The ORLEN Group Sustainable Development Strategy for 2021–2023 has been integrated with the ORLEN 2030 business strategy and its decarbonisation strategy until 2050. This synergy of activities allows the ORLEN Group to pursue an ambitious business agenda for the next decade, to strengthen its financial performance, and to build long-term value for all stakeholders. The Sustainable Development Strategy also implements the ambitious goals of the Paris Agreement, UN 2030 Agenda and European Green Deal. It is built around three ESG pillars: Environmental, Social and Governance.
Key policies and internal acts
Society
The policies and internal regulations concerning the social area include:
ORLEN Group Code of Ethics – defines the values, principles of conduct and rules that set ethical standards for all ORLEN Group employees, based on a revised approach to understanding ORLEN values: Responsibility, Progress, People, Energy and Dependability, as well as the current scale or operations and operating strategy, the requirements of the Group’s environment, and best practices in the field of business ethics. Moreover, it is a document supporting the implementation of the ORLEN 2030 business strategy.
The Charitable Policy of ORLEN S.A. is a vital element of the Company’s corporate social responsibility and one of the main tools in implementing the ORLEN Group Sustainable Development Strategy for 2021–2023, which has outlined ambitious sustainability and CSR goals, closely aligned with the Group’s business strategy until 2030. ORLEN’s charitable activities are guided by the core values embraced by the ORLEN Group: Responsibility, Progress, People, Energy, Dependability and the principles of conduct outlined in the ORLEN Group Code of Ethics. Charitable Policy of ORLEN S.A. also defines the principles of giving, using and accounting for donations. Charitable support is offered directly by the ORLEN Group and indirectly, through the ORLEN Foundation, the ORLEN Foundation for Pomerania, the PGNiG Ignacy Łukasiewicz Foundation, the ANWIL Foundation, the ORLEN Unipetrol Foundation and the Energa Foundation.
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By pursuing its Charitable Policy of ORLEN S.A., the ORLEN Group demonstrates how it fulfils the role of a responsible corporate citizen and employer, a member of the community and a good neighbour. Behind its declaration of being open to the world, responsive to people’s needs and ready to help, there are concrete actions. ORLEN’s charitable engagement is a response to the needs of its stakeholders, mainly local communities. The nationwide coverage of many initiatives makes it possible to reach areas where help is needed and the Company’s support makes a real change in the life of communities.
The Organisational Standard Regarding the Pursuance of the Charitable Policy by Companies of the ORLEN Capital Group was introduced in 2022 in an effort to capture synergies in Group-wide social initiatives. The standard was developed based on the updated ‘The Charitable Policy of ORLEN S.A.’, approved by the Management Board of ORLEN in September 2022. Since 2021, the ORLEN Group has had in place the Organisational Standard for Supervising Foundations Sponsored or Co-Sponsored by ORLEN or ORLEN Group Companies. The standard is based on the Policy on Supervising Foundations Sponsored by ORLEN or ORLEN Group Companies, approved by the Management Board of ORLEN in December 2020.
ORLEN Standards of Conduct in Relations with Local Communities – the document is a set of guidelines on how to interact with local communities in the areas where ORLEN conducts its business activities. It is intended for internal use and binding on all ORLEN employees.
ORLEN Group Human Rights Policy – the document defines the key course of action, conduct and regulations applicable at the Group, which are directly or indirectly related to the protection of human rights within the organisation and in relations with external stakeholders.
ORLEN Group Procurement Policy – the document aims to support the ORLEN Group’s strategy through management of the procurement categories, building a modern management culture combined with operational excellence, and fostering a sustainable supply chain. One of its strategic goals is the qualification and assessment of suppliers.
Procurement Instruction – implements the Procurement Policy and serves as a tool to achieve its objectives.
Supplier Code of Conduct – defines ethical standards that must be met by the ORLEN Group suppliers. It includes guidance on activities related to counteracting corruption, and promotes high ethical standards in business activities. Every supplier cooperating with the ORLEN Group agrees to abide by the principles set out in the Supplier Code of Conduct, demonstrating its respect for social, environmental, ethical and governance standards. Assessment of a entity’s compliance with the Supplier Code of Conduct is an integral part of the process of selection and periodic evaluation of the ORLEN Group suppliers.
