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Annual Report
2021
  • 417-3
  • 102-44
  • 102-43

Complaints

The complaints process is an important part of building the positive experience of Customers and their satisfaction from cooperation with entities of the Bank’s Group. Every complaint brought by a Customer is considered individually, and every problem reported is carefully analysed and explained.

Complaint handling process at the Bank

he submission of complaints or appeals by Customers may take on various forms, depending on the Customer’s decision: written, oral or electronic.

The complaint handling process is conducted along two lines:

  • the first line consists of units dealing with the first complaints of Customers in accordance with the tasks they perform, and with reports concerning personal data protection filed by the President of the Personal Data Protection Office;
  • the second line is the Customer’s Ombudsman and the Office of the Customer’s Ombudsman. They consider:
    • appeals of Customers against the decision of the Bank’s first line in the complaint handling process;
    • reports concerning the Customers filed by:
    • the PFSA;
    • external institutions dealing with the protection of Customers’ rights (such as the Banking Consumer Arbitration, the Arbitration Court at the Polish Bank Association, the Arbitration Court at the Polish Financial Supervision Authority, the Municipal or District Consumer Ombudsman and the Financial Ombudsman);
    • individual cases, in particular due to the significance of the reported issue.

The solution proposed by the Customer’s Ombudsman is the Bank’s final position in a given matter.

Complaints or appeals are handled with due care and diligence, fairly, thoroughly and as quickly as possible. The Bank’s Code of Ethics, the Principles of Good Banking Practice and the Standards of Customer service quality are applied in considering complaints.

Considering a complaint or an appeal involves, in particular:

  • analysing and assessing its validity;
  • taking appropriate steps to eliminate the irregularities identified;
  • giving a comprehensive response.

Pursuant to the Act on the handling of complaints by financial market entities and on the Financial Ombudsman, the Bank follows the principle that a response to a Customer’s complaint should be formulated in a clear and understandable manner and that it should include:

  • a factual and legal justification, unless the complaint is resolved in line with the Customer’s wishes;
  • information about the Bank’s position with regard to the Customer’s objections, including an indication of the relevant parts of the agreement or the product regulations;
  • specification of the deadline within which the Customer’s claim that has been accepted by the Bank will be fulfilled.

The deadlines for replying are in line with the provisions of the law, in particular with the aforementioned Act and the agreements concluded with the Customers.

The Office of the Customer’s Ombudsman regularly monitors and reports, among other things, to the Operational Risk Committee and the Bank’s Management Board and Supervisory Board. The process of handling Customer complaints is supplemented by the initiation of positive changes at the Bank.

Every unit at the Bank which considers complaints and appeals of the Customers:

  • analyses the reports received to identify possible irregularities, the reasons for them and the places of their occurrence and to identify possible changes to products, services or processes whose implementation would contribute to an improvement in the quality of the services provided by the Bank;
  • initiates remedial or improvement measures.

The competent unit (in terms of its responsibilities and the subject matter of the initiative):

  • takes remedial measures to eliminate irregularities;
  • implements improvements in products, services or processes;
  • provides information on the remedial or improvement measures taken and the deadline and method for their implementation to the Office of the Customer’s Ombudsman and to the unit handling the report.

This approach to the complaint handling process means that individual reports lead to the implementation of solutions that are beneficial not only for the person filing the report, but also for other Customers.

The implementation of remedial measures is monitored by the Office of the Customer’s Ombudsman.

Complaint handling process at the other entities of the Bank’s Group

The Bank’s subsidiaries manage complaints on their own, and they implement and follow their own procedures for receiving and considering Customer complaints. These procedures:

  • have been specified in the form of internal procedures/ regulations of the entities;
  • are included in the regulations and contained in the agreements with Customers or
  • arise from the provisions of the generally applicable laws.

Complaints are handled in a reliable and objective manner, taking into account all the information and documents related to the problem reported by the Customer and in accordance with the provisions of the law and concluded agreements.

Most of the Bank’s subsidiaries are subject to the Act on the handling of complaints by financial market entities and on the Financial Ombudsman which regulates this process in detail.

Indicators describing the complaint handling process

In 2021, the entities of the Bank’s Group received nearly 315 thousand complaints in total (320.5 thousand in 2020), approx. 85% of which were handled within 14 days (80% in 2020). Approximately 55% of all cases were fully or partly settled in the Customer’s favour (58% in 2020).

