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2018 Financial and Social Report

The rules for preventing corruption are described in the “Bank Millennium Group’s Code of Ethics”. To prevent corruption risk the Bank Millennium Group identifies the areas that are the most vulnerable to risk and defines the rules of conduct to prevent corruption including: the rules and conditions for ethically accepting and giving (offering) benefits in the Bank Millennium Group and the rules for Bank Millennium and its subsidiaries to participate in tenders. A breach of the foregoing rules forms cause for the enforcement of official consequences, and in special cases for criminal prosecution.

The regulations also refer to the Bank’s business partners. Every supplier taking part in a tender procedure must undertake to observe the rules included in the Bank Millennium Group’s Code of Ethics by signing a representation to that effect.

Within the framework of mandatory training on the Code of Ethics employees familiarize themselves with the Bank Millennium Group’s anti-corruption policy. [GRI 205-2] They may also pose questions and report observed irregularities via a dedicated telephone line or e-mail inbox or they may contact  their immediate supervisor or the person running the Compliance Department.

During internal audits, the vulnerability of bank processes to various types of threats and fraud, including corruption, is examined. [GRI 103-1, 103-2, 103-3]

Risk of corruption
2018 2017 2016 2015 2014
Number and % of organizational units analyzed for corruption risk It is difficult to specify the number of audited units, since audits concern processes and several organizational units may be involved in each process.
Actions taken after corruption cases are found No corruption cases have been found 1

[GRI 205-1, 205-3]

Some Companies have their own anti-corruption regulations. Millennium Dom Maklerski has implemented, among other things: Rules and regulations for persons affiliated with Millennium Dom Maklerski S.A. to invest in financial instruments, and the Procedure for identifying, classifying and assessing the cash and non-cash benefits accepted and given by Millennium Dom Maklerski S.A. in connection with the rendering of brokerage services. Millennium Towarzystwo Funduszy Inwestycyjnych applies the regulations stemming from the legal requirements applicable to that category of entities set forth in the Rules and regulations for accepting and giving performance incentives. [GRI 103-1, 103-2, 103-3]