ORLEN Group Anti-Corruption Policy –
a declaration that the Group’s business objectives are to be pursued in a transparent, fair and ethical manner. The policy is designed to raise employee awareness, encourage positive attitudes and behaviours, and streamline procedures and business process oversight.
ORLEN Rules for Accepting and Offering Gifts – define how ORLEN employees should behave
when accepting or giving gifts.
Integrated Management System Policy – being a declaration to assure quality, minimise environmental impacts, ensure employee safety and information security, it is closely related to the ORLEN core values.
Food Safety Policy – declaration of the commitment to ensuring the highest quality of food products and our food and drink service, care for the health and safety of customers as well as for their culinary tastes, by continually developing the Standards and Best Practices in Food and Drink Services in accordance with the HACCP principles.
Employee matters and respect for human rights
- 11.10.1
Management of material topic: employment practices
Key policies
Collective Bargaining Agreements
The Collective Bargaining Agreement is a social contract, being a source of labour law, that has been reached through negotiations between the employer and trade unions. It is an HR constitution of sorts that sanctions a motivating and coherent remuneration and bonus system, sets standards for employer-employee relationships and provides norms governing an equal partnership between the employer and trade unions. The Collective Bargaining Agreement regulates the broad-based labour relations management concept in accordance with applicable laws and best market practices. It is an element of integration and harmonisation of industrial relations, supporting execution of business processes. It serves as an effective and objective tool for regulating HR management policies, with a particular focus on the hiring, promotion and remuneration systems, by applying transparent solutions regarding the pay scale, base pay and bonus system.
The Collective Bargaining Agreement enables effective and open dialogue with social partners by regulating important issues concerning collaboration with trade unions.
With regard to employees’ right to freedom of association and collective bargaining, the ORLEN Collective Bargaining Agreement provides that the employer:
- Recognises the trade unions as representatives of all employees in matters concerning their collective rights and interests, within the scope defined by laws of general application.
- Agrees to respect the freedom of activity and equality of the trade unions and not to discriminate against employees on the grounds of trade union membership or non-membership.
The Collective Bargaining Agreement outlines general rules governing negotiation of annual pay rises, cooperation between the employer and the trade unions in restructuring matters, and negotiation of matters relating to the Agreement.
Work Rules
In 2021-2022, ORLEN Group companies carried out a project to update their Work Rules, comprising key internal regulations that govern the organisation of work processes and the associated rights and obligations of the employer and employees. Based on those regulations, ORLEN implemented an electronic attendance list. The update process made it possible to review the solutions in place, apply a consistent approach, and ensure proper protection for the parties to the employment contract. In connection with planned amendments to the Labour Code, solutions were developed and tested to introduce remote work as one of work organisation options.
Remuneration Policy for Members of Management and Supervisory Boards of ORLEN Group Companies
ORLEN Management Board Members are each year required to implement the management objective of defining and applying rules of remuneration of Members of Management and Supervisory Boards of ORLEN Group companies in accordance with the Act on Remuneration of Persons Managing Certain Companies (known as the Salary Cap Act), which is ensured by day-to- day implementation of and compliance with the Remuneration Policy for Members of Management and Supervisory Boards of ORLEN Group Companies. The document defines the process of making HR decisions as part of corporate supervision, which guarantees that Management Board and Supervisory Board members at the ORLEN Group companies are remunerated in accordance with the provisions of the Act.
As the number of ORLEN Group companies grew significantly in 2022, all of the acquired subsidiaries of ORLEN confirmed the implementation and application of the Policy. In order to maintain a common policy within the Group, compliance with the Salary Cap Act and thus implementation of the Policy is also addressed in the objective setting and reporting system for members of Management Boards of ORLEN Group companies that are parents of other groups.
Restructuring agreement with trade unions
It sets out the rules of cooperation between the social partners in restructuring processes and the employees’ rights in such processes.