Marketing communication

The Bank’s policy is regulated by the “Principles for the conducting of marketing and public relations (PR) activities and social communication by PKO Bank Polski S.A.” which were adopted by resolution of the Management Board in December 2019. The Principles govern, among other things, the “General requirements for creating advertising messages regarding trading in financial instruments” (appendix no. 3 to the Principles). The Bank’s internal regulations concerning the principles for conducting marketing activities define the features of appropriate advertising messages, as well as the list of undesirable actions. According to these principles, an advertising message, in particular:

  • should be designed in a reliable manner, not be misleading, and should feature respect for the generally applicable laws, principles of fair trading and good practices;
  • must not present benefits in a way that would diminish the significance of the costs and risks associated with the purchase of a product or service.
  • In addition to the Bank’s internal regulations, in its marketing communications the Bank follows:
  • “The Code of Banking Ethics” prepared by the Polish Bank Association as part of the Principles of Good Banking Practice;
  • “Good Practices in consumer credit advertising standards” developed jointly by the Polish Bank Association, the Conference of Financial Enterprises and the Association of Lending Companies;
  • “The principles for advertising banking services” by the Polish Financial Supervision Authority;
  • “The canon of good financial market practices” prepared by entities in the financial and insurance sector.

In its marketing activities, the Bank has mechanisms that prevent the creation of unethical and unreliable messages. Each time, the correctness of the communication is consulted with the units whose tasks include verifying the compliance of messages with the generally applicable laws. The principles of ethics in marketing communication and the mechanisms for preventing the risk of unethical communications also apply to materials prepared at the Bank’s request by external entities (advertising agencies, event agencies).

The same standards apply to all Customer groups. Each message should be formulated in a comprehensible, reliable and credible way, regardless of the Customer to whom it is addressed.

Within the Bank’s Group, the subsidiaries have internal regulations which require them to design messages in compliance with ethical standards (this does not apply to entities that do not actively conduct marketing activities). These standards coincide with those adopted by the Bank. In addition, the Bank’s subsidiaries which have signed agency agreements with the Bank for the provision of marketing services to the Bank’s Group are required to apply the internal regulations on marketing communications in force at the Bank.

In their marketing activities, all of the Bank’s subsidiaries have control mechanisms to prevent the risk of irresponsible or unethical communication from the company. The marketing communication is approved respectively by a given company’s supervisory units or, additionally, in the case of companies which have signed agency agreements with the Bank for the provision of marketing services to the Bank’s Group – by the Bank’s competent departments.

[417-3] In 2021, as part of the marketing activities conducted by the Bank’s Group and the Bank, no administrative proceedings concerning the violation of ethics in marketing communication were pending, and no inconsistencies were recorded in marketing communication.

Communication with investors and Customers

In order to maintain proper relations with all of its shareholders, the Bank has adopted the “PKO Bank Polski S.A. Information Policy with respect to contacts with investors and Customers” (the policy was approved by the Management Board on 9 December 2014). According to its provisions, the overriding aim of the Bank’s information activities is to guarantee high standards of communication with capital market participants, which are a sign of respect for the principles of universal and equal access to information. As part of its information policy, the Bank takes into account the interests of all investors, provided that they are not in conflict with the Bank’s interests. The objective of the information policy is to define the mechanisms of communication with capital market participants to ensure appropriate, fair and full access to information about the Bank for all investors, without giving preference to any of them.

Investors’ interest in ESG issues

[102-44] The Bank has noticed an increase in investors’ interest in ESG issues. In 2021, their questions usually concerned the Bank’s measures aimed at supporting the stakeholders in fighting the epidemic, especially in the context of ensuring the continuity of the Bank’s operations, i.e. the safety of the Customers and employees and participation in social initiatives. The investors were also interested in the Bank’s position on financing high emission industries and the mining sector, the range of the ESG objectives adopted by the Bank, the ESG management structure within the Bank, and plans for the Bank’s participation in international ESG-related initiatives. The Bank’s participation in the international disclosures such as CDP Disclosure Insight Action or the Coal Policy Tool was appreciated by the investors.

The Bank runs a section dedicated to ESG issues on its website, which is a response to the growing importance of sustainable development issues in the Bank’s activities and investor relations. The site is updated regularly.

Customer satisfaction

[102-43] The Bank evaluates the stakeholders’ commitment based on regular Customer satisfaction surveys.

