PKN ORLEN’s compliance function is based on the follo-wing four elements:
- the ERM system, which supports the process of assess-ment of financial and operational risk compliance with regard to the effectiveness of controls and the ERM Policy and Procedure;
- the internal audit and control function – with respect to compliance of the processes with internal regulations;
- assessment of compliance with integrated management systems (ISO);
- managing the risk of non-compliance with legal regulations, standards and ethical norms based on
the requirements of the PKN ORLEN Compliance System documentation, with a particular focus on risks related to the Company’s business sector.
PKN ORLEN’s Integrated Management System takes into account the findings of audits and reviews as well as complaints and grievances. Additionally, preventive/cor-rective measures are taken to address any irregularities identified in the above processes. All these activities are designed to ensure compliance with the adopted reference standards: ISO 9001 (quality management system), ISO 14001 (environmental management system), ISO 45001 (occupational health and safety management system) and ISO/IEC 27001 (information security mana-gement system), ISCC and KZRINiG (certification systems for biomass and biofuels), Factory Production Control System, and Food Safety Management System.
Once a year, based on the reviews, a comprehensive report about the organisation’s Integrated Management System is prepared, submitted to the Company’s Mana-gement Board and posted on the intranet.
PKN ORLEN’s compliance with or preparedness (ali-gnment level) for applicable laws or draft legislation is monitored on an ongoing basis and reported to the PKN ORLEN Management Board. Where necessary, appropriate steps are taken to ensure that the Com-pany meets the requirements of Polish and EU laws and regulations.
The Financial Control Department carries out financial audits aimed at identifying any economic irregularities and fraud, verifying if PKN ORLEN and ORLEN Group employees respect the applicable laws, internal poli-cies and professional standards, estimating the impact of any potential irregularities or cases of misconduct, defining corrective measures and designating respon-sible persons, as well as assessing internal policies.
The audited area is scrutinised mainly against legal com-pliance, relevance, cost efficiency, reliability, efficiency and legitimacy criteria, with the interests of PKN ORLEN and ORLEN Group companies taken into consideration. Independence of the Financial Control Department is assured through appropriate functional reporting lines within the Company’s organisational structure.
Financial audit activities are performed on the basis of annual plans approved by the President of the PKN ORLEN Management Board. Additionally, the Financial Control Department can also perform ad hoc and inve-stigative audits upon requests submitted to the Head of the Financial Control, Risk and Compliance Manage-ment Office by Members of the PKN ORLEN Manage-ment Board and individual business functions.
On the basis of findings presented in the financial audit reports, follow-up instructions are issued which specify and prioritise measures to be taken to eliminate irregu-larities or improve the performance of the audited area. The implementation of post-audit instructions is monito-red continuously until it is confirmed that the corrective measures have been implemented.
Reports summarising the financial audits are drawn up for the PKN ORLEN Management Board and the Audit Com-mittee of the PKN ORLEN Supervisory Board twice a year.