Bonus System Rules
The ORLEN Management Board, Management Boards of other ORLEN Group companies, as well as directors reporting directly to the Management Board and ORLEN employees are covered by bonus schemes that support the implementation of strategies and achievement of key business objectives of the ORLEN Group. The key positions are rewarded based on the annual bonus system: the bonus is granted for achieving individual qualitative and quantitative targets, which are reviewed after the end of the year for which they were set. In 2022, other ORLEN employees were rewarded based on one of the following three bonus schemes: a quarterly/annual, quarterly, or monthly scheme. The processes of target setting and reporting and of bonus granting are standardised on an ongoing basis to ensure that the bonuses have an incentive effect.
The concept of the 2022 objective setting process took account of the growing number of ORLEN Group companies, steps towards standardising the regulations and mechanisms for objective setting and reporting at the newly acquired companies, as well as the need to define the objectives on a case- by-case basis. The key components of the Group’s strategy were described in the 2022 MBO Sheets in all ORLEN Group companies, including projects and initiatives related to the completed acquisitions, i.e. the merger with Grupa LOTOS and PGNiG.
ORLEN Group training rules
They govern the provision of employee training. The purpose of training management is to support implementation of the business strategy, assist employees in their development, and build appropriate corporate culture. Each ORLEN Group company creates conditions for its employees to develop their skills, qualifications, knowledge and competencies.
Corporate Social Benefit Activity Rules
– define the scope of social benefits and the rules for granting such benefits to the current and former employees of ORLEN and its subsidiaries covered by agreements on the joint social benefits programme, as well as the employees’ family members. Additionally, ORLEN offers a uniform employee benefits package to employees of all ORLEN Group companies participating in the joint social benefits programme.
Employee Referral Programme
On July 1st 2022, an Employee Referral Programme was launched at ORLEN to support recruitment processes by reaching a select group of candidates through employees. Employees are able to participate in creating the work environment and actively help in recruitment by referring external candidates for new openings. The effective and mutually beneficial referral programme is a new way for ORLEN to access sought-after professionals.
Well-Being Policy
Well-Being Policy – offers key solutions to improve the quality of life and broadly defined employee well-being, and is broken down into several areas: wellness, work comfort, work satisfaction, work-life balance, external environment. Well-being within the organisation means continuous and dynamic management of employee well-being by addressing employee needs in every dimension.
In April 2022, a health and well-being promotion event under the name Wellbeing Week was held at three locations: Płock, Warsaw and Włocławek. Participants were given an opportunity to broaden their knowledge of how to stay healthy, be more physically active and eat well. The Well-Being Policy is a document developed at ORLEN. Also, the ORLEN Group companies received recommendations to implement it and already have in place policies of a similar standard.
Expatriate Policy
The Policy sets out the rules to be followed when seconding employees to foreign ORLEN Group companies with respect to hiring and agreeing on contract terms and benefits for expats at ORLEN and other ORLEN Group companies. Given the ORLEN Group’s fast-paced expansion on international markets, activity of its employees plays a vital part in growing the Group’s business, ensuring knowledge transfer and opening new opportunities for employee development. Employee secondment or employment in a foreign company of the ORLEN Group is consistent with the Group’s strategic plans to continue building human capital with international professional experience.
In 2022, practices applied on the Polish and international markets in the area of secondment of employees to foreign countries were reviewed in order to assess the ORLEN Group’s own practices. The review confirmed their consistency with the market standards. Based on the conclusions contained in the review report, minor updates were made to the ‘Rules for hiring expatriates by ORLEN and other ORLEN Group companies and defining terms of their contracts’, taking into account the need to adapt certain benefits and perquisites to the evolving environment.
ORLEN Group Best Practices in Employee Mobility
Best Practices in Employee Mobility describe the employee mobility process and define the related procedures. The solutions provided in the document are implemented taking into account the specific nature and regulations of individual ORLEN Group companies, each of which is a separate employer within the meaning of the Labour Law. Mobility is aligned with the Group’s strategic plans to build human capital with extensive professional experience in the long term. These Best Practices are adopted and applied by companies newly included in the ORLEN Group. The number of mobile employees varies according to needs: in 2022, it exceeded 30 people.