In 2021, the Customer satisfaction (CSI) and the NPS (Net Promoter Score) indices were incorporated again in the objectives of most of the organizational units of the Bank, including the Management Board. This means that Customer satisfaction and loyalty are of key importance to the Bank’s activities.

The Bank still conducts internal retail Customer surveys:

  • relational surveys – conducted among Customers in the Primary Customer segment, measuring the level of Customers’ loyalty and their satisfaction with cooperation with the Bank, encompassing the whole of the Customer’s experience;
  • transactional surveys – conducted at the key points of contact between the Customer and the Bank, immediately after the event, measuring satisfaction with a given interaction, which is defined in space and time, and the Bank’s NPS following the Customer’s recent experience in connection with that event.

As part of relational surveys, in 2021 internal relational surveys of Personal Banking Customers and SME Customers were carried out for the first time. Both surveys will be continued in 2022.

Tests were also conducted using a voicebot – this technique is used permanently to conduct relational surveys of Customers in the Primary Customer segment.

In the transactional survey area, the network of surveys on the iPKO transactional platform has been developed very strongly – currently, we are asking Customers for their opinions following the completion of over 40 requests and instructions. In 2021, questionnaires were also implemented in the IKO mobile application.

In addition, a questionnaire was implemented on the iPKO transactional platform, which is available to any Customer after logging in – the Customer may share his/her opinion at a convenient moment, on a topic that is important to him or her.

In total, in 2021 the Bank collected over 500 thousand surveys using various methods, including the remote channels (over 230 thousand interviews in 2020). There are plans to further increase the number of processes monitored, especially the service processes following the purchase of a product.

The Bank continued monitoring corporate Customer satisfaction and maintained high response rates in all surveys conducted at 65% and 64% in relational surveys with decision-makers. This shows that Customers’ willingness to participate in satisfaction surveys in the corporate Customer division has not decreased for over five years.

The largest increase in satisfaction compared with the previous years was recorded among Customers launching financing. The high ratings in this area were due to, on the one hand, Customers’ experience with the lending process last year and, on the other hand, appreciation for the Bank’s approach to their needs and specific nature in the first pandemic period.

The share of the Customer’s opinion in the product development process is growing each year. The Bank makes efforts to make it heard at every stage of product development. Therefore, it gradually increases the share of surveys which are aimed at supporting product development, testing concepts with Customers and participating in defining requirements, as demonstrated by the recruitment of a second qualitative researcher in the corporate area. At the same time, Customer satisfaction measures are an important element in the post-implementation evaluation of new solutions. The examples of new implementations in which objectives based on Customers’ opinions were planned and accounted for together with the revenue targets include, among others, a new mobile application interface, Express Elixir transfers or a new mass payment module.

Supply chain

Risk in the supply chain

The entities of the Bank’s Group follow the principles of social responsibility in the supply chain by managing their relationships with external entities in the following manner:

  • they follow the principles of fair competition;
  • they settle their liabilities in a timely manner to ensure liquidity in the supply chain;
  • as part of the procurement policy, at the stage of the letter of inquiry they oblige the suppliers to follow the principles of social and environmental responsibility;
  • they support diversity in cooperation with external entities.

Operational risk related to outsourcing banking activities to external entities

The Bank conducts banking activities with the support of external entities. As a result, it is exposed to operational risk arising from outsourcing services to them.

Principles for operational risk management; Principles for outsourcing the activities of PKO Bank Polski S.A. to external entities other than agents or intermediaries (outsourcing); Principles for cooperation with agents, and Principles for cooperation with intermediaries and Internet intermediaries.

Risk management is performed at all stages of outsourcing activities to external entities:

  • before selecting an entity: assessment of the risks related to outsourcing activities, including the assessment of the critical nature of the activities planned to be outsourced;
  • selecting an entity: the assessment of operations, technical and organizational measures to protect data, credibility, financial position of the entity and the possibility of ensuring continuity of the entrusted operations, identification and assessment of the existence of a conflict of interests;
  • concluding an outsourcing contract: including contractual provisions in contracts with contractors which secure the interests of the Bank and its Customers (including securing data containing protected information, possibility of effective oversight of outsourcing contracts by the competent supervisory authorities and other required provisions), maintaining and ongoing updating of the records of contracts concluded and the entities which perform them;
  • monitoring of cooperation: supervising the performance of contracts, regular review of contingency plans, regular risk assessment, including the critical nature of the activities outsourced, reporting irregularities in the performance of contracts, monitoring KRIs providing information about the scale of breaches in cooperation with external entities, annual review of the cooperation with external entities performing outsourcing contracts and presenting the results to the relevant bodies.

