Annual Report
2017

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Goal 5: We Want to improve our management approach

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Goal 5: We Want to improve our management approach

  • We coordinate our CRS activities
  • We have a responsible supply chain
  • We prevent unethical behaviour
  • We report on our corporate responsibility on a regular basis

A. We coordinate our CRS activities

The director of the Communication and Marketing Strategy Department, who reports directly to the president of the management board of the bank, and whose managerial objectives (MbO) include CSR-related objectives, is responsible for coordinating the efforts aimed at implementing the socially responsible approach in management. On an ongoing basis, CSR projects are coordinated by the CSR specialist reporting immediately to the director. The CSR specialist is also responsible for cooperation with managers of individual functional areas related to social responsibility.

B. We have a responsible supply chain

Suppliers invited to procurement proceedings organised by the Procurement and Administration Department are requested to submit relevant statements and act in line with the principles of social and environmental responsibility.

External supplies for the group subsidiaries include the cooperation with:

  • electricity and media providers,
  • real estate agencies,
  • providers of specialist services, mainly IT services,
  • companies supporting sales and customer service,
  • operators of ATMs, credit and payment cards,
  • suppliers of services related to the maintenance and security of facilities.

As regards the majority of areas and categories, purchases are made at the central level, i.e. by mBank on behalf of the entire group. All the suppliers who participate in processes launched with the use of the procurement platform are verified against ethical, social and environmental requirements in the same way regardless of the fact which subsidiary will use their services. A potential supplier/bidder has to accept our “Principles of Participation in the Procurement Process”. The said principles oblige potential suppliers/bidders to do, i.a., the following:

  • respect human rights and labour standards, counteract corruption and protect the natural environment. In particular, they have to respect the Universal Declaration of Human Rights, International Labour Organisation Standards, OECD Guidelines (in particular those pertaining to counteracting corruption), the Rio Declaration on Environment and Development, Agenda 21, as well as the United Nations Convention against Corruption;
  • observe international trade sanctions and embargoes, including sanctions that may be applicable due to a resolution of the UN Security Council or imposed by the EU;
  • inform mBank about the procedures they have implemented to protect human rights, ensure compliance with labour standards, counteract corruption and protect the environment, or to immediately repeal these procedures, whenever so requested.

C. Prevention of unethical behaviour

Effective procedures and tools as well as awareness of our employees – these are the keys to prevent unethical behaviours. We effectively detect violations of the rules and take appropriate measures.

Our approach to the issue at mBank Group is governed by:

  • Anti-Corruption Policy,
  • Gift Policy,
  • Anti-Fraud Policy,
  • Policy of Managing Conflicts of Interest.

The Compliance Department is responsible for observance of principles set forth in the above documents at mBank. The unit is also responsible for coordinating work of compliance units in the group subsidiaries.

Owing to the specificity of brokerage operations, mBank’s Brokerage Bureau applies separate provisions and additional procedures. Moreover, the unit has its own supervision. Fraud is a deliberate use of an official position or status of mBank’s client or counterparty in order to receive unauthorised benefits to the detriment of mBank or its clients. We distinguish, for example, electronic banking fraud, credit fraud, theft, money laundering, unauthorised access or industrial espionage.

Selected employees are trained in prevention and early detection of frauds. Each employee who suspects that fraud has taken or may take place is obliged to inform their supervisor about it. Another option is to use electronic system that guarantees anonymity. Employees who (in good faith) report suspected fraud are protected against any acts of retaliation.

are very precise; furthermore, in 2017 these rules were additionally tightened up. It is forbidden to accept any gifts from the bank’s counterparties, except for small ones, e.g. Christmas gifts, up to the amount of PLN 250. Similar rules apply to gifts given by our employees. Accepting or giving a gift above this value requires relevant consent and is documented in the dedicated gift register. We strictly enforce a total ban on offering benefits to representatives of public institutions, employees of the public sector and local governments, politicians, etc.

All the organisational units and job positions are systematically audited in terms of corruption risk. There are several dozen checks carried out annually, both on a planned and ad hoc basis. We also guarantee all employees and cooperating entities support in counteracting corruption, also in the form of training. All identified corruption incidents or corruption attempts are subject to registration and punishment. In 2017, the Compliance Department did not identify any incidents bearing the hallmarks of corruption.

The adopted solutions assure that neither mBank nor its employees or other persons linked to mBank benefit or avoid losses at the expense of the interests of clients. In the case of a conflict of interest, the interests of the bank and its clients have priority over the employee’s interests, and the interests of its clients have priority over the bank’s interests. Special solutions in this regard apply at mBank’s Brokerage Bureau.

The compliance units are informed of any identified or potential conflicts of interests. They analyse reported conflicts of interest and issue recommendations on the procedure to be applied in a given case.

D. We report on our corporate responsibility on a regular basis

This report has been mBank Group’s second integrated report and has for the second time covered the entire capital group. It has been our third non-financial report under the mBank brand.

The publication of the consolidated integrated report is a part of implementation of our “Strategy for Corporate Sustainability and Responsibility of mBank S.A.”

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