ORLEN Group Employee Migration Policy
The Policy developed in 2022 defines procedures to be followed by ORLEN Group companies that are employers of personnel migrating within the Group as a result of recruitment, restructuring and/or mobility processes. When an employee of an ORLEN Group company is hired by another ORLEN Group company in connection with any of those processes, all the Group companies should act in accordance with the applicable laws and regulations to effectively leverage the potential of such employees and to achieve synergies.
Each ORLEN Group company is a separate employer and enjoys discretion when making HR decisions, which does not preclude sharing information between Group companies concerning HR guidelines and/or processes, in particular where they are parties to relevant agreements or arrangements defining the scope of mutual cooperation as well as the purpose and scope of sharing information on employees. The Policy ensures smooth operation of business processes within the Group with due respect for the employees’ right to change employers.
Employee onboarding
The purpose of onboarding is to prepare employees to effectively perform their tasks in a new workplace within the shortest possible time frame. The process aims to effectively integrate new hires into the organisation, introduce them to their new tasks and duties and familiarise them with the employer’s procedures and policies. The process also involves integrating new hires into the corporate culture and into their teams. With the need for continuous process improvement in mind, in-house training for employees to be promoted to managerial positions was developed and implemented in 2022. It facilitated adaptation of the internally promoted individuals to their new roles. Besides the usual meetings for new hires, onboarding meetings were held for more than 520 employees of Grupa LOTOS being transferred to ORLEN. The online meeting format, which proved its worth during the pandemic, was again applied, ensuring high attendance by employees based in different locations across Poland.
Family-Friendly Employer programme
Internal order on the Family Friendly Employer Programme and Initiatives celebrating long service, retirement and birthdays of former employees – sets forth the rules for the operation of the Family Friendly Employer programme and governs all activities related to celebrating long service, retirement and birthdays of former employees. It sets out the rules governing initiatives for employees celebrating long service or those retiring, as well as pensioners celebrating their 70th, 75th, 80th, 85th and following birthdays.
Employee Pension Plan
It guarantees additional financial resources to ORLEN employees, to be used once they leave employment and retire. The basic contribution under the scheme is funded by the employer, while the employee has the option to fund an additional contribution.
A pension and savings scheme enabling ORLEN employees to save additional funds for their future pension on favourable market terms.
Employee Capital Plan
It is a long-term retirement savings scheme, with the option to disburse the funds early or after the employee turns 60. Savings in PPK accounts constitute the employee’s fully private and heritable financial capital. PPK contributions originate from three sources: the employee, the employer and the state.
Pay on Request
It is a benefit which gives employees quick and easy access to their salaries before pay day.
Legal Benefit
The service offers access to unlimited legal advice on personal matters provided by email and telephone, including family and civil law, real estate purchases and rentals, as well as consumer complaints, relations with banks and insurers, traffic incidents, contacts with authorities in administrative proceedings, to name just some benefits.
Cafeteria
It is an online platform allowing employees to manage their benefits according to their personal needs. They can redeem points obtained from the employer for a broad range of benefits.
MyCar Programme
The Programme is a car-related benefit offered as an alternative to a company car. It is a monthly cash benefit for the purchase or rental of a private car for business purposes, equivalent to the lease payment for a company car. In addition, MyCar beneficiaries are provided with a shopping card to pay for fuel, non-fuel products and services at ORLEN service stations within a predefined limit.
ORLEN Passion
The scheme has been designed in response to the needs of employees who wish to practice and develop their hobbies and out-of-work passions. Thanks to the Company’s support, employees are offered additional financial or in-kind resources to pursue their activities in sports, arts, culture, science and many other fields.
Master Benefit and Car Platforms
They are car benefits supporting subscription car rentals.
Discount Chocolate
Discounts for products and services of ORLEN’s partner companies, for example computer equipment, PZU insurance products, Apple products, mobile plans, eyeglasses, etc.