The procedures for managing operational risk, including the outsourcing risk at PKO Bank Hipoteczny S.A., correspond to the standards applied at the Bank. KREDOBANK S.A. has adopted its internal regulations: entering into cooperation is preceded by an assessment of the risk related to outsourcing a given activity.

Cooperation with suppliers of goods and services related to the ongoing procurement of the entities of the Bank’s Group

The task of the Bank’s Procurement Department is to oversee the procurement process in order to ensure the timely supply of the required goods and services of an appropriate quality. In addition to the Bank’s interest in the broad sense, the Procurement Department oversees compliance of the procurement processes with the principles of ethics, including the principle of equal treatment of all participants. When selecting suppliers, the Bank also takes into account certain criteria other than price, including compliance with business ethics and strives for transparent relationships with suppliers. The procurement policy is developed on the basis of the best market practices. The main regulatory provisions are the “Principles for purchasing goods and services”, “Procedures for purchasing goods and services at the Bank” and the “Procurement policy” updated in 2021. The policy takes into account the most important aspects of the procurement of goods and services at the Bank, offers the possibility of applying ESG criteria, and refers to the best business practices. It also sets strategic objectives for the procurement process.

Relationships with suppliers are built on the basis of honesty, transparency of action, mutual respect and professionalism, including, in particular, through:

  • honouring the accepted arrangements and obligations;
  • making payments and settling other liabilities in a timely manner and in accordance with the contractual terms;
  • resolving difficult situations and conflicts through dialogue;
  • verifying suppliers solely on the basis of merit and business considerations;
  • informing suppliers about the standards of conduct;
  • efficient communication with suppliers at every stage of the procurement process.

In 2021, in carrying out the procurement process the Bank analysed the situations which could cause a potential conflict of interests. During the approval of a request for proposals the employees handling the procurement process confirm the absence of a conflict of interests, whereas the request for proposals is accompanied by information for the suppliers: a map of the conflict of interests and a conflict of interests declaration form. The suppliers are obliged to disclose all situations/relationships which cause or could cause a conflict of interests in the future, with the bid. If such circumstances arise, at each stage of the procurement process, among others, after the bid has been submitted, at the stage of signing the contract or afterwards, the affected bidder or supplier is obliged to submit a declaration on the conflict of interests immediately.

The Bank and other entities of the Bank’s Group approach the issue of settling their liabilities to suppliers in a timely manner with due care and diligence. In 2021, the value of invoices paid late, on which interest was charged as a result, constituted a marginal percentage of all the invoices paid. The list does not include payments in the case of which the delay (if any) was agreed with the supplier, because the collection of this information would be excessively laborious.

Share of the value of invoices on which interest was paid in the total value of invoices paid

BANK GROUP
2021 2020 2019 2021 2020 2019
Share in total value of invoices (%) 0.003 0.009 0.001 0.022 0.017 0.024

Suppliers interested in entering into cooperation with the Bank may register at the ‘PKO Zakupy’ procurement platform on their own. Each supplier must be approved by an employee of the Procurement Department. Suppliers who have been approved may take part in procurement proceedings.

The Bank and the Companies of the Bank’s Group have an impact on the suppliers with respect to socio-environmental issues at the stage of each request for proposals sent. In accordance with its content, when joining in the procurement proceedings, the suppliers must declare that, throughout the supply chain, they are guided by the overriding principle of respecting the law, a sense of justice and social responsibility and they understand the influence exerted by their activities on the natural environment, their surroundings, the other party, their employees, co-workers, subcontractors and business partners, and they are guided by the principles of ethics.

The subsequent part of the statement contains detailed declarations regarding:

  • ensuring safety in the workplace;
  • being guided by cooperation, trust, and a responsible and partnership approach to the other party;
  • compliance with the rules on working time and remuneration for work;
  • respect for human rights;
  • counteracting corruption;
  • protecting the natural environment.

The updated Procurement Policy of the Bank takes into account ESG-related aspects, among other things, it defines the strategic objectives of the procurement organization in this regard. These objectives include, among other things:

  • conducting ESG surveys among key suppliers;
  • drawing up a Supplier Code of Ethics which takes into consideration primarily occupational safety guarantees, prohibition of child labour, environmental protection, data privacy and security, prevention of corruption, managing conflicts of interests, etc.

