepare guidelines on ESG as well as methods and process of ESG risk assessment, and the Valuation and Financial Modelling Office, which will verify and prepare valuations of financial instruments for the purposes of the Bank’s financial reporting and to confirm the value of collateral.

The existing Office for Operational Risk was transformed into the Operational Risk Department and its scope of activities was extended to include creation and development of an ESG risk disclosure system and adjustment of the Bank’s activities to regulations in that area.

The Management Board of the Bank regularly monitors whether the risk management system matches the risk size and profile and the legal environment.

Through its actions and conduct, the Management Board of the Bank promotes the awareness of the relevance of risk in the activities pursued by BGK, the principles of assuming risk and its management, i.e. the risk culture. Regular initiatives aimed at building the risk culture at BGK include the Risk Culture Week and the Risk Coordinator Academy.

Since 2020, the Bank has been implementing the provisions of CRDV/CRRII (Directive and Regulation of the European Parliament and of the Council (EU) on risk management in financial institutions). For this purpose, a separate project has been established. Implementation work was completed in the fourth quarter of 2021.

Actions regarding ESG risks

• As part of adjustment and implementation work in the field of ESG risk management, a preliminary definition of ESG risk was devised for the purpose of ICAAP (Internal Capital Adequacy Assessment Process) and comprehensive stress tests. The Bank adopted an approach whereby ESG risk is treated as a risk embedded in the Bank’s other material risks. In 2021, the Bank introduced a criterion for assessing the materiality of the ESG risk.
• BGK’s Strategy for 2021–2025 includes the pillars of Sustainable Development and Social Commitment, whose specific provisions account for the ESG dimension. Awareness of sustainable development is built through the Bank’s “Sustainable development” project and participation in the implementation of the “Sustainable development” Pillar of BGK’s Strategy.
• Comprehensive stress tests have been carried out taking into account ESG risk factors. Scenarios were built for the environmental risk, which provided for both physical risk and the transition risk, while in 2021 the approach was extended to cover the additional social and governance risk factors.
• A methodology for identifying ESG risks is planned to be developed in 2022.
• The procurement process includes the option of providing a CSR statement, for which companies participating in the procurement procedure may receive additional points.
• Sustainability guidelines and regulations issued by regulators are monitored on an ongoing basis.
• Issues related to selected ESG factors are taken into account in the Bank’s current reporting. In 2020, the Bank published current reports on the impact of the COVID-19 pandemic on its operations and financial standing.
• The Code of Ethics applicable at BGK takes into account elements related to sustainable development.
• In 2021, an ESG survey was prepared, through which we turn to credit customers with questions about the environmental, social and governance aspects of their activities.

Work related to the analysis of ESG risks was performed in 2021, and in 2022 we will implement the ESG risk management process in the Bank’s operations.

We seek to cooperate with entities that understand and share our values. The Code of Conduct sets out the rules that we follow and which we also expect to be observed by our business partners, counterparties and suppliers.

With this approach to cooperation, we want to build partnership relations, based on professional standards and respect, that are beneficial to all parties. Entities that apply those principles will be perceived as reliable business partners. Responsible and ethical procurement also supports the development of entrepreneurship and contributes to environmental protection. This way, we improve the quality of the purchased products and services.

We expect that parties to procurement procedures read the Code and the declaration on compliance. Contractors that enter the procedure undertake to comply with and apply the Code. We also reserve the right to verify the observance of its provisions by partners. In the case of any breach, we will require that corrective actions be taken. In the case of a gross breach, we may suspend cooperation or terminate it in accordance with the provisions and procedure specified in the agreement.

The Code of Conduct for BGK’s Business Partners contains rules and expectations in the following areas:

• human rights and labour standards, including: observance of occupational health and safety rules, human rights and labour law, non-discrimination;
• environmental protection, including: reduction of adverse environmental impacts, responsible waste management, reduction of greenhouse gas emissions, responsible sourcing and use of raw materials;
• business ethics, including: zero tolerance for fraud and corruption, counteracting money laundering and terrorist financing, protection of confidential information and bank secrecy, fair competition and compliance with antitrust law, prevention of conflicts of interest, timely payment of liabilities, business gifts, whistleblowing.

When purchasing advertising materials, we will prefer those that have appropriate environmental certificates.

In 2022, we plan to prepare guidelines and concepts for sustainable procurement which will account for, inter alia, ESG certificates.