Policy for assisting employees during crisis
The purpose of the policy is to provide assistance to employees and their family members going through a personal crisis. In providing support, the employer takes into account the particular occurrence, the type and scale of damage or loss sustained, as well as the personal and financial circumstances of the affected employee and his or her family members. Depending on the above criteria, the employee may be provided with financial, medical, psychological or legal assistance.
Psychological support at the workplace
The purpose of this initiative is to provide psychological support and assistance to employees and their immediate family members in difficult professional or private life situations. The practice is run by the Occupational Psychology Centre operating within the ORLEN structures, which offers immediate assistance in emergencies. After a fatal accident that occurred in the Production Area in September 2022, employees received immediate psychological support, which continued on the following days. A psychological support workshop on how to deal with severe stress was co-organised for staff, with the aim of providing them with additional knowledge helpful in building mental resilience. Lectures were also co-organised for employees and managerial staff teaching them how to take care of their own well-being and the well-being of their subordinates (‘Leader of Well-Being’, ‘How to consciously manage your own energy’). The lectures reflected the organisation’s holistic approach to employees. A total of 81 support conversation were conducted in 2022 with employees of ORLEN, the ORLEN Group and their immediate family members. Psychoeducation activities were also conducted.
The human rights policies and internal regulations include:
Code of Ethics – defines the values, principles of conduct and rules that set ethical standards for all ORLEN Group employees, based on a revised approach to understanding ORLEN values: Responsibility, Progress, People, Energy and Dependability, as well as the current scale or operations and operating strategy, the requirements of the ORLEN Group’s environment, and best practices in the field of business ethics. It contains provisions concerning, inter alia, respect for diversity, including fair treatment of all employees regardless of their age, gender, position, religion, nationality or beliefs, equal opportunities for personal and professional development, as well as responsibility for building an ethical, safe and supportive workplace. It also includes provisions discussing ethical and responsible attitudes towards all stakeholders, including employees, consumers, business partners and local communities. Moreover, it is a document supporting the implementation of the ORLEN 2030 business strategy.
ORLEN Group Human Rights Policy
The Policy outlines the key standards for conduct, behaviour and regulations applicable at the ORLEN Group, which are directly or indirectly related to the protection of human rights within the organisation and in relations with external stakeholders.
ORLEN Group Procurement Policy – the document aims to support the ORLEN Group’s strategy through management of the procurement categories, building a modern management culture combined with operational excellence, and fostering a sustainable supply chain. One of its strategic goals is the qualification and assessment of suppliers.
ORLEN Workplace Bullying, Discrimination and Harassment Prevention Rules
In addition to formal regulations, the Rules encompass measures designed to prevent any conduct that could be considered bullying, discrimination, or other forms of harassment. The initiatives taken to create an engaging work environment and training programmes focusing on managerial responsibilities in preventing workplace bullying, discrimination and harassment that were delivered in 2022 had a positive impact on the Company’s organisational culture. Promoting a work culture based on trust and respect is among the main objectives of its HR strategy.
Conflict of Interest Management Policy
The Policy sets standards to be applied by the ORLEN Group companies in identifying, disclosing and managing conflicts of interest. Its purpose is to reduce the risk of corruption and misconduct in business processes, ensure due care in the activities of the ORLEN Group companies, raise employees awareness of how to avoid conflicts of interest and counteract misconduct, and define rules and standards of conduct for reporting, disclosing and managing conflicts of interest.
Diversity Policy
The Policy aims to promote values, standards and practices that foster equal treatment of employees and create an atmosphere of acceptance. It sets out the objectives and principles that mainly aim to raise awareness and understanding of the importance of diversity and to create an open and tolerant work environment. The Diversity Policy is a document developed at ORLEN. Also, the ORLEN Group companies received recommendations to implement it and already have in place policies of a similar standard.
Policy defining the work conditions and rules for people with disabilities
The objective of the policy is to provide people with disabilities with equal opportunities in the workplace, taking into account the type and degree of disability, enable them to obtain and maintain adequate employment, return to work, receive promotion, as well as support them in independent living and their integration with other employees.