In 2021, the Bank retained the Procurement Excellence certificate obtained in 2016. The Certificate is a quality mark awarded by the Chartered Institute of Procurement and Supply (CIPS), the largest procurement organization in the world. The certificate renewal process was completed in February 2021.

At present, PKO Bank Polski S.A. is the only financial institution with this certificate in Poland and the entire Central and Eastern Europe. The Procurement Excellence certificate is a globally recognized distinction awarded to organizations which demonstrate the highest standards of procurement processes.

[414-1] In 2021, all new suppliers (326) were verified by the Bank in terms of social criteria.

[414-2] The Bank did not record any negative social effects in the supply chain.

Product compliance risk

In terms of the products offered, PKO Bank Polski S.A. and the PKO Bank Polski S.A. Group pursue a policy which is to ensure: compliance of the products with the applicable regulations and their correct labelling. The scope of this policy at the Bank and in the Bank’s Group encompasses the stage of formulating a product offer, the presentation of the product to the Customer, the purchase (i.e. signing the agreement) and the stage of the product being used by the Customer. The principles and mechanisms of pursuing the compliance policy and appropriate labelling of products apply to the Bank and the entire Bank’s Group.

The Bank and the Bank’s Group make every effort to ensure that the products offered meet the requirements set out in the legal regulations and the accepted market standards. These efforts are focused on ensuring that:

  • the products offered are adequate to the needs of the Customers to whom they are addressed;
  • the manner and proposed form of the purchase of products are adequate to their nature;
  • before concluding the agreement, Customers are provided with reliable, transparent and comprehensive information about the product, in particular its nature, design, conditions, benefits and risks, as well as fees, commissions and other costs related to the conclusion, performance and potential early termination of the agreement (in a manner comprehensible to an average person).

These rules apply to all entities of the Bank’s Group, as well as the enterprises which the Bank has entrusted with the performance of specific operations related to the sale or handling of products.

As part of ensuring compliance of the products with the regulations, the Bank manages the misselling risk at the stage of product development and launch, and then at the stage of offering the product to Customers. Each product undergoes a pre-implementation analysis with regard to the risks it generates and the identification of target Customer groups. The Bank also identifies the groups of Customers to which the Bank should not offer the purchase of a given product because of its inadequacy to the Customer’s needs or for other reasons (the so-called anti-groups). If there are any anti-groups, control mechanisms are implemented to mitigate the misselling risk. The misselling risk is also mitigated at the stage of commencing the sales activity – before offering the purchase of a specific product to a Customer, it is assessed whether a given product is adequate to the needs of this type of Customer (in order to eliminate the cases, for example, of selling unemployment insurance to pensioners or long-term investment products to elderly persons). Additionally, the Bank always provides reliable and exhaustive information to Customers about the products offered so that they can make an informed choice in this regard. The Bank informs Customers about both benefits and risks arising from the purchase of the individual products.

The Bank considers any irregularities reported by the Bank’s Customers (in particular complaints) within the deadlines arising from the legal regulations. Depending on the findings, the Bank takes measures to eliminate such irregularities, prevent their occurrence in the future and improve the quality of service.

Similar solutions concerning misselling risk management, in keeping with the principle of proportionality, are also in place in the other entities of the Bank’s Group which develop or sell financial products.

[417-1] The Bank’s Group, including the Bank, fulfils the requirements concerning correct labelling of banking and investment products by providing the Customers with all the necessary information about them, especially at the pre-contract stage.

The scope of information provided about the products is specified in the applicable legal regulations and the recommendations of the PFSA. The general rule is that the highest level of protection is available to retail Customers – consumers. This information is formulated in such a way that it is comprehensible to the so-called “average consumer” within the meaning of the Act on counteracting unfair market practices, i.e. a consumer who is sufficiently well-informed, attentive and cautious; whereas the scope of the information provided to financial institutions and other professional buyers of financial products and services is narrower.

Proper product labelling also covers the Bank’s advertising messages which support its sales activities and shape its brand image. All marketing materials published by the Bank take into account the specific obligations arising from the legal regulations (e.g. the Consumer Credit Act – as regards the advertising of such loans) as well as market standards and the PFSA guidance formulated in the adopted “Rules of advertising banking services”.

Society Human rights
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