Responsible management principles


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

  • professionalism, which means active provision of quality services through continuous enhancement of competencies;
  • commitment, which means taking initiative to work for the Bank and its partners;
  • partnership cooperation, which means taking action to achieve a common objective based on mutual understanding and respect.

In 2021, three more values were added to complement and strengthen the direction set by the Bank’s Management Board:

  • 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.

In 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 at the Bank, which still provides for these issues, but the rules of accepting and giving gifts and managing conflicts of interest have been addressed in detail in the relevant Policies. Also, 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. An ethical awareness survey for employees and a number of activities promoting ethical issues (e.g. publication of expert texts) are carried out each year. Ethics is also included in the onboarding training of new employees.

In 2020, no legal action was taken against BGK for anti-competitive behaviour or monopoly practices.

Prevention of conflicts of interest

In accordance with the Code of Ethics applicable in 2020, a conflict of interest was defined as a situation where an employee has the option to make a decision or act on behalf of the Bank in a way that will or may be beneficial to them or their related persons, also where the interest of an employee 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.

As of 2021 the Code of Ethics has been amended and a separate Conflict of Interest Management Policy has entered into force, which extends the existing provisions of the Code of Ethics on the issues related to conflicts of interest. BGK also operates a Gift Policy.

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

Reporting breaches

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:

through an anonymous channel
in person
by phone
by submitting a notification to the Employee Relations Manager (helpline);
in writing
on paper or in electronic form.

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.

In 2020, one notification of mobbing and discrimination was recorded – following the investigation, it was considered as unsubstantiated.

Ant-Corruption policy

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

Any form of corrupt practices and misconduct, in particular 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, in particular 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.

A Protective Action Office at the Security Department cooperates with law enforcement authorities and state security services.

No corruption incidents were found in 2020. However, an employee of the Bank was subject to one corruption attempt, which was handled immaculately: the BGK employee immediately reported it to superiors, as a result of which the Security Department prepared a notification to the prosecutor’s office of suspected crime committed by a person who made an unsuccessful attempt to corrupt an employee of BGK.

Organisation of the risk management process

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, control, monitoring 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 includes 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 control, 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 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 reporting, which comprises provision of information on the risk profile, identification of possible threats, and provision of information on the measures adopted.

As an important element of the risk management system, an internal audit function is in place that reports directly to the President of the Management Board, in accordance with the Articles of Association of the Bank. Its task is to investigate and evaluate, independently and objectively, the adequacy and effectiveness of the risk management and internal control system. In compliance with external requirements and best practices, all the operations of BGK are subject to audit. The internal audit function at BGK follows the IIA’s International Standards for the Professional Practice of Internal Auditing, which is confirmed by regular independent external reviews. In line with regulatory requirements, the Bank has mechanisms in place which guarantee independence of the internal audit function, including but not limited to supervision of the internal audit function by the Supervisory Board, approval of the appointment of the internal audit head by the Supervisory Board, approval of the function’s plans and reports by the Supervisory Board as well as direct communication between the internal audit head and the Chairman of the Audit Committee.

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.

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 so-called 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. To that end, a separate project has been set up.

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 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.
  • The Business Model Programmes include preliminary allocation that takes into account the ESG aspect in setting KPI targets and indicators.
  • Pilot comprehensive ESG stress tests were carried out. 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 2021.
  • The procurement process includes the option of providing a CSR statement, for which companies participating in the procurement procedure may receive additional points.
  • Websites of supervisory authorities and regulators are monitored on an ongoing basis for issues related to sustainable development.
  • Issues related to ESG factors are taken into account in the Bank’s current reporting. Publication in 2020 of current reports on the impact of the COVID-19 pandemic on the Bank’s operations and financial standing.
  • The Code of Ethics applicable at BGK takes into account elements related to sustainable development.

The Bank monitors the regulatory environment regarding ESG on an ongoing basis and undertakes adjustment measures to meet the guidelines of the European Banking Authority.

Further work is scheduled for 2021 to analyse, and for 2022 to implement the ESG risk management process in the Bank’s operations.

Code of Conduct for BGK’s Business Partners

BGK seeks to cooperate with entities that understand and share its values. The Code of Conduct sets out the rules followed by the Bank and which it also expects to be observed by its business partners, counterparties and suppliers.

With this approach to cooperation, BGK wants 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, the Bank improves the quality of the purchased products and services.

The Bank requires that parties to procurement procedures read the Code and the declaration on compliance. If cooperation is established, the Code of Conduct becomes an integral part of the agreement. The Bank also reserves the right to verify the observance of its provisions by partners. In the case of any breach, BGK requires that corrective actions be taken. In the case of a gross breach, the Bank may suspend cooperation or terminate it in accordance with the agreement provisions.

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 and invitations, whistleblowing.

When purchasing advertising materials, BGK prefers those that have appropriate environmental certificates.

In 2021, we plan to prepare guidelines and concepts for sustainable procurement which will account for, inter alia, ESG certificates.