Environment and climate
ORLEN’s internal documents stemming from the implemented systems and decisions of public administration bodies include the following:
Environmental protection
- Environmental Monitoring Procedure – ensuring correct monitoring of air (imissions), wastewater, rainwater and snowmelt produced at fuel terminals, and groundwater on and in the vicinity of the Płock production plant and on the fuel terminal sites, as well as identification and recording of key metrics of the Responsible Care programme relating to environmental protection, health protection, process safety (including safety and distribution of chemicals) and work safety.
- Responsible Care Management Framework – a management system compliant with the guidelines of the European Chemical Industry Council (CEFIC), providing support in the development of management systems implemented at the organisation. Adopted as a result of ORLEN subscribing to the Declaration of Support for the ICCA Responsible Care Global Charter in 2007, it is a continuation of the Responsible Care programme that ORLEN has been implementing since 1997.
- Integrated Permits – decisions issued for the IPPC installations of ORLEN: refining units, petrochemical units, CHP units, CCGT units, wastewater treatment plants on the premises of the Płock production plant and the PTA plant and CCGT unit in Włocławek, specifying operating conditions that must be met for the units to be safe to the natural environment and people.
- CO2 Instruction on the Operation of the ORLEN System for Carbon Dioxide Emission and Activity Level Monitoring and Reporting – defines the rules for timely and reliable entering of data in the IT system for CO2 emissions monitoring, including data on activity levels from each installation covered by free allowance allocations.
- Instruction Specifying the Rules for Calculating and Paying Charges for Air Emissions of Gas and Particulate Matter and Charges for Water Services at ORLEN – a procedure put in place to introduce a uniform calculation methodology, improve the quality of data acquisition, and ensure timely and reliable transfer of data serving as the basis for calculation of the charges.
- Waste Management Procedure – defines activities related to recording, storage, collection and disposal of waste generated in refining, power generation, storage, auxiliary and security processes.
- Instruction Specifying the Rules for Packaging Management at ORLEN – a procedure put in place to ensure compliance with the requirements under the Act on Packaging and Packaging Waste Management and the requirement to report on actual packaging volumes.
- Internal Order on the Rules and Procedures for Managing Expenditures and Provision for Land Remediation and the Procedures for Remediation Projects at ORLEN – specifies rules for the financing and execution of remediation projects on ORLEN sites.
- Instruction on the Operation of the LDAR System at ORLEN – describes implementation and maintenance of the leak detection and repair system in order to identify, monitor and reduce diffuse emissions of volatile organic compounds, and thus mitigate the environmental impact of the production plant in Płock and the PTA plant in Włocławek, reduce losses of raw materials and products, and improve process safety.
- Procedure for Identifying Environmental Aspects and Determining Material Aspects – defines the process of identification, determination of materiality and periodic reviews of environmental aspects as well as allocation of responsibility for these activities.
The environmental objectives are set out in ORLEN’s Integrated Management System Policy and the Energy Policy. Such activities are carried out based on the Integrated Management System, which includes the Quality Management System (ISO 9001: AQAP 2110), Environmental Management System (ISO 14001), Occupational Health and Safety Management System (ISO 45001), Information Security Management System (ISO/IEC 27001), Energy Management System (ISO 50001) , Certification System for Biomass and Biofuels ISCC, KZR INiG certification system for the HVO process, Factory Production Control System (ZKP) – for bitumen production, and Food Safety Management System (HACCP) according to Codex Alimentarius. The Company holds valid certificates of compliance with ISO 9001:2015, AQAP 2110, ISO 14001:2015, ISO 45001:2018, ISO/IEC 27001:2017-06, ISO 50001:2018- 09, ISCC EU, KZR INiG, and ZKP.
These systems meet the highest international management standards and support the Company’s day-to-day efforts to ensure professional customer service and maintain top quality, safety, health protection, climate and environmental standards. The key ORLEN Group companies have Integrated Management Systems in place, which include an Environmental Management System implemented and maintained in accordance with the ISO 14001 standard as their integral part. The Group companies also follow Integrated Management System/ Environmental Management System Policies, providing for an obligation to protect the environment, which includes pollution prevention and other specific obligations relevant to the operations of individual companies. These policies also include a requirement to comply with the law and other external and internal requirements identified together with stakeholders.
