Counteracting corruption

There is zero tolerance for any form of corruption in the PZU Group; codes of ethics oblige employees to carry out their business duties in accordance with ethics and the law, to cooperate with business partners, and follow the rules for accepting and giving gifts, and preventing conflicts of interest. Various regulations are in place at PZU Group entities to prevent corruption, including operational procedures in compliance. The entities’ management boards are responsible for managing compliance risks, as well as implementing compliance guidelines and recommendations. In addition, in 2025, the PZU Group’s Sustainability Policy was updated.

PZU Group entities, excluding banks, are implementing compliance solutions along the lines of those in place at PZU and PZU Życie, proportionally and adequately to the specific natures of these entities. The PZU and PZU Życie Anti-Corruption Program defines a framework for corruption risk management. It provides the foundation for implementing detailed internal regulations in individual areas of the companies’ operations. The goal of the Program is to maintain PZU’s reputation as a company with integrity, transparent management practices and ethical business operations. The AntiCorruption Program establishes rules for corruption risk management, division of responsibilities, and identification of business areas particularly vulnerable to corruption and corruption factors.

Poland, as well as Lithuania, Latvia, Estonia and Ukraine, where the PZU Group’s foreign entities operate, have ratified the United Nations Convention Against Corruption, the provisions of which provide a standard for national anti-corruption legislation. The PZU Group undertakes anti-corruption measures in accordance with applicable legal regulations and ethical standards enforced in Poland and the European Union and Europe overall.

The detailed scope of training is tailored to the specific nature of the entities and the risks they face. Entities where anti-corruption training was not provided as defined above in 2025 are: PZU Finanse, PZU Lab, Ogrodowa-Inwestycje, PZU Pomoc, BALTA, and PZU Tech. Other anti-corruption training was conducted at these entities, such as on whistleblowing procedures, rules for accepting and giving gifts, compliance, and conflict of interest management. At BALTA, anticorruption training takes place every two years and was conducted in 2024. Training in the PZU Group mainly involves e-learning. Some anti-corruption training courses require a knowledge assessment test upon completion. Anti-corruption training is made available to members of the PZU Management Board and Supervisory Board.

At PZU and PZU Życie, the business areas that are most at the risk of corruption are purchasing, sales, prevention, sponsorship, human resources and accounting. PZU Group entities individually identify business areas exposed to corruption risks. In the PZU Group, all employees, regardless of their function, are equally subject to by anti-corruption training, and no records are kept of training for those at particular risk of corruption.

The PZU Group did not identify any court-confirmed cases of corruption in 2025 or 2024. No fines were recorded for violations of anti-corruption and antibribery laws. There were also no court-confirmed incidents of corruption or bribery that resulted in the termination or non-renewal of contracts with business partners.