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ING Bank Śląski S.A. Group has compiled the annual report in line with the best global practices of integrated reporting. To help readers use the interactive tools, we prepared a user guide with key features. We encourage you to watch a short animated video before reading the report.

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Integrated Annual Report
of ING Bank Śląski S.A. 2019

Anti-corruption policies

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As a public trust organisation, the Bank sees anti-corruption practices as the top priority in its relationships with clients, business partners, and among employees. Any and all forms of bribery or corruption are absolutely forbidden. All Group employees are required not to accept any actions suggesting an attempt to commit a crime or of corruption. The Regulations – Employee Business Ethics Standards of ING Bank Śląski S.A., which lay down the principles of conduct for each employee in the context of anti-corruption and combating conflicts of interest, information protection, and the whistleblowing procedure is the formal document regulating those aspects.

The anti-corruption aspects are detailed in the Anti-Bribery and Corruption Policy which all our employees are required to comply with. The Policy provides for the restrictions on accepting and giving material and non-material benefits in contact with clients, business partners, and public servants as regards:

  • gifts or invitations to events,
  • cash or its equivalents,
  • trip or accommodation funding,
  • hiring a given person by the Bank or offering him or her a traineeship or internship,
  • sponsoring or charity donations by the Bank,
  • business meals,
  • relationships with business partners.

In line with the accepted Policy, the Group follows the rules of integrity and ethics and applies the “zero tolerance rule to unfair behaviour”.

Should an employee accept or give gifts or benefits due to the participation in events – such an action always needs to be rationalised in business terms and the value of such benefits must be proportional to the specific nature of a business relationship. There must be always a legally compliant purpose of accepting or giving benefits. No such action can entail a conflict of interest, or even imply that such a conflict has occurred. The Bank disapproves giving benefits being political donations on its behalf. Staff decisions concerning employee hiring and secondment have to be substantiated with professional and objective criteria and they cannot serve illegal exertion of influence. The Policy provides for the amount thresholds on the benefits being gifts and participation in events which can be given or accepted by our employees.

Furthermore, the Group maintains a Register of Benefits. Accepted or given gifts, participation in events or business meals – in contacts with clients, business partners, and public servants – may need to be reported depending on their value.

The above rules are an element of the Anti-corruption Declaration ING Bank Śląski S.A., which is always enclosed with agreements made with vendors. As per the Declaration, the ING Group disapproves of actions which satisfy the criteria of or imply bribery, and expects its business partners to comply with the anti-corruption standards. Further, the Group does not cooperate with business partners who do not accept our standards.

All employees are required to report corruption- or conflicts of interest-related irregularities. Infringements of the above regulations and laws can be reported in person or anonymously via the whistleblowing procedure set out in the Whistleblowing Policy for Infringements of Law, Internal Regulations and Ethical Standards.

Compliance with policies is also ensured at the level of subsidiaries.

 

We counteract corruption

  • [205-2]
    Communication and training about anti-corruption policies and procedures
  • [205-3]
    Confirmed incidents of corruption and actions taken
At ING Bank Śląski S.A. we do not tolerate corruption. We raise awareness of our employees in that regard so that they could identify and counteract corruption better. We apply several simple rules:


  • We do not take or give any gifts or invitations to events whose value exceeds the amount thresholds set.

  • We declare acceptance or presentation of benefits above the permitted value to the electronic Register of Gifts- currently the threshold is PLN 200. We report such acceptance or handing in relations with clients and business partners. In relations with public officials, we report each case of accepting or giving benefits regardless of value.

We also require our vendors and business partners to comply with those rules. We encourage them to adopt the ING Bank Śląski S.A. Anti-Bribery and Corruption Declaration.

The content of Declaration in on the website.

In 2019, no cases of bribery or corruption were identified.

We combat conflicts of interest

  • [102-17]
    Mechanisms for advice and concerns about ethics

We introduced internal procedures and controls to combat conflicts of interest. They cover:

  • the segregation of duties in the Bank's organisational structure and relations between different management levels as well as personal links between employees,
  • the requirement to consult and inform the Bank for employees that want to start or started additional professional activity,
  • private account dealings by employees having access to confidential, insider information or professional privilege.

We report instances of breach of law and Business Ethics Standards

  • [102-17]
    Mechanisms for advice and concerns about ethics

Employees can report suspicions of crimes and violation of Business Ethics Standards anonymously. They can also report the same by name and we ensure confidentiality and discretion as well as protection against repressive actions. If a report is confirmed, appropriate corrective and preventing measures are taken for the future. The reports are received by the Compliance Department Director who alerts the CEO and agrees with him on the next steps.

There were 13 reports made in 2019. After analysis and explanatory proceedings, irregularities were confirmed in 4 cases and corrective measures were applied.

In order to recall the rules for reporting illegal, inappropriate or unethical behaviour, an e-learning training course was implemented at the turn of 2018/2019. The training course presents how an employee can act in case of suspected violations of law, internal regulations and ethical standards. Training is mandatory for all employees.

The Bank does not have external dedicated channels for reporting violations of law and ethical principles. Stakeholders can, however, contact us through all available channels and inform us of any violations. If such a case were to occur, it would be referred directly to the Expert Centre – Compliance Department.

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