All systemic activities, in particular those which are material to the safety of people and the natural environment, are aligned with the ORLEN Group Strategy, which takes into account the aim to optimise technological processes, reduce greenhouse gas emissions, achieve climate neutrality and net zero emissions, and comply with sustainable development principles.
Energy
Fulfilment of REMIT obligations by ORLEN – this document sets out, in particular, the rules of conduct applicable to insiders and the procedure of disclosing inside information to the public.
Rules of Conduct Relating to Regulations on Introducing Restrictions in the Supply and Consumption of Electricity in the Territory of the Republic of Poland – the objective is to safeguard the operations of ORLEN if restrictions are imposed by the state authorities.
Instruction on Forecasting and Balancing requirements for Energy Utilities – MEBiP for Organisational Units Located in Płock, the PTA Plant in Włocławek and External Customers – the goal is to keep a proper balance of consumption of energy utilities in specific areas of ORLEN and by external consumers connected to the power grid.
Rules for Managing and Trading in Electricity and the Related Property Rights – this document sets out the rules for managing and trading in electricity and property rights at ORLEN as part of GAHE (Active Energy Trading Platform). The regulation also applies to the ORLEN Group companies operating within GAHE.
Rules for the Performance of the Energy Trading and Technical Operator Tasks – include processes involved in trading in electricity, property rights in certificates of origin for electricity, energy efficiency certificates, guarantees of origin, the related energy ranges and ancillary services
Detailed Rules for Recognition of Qualifications Held by Persons Involved in the Operation of Power Equipment, Units and Networks at ORLEN – include the types of work and positions, as well as power equipment, units and networks in the case of which the operator is required to have specific qualifications; the scope of knowledge required to obtain recognition of qualifications held by persons involved in the operation of power equipment, units and networks; and the qualifications verification procedure.
Counteracting corruption and bribery
ORLEN Group Anti-Corruption and Misconduct Prevention Policy is designed to raise employee awareness of anti-corruption, encourage positive attitudes and behaviour, and streamline procedures and business process oversight. The document underscores the importance of training and awareness-raising among employees and the responsibility of companies’ managements to create conditions that help to prevent and counteract corruption at the ORLEN Group. The person responsible for coordinating the implementation of the Policy objectives is the ORLEN Anti- Corruption Compliance Officer. Relevant activities are based on three pillars: employees directly engaged in business processes, employees responsible for economic security support functions, and employees responsible for internal control and audit.
ORLEN Group Conflict of Interest Management Policy ensures transparency in business relationships, identifying and managing any potential or actual conflicts of interest involving employees and representatives of external stakeholders.
Anonymous Whistleblowing System allows ORLEN employees and other persons to report any irregularities and violations of law related to the Company’s operations. Whistleblowers can remain anonymous, thus protecting their identity and enhancing the Company’s security. In the Anonymous Whistleblowing System, reports can be made either in written form or orally and whistleblowers are afforded protection.
ORLEN Group Policy for Accepting and Offering Gifts – its purpose is to prevent corruption, ensure transparency in business relationships and enable registration of gifts accepted and offered. The Policy lays down the key rules for accepting and offering gifts, and specifies employees’ responsibility in this respect.
Rules for Organising the Counterparty Screening Process at ORLEN – counterparty screening is a process comprising a set of actions to identify the counterparty, determine the circumstances associated with a transaction and exercise due diligence in deciding whether to enter into or continue a transaction with that counterparty.
ORLEN Group anti-money laundering and terrorist financing rules and instructions – laying down detailed procedures to be followed in counteracting money laundering and financing of terrorism at the ORLEN Group. The rules are addressed to all companies’ employees in customer-facing positions and employees who have direct access to financial documents or participate in the execution of transactions.
ORLEN Group Regulatory Risk Management Policy, being a part of the Compliance Policy – governs regulatory risk management processes resulting from existing or proposed legal regulations, excluding tax risks.
