GPW Group Code of Ethics in Business
In addition to improvement of professional qualifications, GPW also takes steps to develop its value-based corporate culture which is unique in awarding and applying employee initiatives that improve the effectiveness of the organisation.
GPW Code of Ethics
The GPW Employee Code of Ethics defines the core values applicable to all activities of the Company. The Code of Ethics outlines the principles and values to be followed by all GPW employees; it disseminates and promotes a culture of compliance with the law and decision-making based on ethical criteria.
Our employees follow the values defined in the GPW Employee Code of Ethics in mutual relations among employees, relations with customers and counterparties, relations with competitors, communication, promotion and advertising.
The GPW Employee Code of Ethics lays down sanctions for non-compliance. The document has been signed by all GPW employees.
In 2018 and in 2019, GPW was named an Ethical Company of the Year.
In 2020, GPW was named Super Ethical Company of the Year. Ethical Company of the Year is Poland’s only ranking established seven years ago which promotes good business practice, fosters ethics and fair play, and awards companies which consider the code of ethics more than a marketing tool and live according to its spirit.
The ranking is organised by Puls Biznesu with expert support of PWC Legal.
GPW was named Super Ethical Company of the Year among others in appreciation of its donation to the fight with the COVID-19 pandemic which financed barrier tents for the hospitals operated by the Medical University of Warsaw.
Anti-corruption and whistleblowing
In October 2018, the Warsaw Stock Exchange accepted the “Anti-corruption and whistleblowing standards recommended for compliance systems in companies listed on markets organised by the Warsaw Stock Exchange” developed by experts representing different groups of capital market participants.
The publication provides recommendations for organisations’ compliance function as well as tools which mitigate the risk of unethical behaviour enabling corruption and conflicts of interest. The standards address expected regulatory amendments, such as the Act on Liability of Collective Entities, and define “due diligence” required in anti-corruption processes and procedures. The document does not require companies to report their compliance with the guidelines.
Whistleblowing policy
GPW follows high standards of ethics and expects its employees to do the same, among others by reporting any reasonable suspicion of infringement of internal regulations and applicable standards. GPW has in place a Whistleblowing Procedure which defines how GPW employees may anonymously report identified or suspected infringements. The Whistleblowing Procedure ensures that all reports are handled in confidence and with due diligence.
Reports may be lodged on infringements of employee obligations, infringements of the Code of Ethics, as well as suspected abuse or illegal disclosure of inside information or professional secret and manipulation of financial instruments.
Personal data protection
The Warsaw Stock Exchange attaches special importance to personal data security. GPW has taken a range of measures to protect personal data against loss, destruction or damage, and especially against unauthorised access. Data are protected both with technology and organisational solutions. According to the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), information concerning personal data processing, the legal basis of processing, the ways of collecting and using personal data, and the enforcement of the rights of data subject is presented in the Privacy Policy published on the GPW website https://www.gpw.pl/polityka_prywatnosci
GPW conflict of interest management rules
Employees across GPW’s organisational structure protect GPW’s reputation and image.
The Warsaw Stock Exchange has established transparent conflict of interest management rules.
GPW’s conflict of interest management rules help to prevent, identify, and manage conflicts of interest in order to ensure that GPW’s activity is fair, transparent, and professional in accordance with business ethics and corporate governance standards.
The GPW Management Board has appointed the Compliance and Risk Department as the function responsible for supporting employees in the identification of circumstances or events which give rise to conflicts of interest and in the interpretation of applicable provisions. The GPW Management Board acting through the Compliance and Risk Department notifies the Polish Financial Supervision Authority of any significant conflict of interest immediately when it is identified. The Exchange Supervisory Board oversees the implementation and functioning of mechanisms derived from the regulations and assesses their adequacy and efficiency.
GPW employee gift policy
The GPW employee gift policy aims to prevent any circumstances where the professionalism, objectivity, impartiality, and integrity of GPW employees could be compromised or GPW’s reputation could be damaged because a GPW employee accepts or presents a gift. Employees are required to report any identified infringements of the policy.
GPW AML/CFT policy
The anti-money laundering and combatting the financing of terrorism policy of the Warsaw Stock Exchange sets out the conditions for the exchange and protection of information maintained under the AML/CFT requirements; the mitigation of AML/CFT risks; the measures necessary to manage identified AML/CFT risks; the financial security measures; raising GPW employees’ AML awareness; employee reporting of actual or potential infringements of AML/CFT regulations; and GPW’s AML internal controls and compliance.
The procedure clarifies GPW’s AML requirements and applies to all GPW employees.
In line with the CSR strategy, individual procedures and policies are also implemented in other GPW Group Companies.