Annual report 2019

Ethics and organization values

Corporate governance

Corporate governance in BNP Paribas Bank Polska S.A. results from legal acts (in particular Code of Commercial Companies, Banking Law and laws regulating capital market) and recommendations included in the documents: “Best Practices for WSE Listed Companies” and “Principles of Corporate Governance for Supervised Institutions”

The information regarding compliance with corporate governance principles in 2019 has been available in the following section.

  • 102-16

The BNP Paribas Group is guided in all its activities by the values set out in the BNP Paribas Way document. These values are divided into two categories: the first defines the driving forces, the second indicates the four strengths
of our organization and its employees.

For more information on the organization’s values, see Chapter Responsibility in the workplace.

The norms of behaviour and ethical standards accepted in the BNP Paribas Group are set out in The BNP Paribas Group Code of Conduct. It specifies principles consistent with the Group’s values. This document expresses what we are striving towards, to be a respected European bank with global reach, and what should be remembered by every employee of the BNP Paribas Group.

Important documents regulating ethical issues at Bank BNP Paribas also include:

  • Regulations on conflict of interest management at BNP Paribas Bank Polska S.A.,
  • Policy on reporting violations of law as well as procedures and ethical standards applicable at BNP Paribas Bank Polska S.A., including anonymous reporting (whistle-blowing),
  • Rules of accepting and giving presents by Employees of BNP Paribas Bank Polska S.A.,
  • Regulations for the protection of the flow of confidential information at BNP Paribas Bank Polska S.A.,
  • Regulations for investing by related persons and executing transactions by managers.
  • 102-17

The Bank and the Bank’s Capital Group have internal mechanisms enabling employees to obtain advice on behaviour in ethical and legal matters. These include dedicated function boxes through which employees can raise questions and concerns regarding ethics in the workplace.

We conduct ongoing and planned inspections regarding compliance with ethical standards in the Bank’s operations. In addition, we conduct educational activities reminding employees of the ethical principles in force in the bank.

Bank BNP Paribas, as a responsible financial institution, is involved in a number of initiatives, promoting ethics and responsibility in business.

Anti-Corruption Policy

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  • 205-1
  • 205-2
  • 205-3

In September 2018, the Bank implemented the Anti-Corruption Policy. The policy regulates the issues of promoting ethical behaviour as well as detecting and penalizing corruption incidents. It allows to manage the risk of corruption. It also monitors the events that are even only potentially corrupt.

The Bank’s anti-corruption system is based on:

  • internal regulations specifying the method of operation and reporting corruption incidents to the appropriate organizational units of the Bank,
  • training employees to increase their awareness and show paths of action in specific situations,
  • operational control as part of the implemented internal control system.

In accordance with the Bank’s Anti-Corruption Policy, the Managing Director of the Compliance Monitoring Division designates a person acting as Anti-Corruption Correspondent, whose tasks include coordinating anti-corruption activities.

As part of the anti-corruption process, the Bank monitors, among others, indicators regarding reported cases of fraud, identified conflicts of interest, accepted / forwarded gifts and invitations, due diligence in establishing relationships with clients / contractors / agents and the level of employee awareness.

The anti-corruption policy is available in the Intralex internal system. Every employee of our Bank has the opportunity to read the document.

  • 205-2

The anti-corruption process must be known and understood by all employees of the Bank. To this end, we conduct relevant training on the subject, which lasts 1 hour and is available to all employees of the Bank.


In 2019, 9,045 employees of the Bank participated in the anti-corruption training and passed the verification test in this area. This represents 94.51% of employees to whom the training has been assigned as compulsory.

Each newly recruited employee is required to undergo a workshop training, as well as to complete on-line training in the field of counteracting the conflicts of interest, counteracting corruption and fraud. The training also includes broadly understood professional ethics.

We are currently working on an additional training, the scope of which will be dedicated to the employees particularly exposed to the risk of corruption. In addition, stationary training sessions, targeted at employees particularly involved in the anti-corruption process, were conducted. In 2019, such training was attended by members of the Bank’s Management Board and Supervisory Board, as well as employees of the Legal Division and the Compliance Monitoring Division.

  • Policy on notification of a non-compliance incident at BNP Paribas Bank Polska S.A. gives employees the opportunity to submit a notification of the occurrence or possibility of a non-compliance incident, including an act of corruption, in a manner independent of all other methods described in other banking regulations.
  • Rules of accepting and giving presents by employees of BNP Paribas Bank Polska S.A. describe in detail the process of accepting and giving gifts. According to them, employees may under no circumstances make the scope of services provided by the Bank or the products offered dependent on potential personal benefits obtained from customers. In particular, it is forbidden to solicit a gift from the customer. It is unacceptable to accept or give presents that may affect the impartiality and independence of decisions. The rules describe the process of giving presents to persons performing public functions.
  • Code of good practice for employees of BNP Paribas Bank Polska S.A. in commercial relations with contractors. According to the document, employees commit to guarantee fair competition.
  • Regulations on managing conflicts of interest of BNP Paribas Bank Polska S.A. and the Brokerage Office of BNP Paribas Bank Polska S.A.
  • Regulations on managing the risk of conflicts of interest between the Bank and the Employees.

Compliance with regulations

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  • 206-1
  • 417-3
  • 418-1
  • 307-1

In 2019, there were no confirmed cases of corruption in the Bank or in the Bank's Capital Group.

At the Bank, one case of non-compliance with regulations and / or voluntary codes regarding marketing communications was recorded. There was one proceeding pertaining to behaviour violating the freedom of competition or antitrust regulations in which the organization acts as a participant in the proceeding (the proceeding did not end in the reporting period). There was also one proceeding regarding a case of non-compliance with regulations and voluntary codes regarding marketing communications. It ended with the imposition of a fine.

The Bank also reported 44 cases of sending customer documents by mistake to an incorrect email address and / or temporary provision of customer data to a third party in an online application.

No fines or other sanctions for non-compliance with environmental protection law were imposed on the Bank.

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