Policy on corporate governance and allocation of the companies in which ORLEN holds equity interests to ORLEN Management Board Members in charge of business oversight of the companies – a document containing instructions on the selection of candidates for members of the ORLEN Group companies’ governing bodies and the rules for setting and reviewing Individual Bonus- Related Targets for members of the ORLEN Group companies’ management boards. It provides for full corporate supervision over the ORLEN Foundation.
Supplier Code of Conduct – defines ethical standards that must be met by the ORLEN Group suppliers. It includes guidance on activities related to counteracting corruption, and promotes high ethical standards in business activities.
Rules for Managing the Risk of Losing Information Security Attributes – information and guidelines on the process of managing the risk of losing security attributes.
Rules for Financial Control Procedures Carried out by the Financial Control, Risk Management and Compliance Office – set out the rules governing financial inspections at ORLEN and other ORLEN Group companies.
ORLEN Financial Control Standards – set out the framework for management, performance and quality assurance in financial control activities. The purpose of the Standards is to ensure and maintain a professional level of financial inspections carried out by the Financial Control Department of the ORLEN Financial Control, Risk and Compliance Management Office and to standardise the approach to preparation, conduct and recording of financial inspections and assessment of their findings.
Rules for the Implementation of Audits, Consultancy and Business Analysis Assignments at ORLEN – define the rules for conducting audits, consulting projects and business analyses at ORLEN, other ORLEN Group companies and other entities, to the extent permitted by law.
Enterprise Risk Management Policy and Procedure – laying down the principles of Enterprise Risk Management for ORLEN and the roles and responsibilities of each individual involved in the process.
Integrated Management System Policy – a document describing the working standards for quality assurance, reduction of environmental impacts, health and safety at work, information security and food safety. It is a declaration to assure quality, minimise environmental impacts, ensure employee safety and information security, and is closely related to the ORLEN core values.
Companies of the former LOTOS Group and the PGNiG Group (until August 1st 2022 and until November 2nd 2022, respectively, and until the end of 2022), applied anti-corruption policies and solutions adequate for the ORLEN Group, ensuring a comparable degree of protection for their operations.
Occupational health and safety
Key policies
The existing policies and internal regulations regarding occupational health and safety include:
- Occupational safety at the ORLEN Group is governed by national legislation, European Union regulations, harmonised national standards and principles resulting from best practices for safe work and process execution.
- The ORLEN Group companies have systems of internal by-laws in place that include personal, process and fire safety policies, rules, internal orders, procedures, manuals, work instructions etc. On the other hand, initiatives implemented at the corporate level of the entire ORLEN Group involve initiating, creating and monitoring measures aimed at harmonising and continuously improving the solutions used across the companies in the context of their occupational safety standards and systems.
- Development directions for the personal and process safety area at the ORLEN Group 2022– 2026 – an OHS management concept, based on building and developing a uniform safety framework for the ORLEN Group, while enhancing excellence in operations and preventive measures related to personal and process safety.
- ORLEN Group Safety Standards and Technical Standards – uniform requirements for work safety, process safety, fire safety, and safety of operations involving handling of dangerous goods. The ORLEN Group has established and follows about 59 occupational safety standards, which are aligned with the best practices in the fuel and energy industry. The ORLEN OHS Office coordinates identification of the needs for new standards or updates to current ones on an ongoing basis.
- Comprehensive prevention system of ORLEN – the key component of the occupational health and safety management system, which consists of internal organisational documents related to occupational health and safety, fire and chemical safety, radiation protection, technical and process safety, and safety of operations involving handling of dangerous goods. These include: ORLEN process safety management system, Radiation Safety Instruction for the Płock Production Plant and Włocławek PTA Plant, ORLEN Fire and Chemical Safety Rules, and company regulations concerning road transport of dangerous goods. ORLEN Group companies have set up similar systems within their own organisational structures.
- ORLEN Safety Points – a set of basic principles required to be observed together with all applicable regulations and standards. Safety Points for ORLEN company-owned service stations are the key rules that must be adhered to on the premises of the service stations owned by ORLEN. ORLEN Group companies have similar rules in place within their organisational structures, adapted to the specific nature of their processes.
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ORLEN Group 2022 Integrated Report
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