Financial and
ESG report 2020

Combating corruption

[GRI 103-1, 103-2, 103-3]
The Bank’s approach calls for zero tolerance to any and all manifestations of corruption, which may be succinctly defined as the acceptance or giving of (financial or non-financial) benefits with a view to generating a specific behavior or omission by the other party.

Construed in this manner, corruption is associated with the area of ethical behaviors of employees and is governed by the Code of Ethics of the Bank Millennium Group. As regards the prevention of counteracting corruption, the Code of Ethics focuses on: 

The Bank applies fair and uniform rules for the selection of its suppliers where such selection is based on objective criteria such as the quality, price, reliability and compliance with the principles of ethical business conduct. Tenders are conducted in a transparent manner, in compliance with the applicable internal regulations. The Bank also keeps trade secrets confidential, adheres to confidentiality clauses and protects all information it obtains in the process of negotiating and performing contracts with its suppliers. 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. 

the Bank complies with the law and ethical standards in their contacts with individuals holding a public office and get in touch with such individuals only when and to the extent such contacts are indeed necessary for the performance of their official duties. Moreover, the Bank has adopted an approach that requires political neutrality, which is manifested, among others, in the absence of support, funding or enabling any political activity within the space administered by the Bank. 

as a rule, it is forbidden to accept and give (offer) benefits, except when they are modest and of reasonable value, and their giving or receiving is non-binding, i.e. does not oblige to reciprocity, as nor does it give the impression that their handing over or receipt is to induce the other party to make a decision in return for their receipt. Benefits of small value are also allowed, as they are customarily given and received on special occasions (eg Christmas). Particular attention is also paid to maintaining the appropriate time for giving benefits, i.e. this time cannot coincide, for example, with conducting a tender, planning a cooperation agreement, etc., which could mean that the benefit given is to persuade the other party to make a specific decision. 

[GRI 205-2] Within the framework of mandatory training on the Code of Ethics employees (806 people) familiarize themselves with the Bank Millennium Group’s anti-corruption policy. 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 Compliance Department head.  

Risk of corruption (Bank Millennium Group)
[GRI 205-1] Number and percentage of organizational units analyzed for corruption risk During internal audits, the vulnerability of bank processes to various types of threats and fraud, including corruption, is examined. Such examination covers all the operations of the Bank and all business processes implemented within the Bank Millennium Group, as appropriate for assessment of the degree of the risk of exposure to the specific type of threat. It is difficult to specify the number of audited units, since audits concern processes and often several organizational units may be involved in each process.  
[GRI 205-3] Actions taken after corruption cases are found  In 2020, no corruption cases have been found.  


[GRI 103-1, 103-2, 103-3]

Some Companies have their own anti-corruption regulations. Millennium Dom Maklerski has implemented, among other things: Rules and regulations for persons engaged in Millennium Dom Maklerski 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. 

Millennium Towarzystwo Funduszy Inwestycyjnych applies also the principles provided for in the Bank Millennium Group’s Code of Ethics.  

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