Integrated Report 2021

Corruption prevention

There is an Anti-Corruption Policy in place at the Bank. It regulates how corruption is identified and limits the risk of corruption. It also defines the principles of conduct and scope of responsibility in this area. Due to the adoption of the aforementioned regulation, all events of a potentially corrupt nature are monitored.

  • 102-25
  • 205-1
  • 205-2
  • 205-3
  • G-P3

We have a zero-tolerance rule for all forms of corruption, including accepting, offering, requesting, giving or agreeing to additional benefits, items or advantages.

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

  • Internal regulations specifying the method of operation and of reporting corruption incidents to the appropriate organisational 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.

The Bank continuously evaluates the management and control system (procedures, reporting, audits, training) implemented to counteract corruption. Appropriate internal regulations in this respect are implemented and updated on an ongoing basis. Risk mapping and the analysis of corruption-related information are centrally supervised. The Managing Director of the Compliance Division appoints a Corruption Prevention Correspondent, whose tasks include coordinating anti-corruption activities.

To counteract corruption, the Bank monitors, i.a., indicators concerning reported cases of fraud, identified conflicts of interest, accepted/given gifts and invitations, due diligence in establishing relations with Customers/contractors/intermediaries, the level of employee awareness. In 2021, the Internal and External Corruption Risk Assessment was integrated into the Operational Risk and Control Self-Assessment (RCSA) process.

We expect our business partners (suppliers, contractors, subcontractors cooperating with the Bank and its Customers on behalf of the Bank) to act in accordance with the principles set out in the Anti-Corruption Policy. An anti-corruption clause is a key part of each agreement concluded by the Bank with its business partners.

The current policies in the area of counteracting corruption are listed in the Due diligence policies and procedures section of the present chapter.

No cases of corruption were identified at BNP Paribas Bank Polska S.A. in 2021.

  • 205-2
  • G-P3
  • UNGC 10

Anti-corruption processes must be familiar and clear to all employees of the Bank. Therefore, we conduct relevant training, available to all employees, and we provide additional information through internal communication channels. A separate training course is addressed to employees particularly exposed to the risk of corruption. It provides i.a., practical solutions which help to counteract the risks. The Corruption Prevention Correspondent organises additional training for individual units of the Bank.

In 2021, the Bank implemented an updated training programme devoted to the Code of Conduct. One of its modules was devoted to counteracting corruption. Additionally, we designed a dedicated intranet site, which describes the anti-corruption system. IT solutions that will allow for more effective monitoring of key corruption indicators are also being developed.


of the employees who were assigned anti-corruption training completed the programme


of Management Board members received anti-corruption training


suppliers are familiar with anti-corruption policies and procedures, which is 65% of active suppliers and c. 93% of key suppliers

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