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We play fair - „we have the suitable qualifications and tools to discharge our obligations in respect of our clients. That enables us to give them accurate and comprehensible information regarding our offer and products. Let’s do our best for this knowledge not to mislead anyone. We articulate transparent and unambiguous model contracts and advertising materials. Contacts with clients are based on trust.

Let’s remember that when doing our professional duties we are always acting on behalf of the PZU Group. If a client loses trust in us, then further cooperation may be called into question. We are obligated to treat all clients equally. Service should not be denied to anyone, nor should the provision of information or explanations. We approach aftersales service with an equal amount of professionalism.”

Michał Lutostański“The PZU Group is an insurance leader in Poland which offers comprehensive protection to clients in key areas of life and business. We are a modern company that is changing with our thoughts concerning the millions of Poles who have placed their trust in us and entrusted their most important affairs to our care. We do not want to lose their trust. That is why in our communication we endorse the most important brand values such as safety, professionalism and trust. These are the fundamental values that inform our marketing efforts”.

Michał Lutostański, Director of Marketing

PZU Group’s policies [Accounting Act]

[GRI 103-2]

Product liability in the PZU Group assumes an exceptional form: the priority in every offer is client safety understood in a broad sense. Our corporate value embodied by “We play fair” is not an empty slogan. Rather, it is translated into the daily practice of thousands of people who work in this Group. In accordance with the “PZU Group Code of Best Practices”, we apply transparent rules in communication, keep our undertakings and the client can always rely on us.

[G4-FS15]

Policies for the fair design and sale of financial products and services

All Group products and services are meticulously checked by experts before they can be proposed to clients. Lawyers and employees of the Compliance Department ensure that no clause in any agreement violates client interests, and that the entirety is compliant with current case law regarding consumer rights.

The transparency of the Group’s insurance products is ensured by the provisions of the Insurance Distribution Act of 15 December 2017 which entered into force in 2018 and was later amended. The Act is the effect of implementation into the Polish legal order of Directive (EU) 2016/97 of the European Parliament and of the Council of 20 January 2016 on insurance distribution (Insurance Distribution Directive).

PZU has in place a „Procedure for developing, modifying and withdrawing products supervised by the Mass Product Department”. The procedure stipulates that the product manager prepares draft General Terms and Conditions of Insurance (GTCI) and rate tariffs which he/she agrees on, together with the resolutions introducing them, with relevant units, according to the legislative process in place in the company. Then, based on the agreed GTCI, the product manager drafts or modifies the document containing key information on the product (IPID, Insurance Product Information Document), taking into account the product complexity and client type (requirement from Article 8 of the act on insurance distribution) for all PZU products.

PZU Życie, in turn, has a „Procedure for developing, implementing and modifying individual protection and unitlinked products and individual and group insurance-based investment product managed by the Product Development Department”. The Product Development Department (BRP) prepares and consults the detailed scope of product information. Then, in accordance with the provisions of law, guidelines and recommendations of the regulatory authority, the GTCI are prepared together with the so-called product card, i.e. objective information on the product. Thanks to it, clients can made more considered decisions and purchase insurance cover that best corresponds to their requirements. In the cases when this is required by the „Procedure for review and amendment of Key Information Documents” also a document with key information on the product, i.e. KID is prepared.

BEST PRACTICE

The PZU Group wants for its clients to invest and insure themselves in a responsible manner – to make deliberate decisions with a grasp of the risk and costs related to the products they purchase. Therefore the company fully satisfies the norms of the Commission Delegated Regulation (EU) 2017/653 of 8 March 2017 supplementing Regulation (EU) No 1286/2014 of the European Parliament and of the Council of 26 November 2014 on key information documents for packaged retail and insurance-based investment products (PRIIP) through establishing regulatory technical standards regarding presentation, content, review and change of documents comprising key information and the conditions for satisfying the requirements regarding provision of such documents. That is why the company conveys important information from the client’s viewpoint in an understandable fashion. The Key Information Document (KID) accompanies all products for which this is required according to the regulation, chiefly insurancebased investment products and endowment insurance policies. This is a standardized information sheet giving clients the ability to compare with ease products offered by different insurance undertakings. This sheet is mandatorily forwarded to clients when presenting an offer. It can be found on the product pages of the pzu.pl portal.

TUW PZUW carries out regular reviews of the existing products and services (including those offered by third parties) to assess whether they still bring benefits to consumers or have negative effects. In the first quarter of each year, TUW PZUW prepares collective information on satisfaction of clients’ expectations regarding individual products, analyzing in detail complaints, if any, processing problems and drawbacks involving lack of precision and clarity in the contracts. Monitoring is the basis for preparation of an assessment of adequacy and introduction of increasingly better solutions. This is also supported by the annual analysis of complaints from the perspective of the product and service and the applied procedures, and the findings and recommendations are reflected in a comprehensive report. On this basis TUW PZUW works out and regularly implements solutions aimed at further improvement of quality. The obligation to offer products responsibly in TUW PZUW is laid down in the scope of duties of the company’s Management Board.

In Bank Pekao, key regulations pertaining to this area as regards compliance risk assessment are: “Policy for New Product Implementation Process at Bank Pekao S.A.” and “Rules for developing marketing communication at Bank Pekao S.A.”
BEST PRACTICE

Alior Bank has in place the „Policy of preventing dishonest sales” intended to counteract the practice of misselling. The document lays down the rules that must be applied in the process of designing and distributing products. The product shelf has been reduced and selected offer elements may be distributed only by authorized channels (e.g. Private Banking) and employees who have the appropriate knowledge and experience. The sales processes are subject to regular monitoring for the threat of misselling. There are defined rules of handling identified misselling cases.

Also all foreign companies have appropriate procedures in place. AAS Balta, operating in Latvia, in addition to guidelines regarding communication with clients, applies a policy for identification of client needs and management of product changes and development. Lietuvos Draudimas in Lithuania, in turn, has a procedure for managing the launch of new services.
BEST PRACTICE
System for preventing grievances

The process of preventing grievances underpins responsible sales. Based on the conclusions drawn from complaints, all employees involved in examining complaints put forward to the Client Relations Department (the owner of the complaint handling process) complaints-related initiatives, or ideas on how to streamline and eradicate the sources of these complaints and client dissatisfaction. For this purpose, an appropriate tool has created: the Complaints-related Initiatives Database. The Client Relations Department is responsible for handling all submitted initiatives: verifying all submitted ideas, checking the reasonability of proposed changes with business owners, monitoring the progress of work and then reporting on the outcome of changes and their business impact.

In 2020, 107 complaints-related initiatives were developed (i.e. those that were reported based on requests derived from client complaints). In 2020, on the basis of the recommendations obtained in the Customer Journey project in the complaints area, a number of initiatives have been prepared to facilitate the complaint handling process and work organization and engagement of employees processing complaints.

[GRI 417-2, GRI 417-3]

From 2018, PZU and PZU Życie did not observe any failure to comply with regulations or codes concerning the labeling of products and services or marketing communication.

Responsible and understandable communication

One of the values laid down in the “Best Practices of the PZU Group” is honesty. It means that “we follow transparent rules for client communication”. PZU is the only insurer in Poland that has as many as four “Simple Polish Certificates”. This is a quality certificate awarded by the Institute of Simple Polish of the University of Wrocław.
Dorota Macieja, Członkini Zarządu PZU Życie“Using clear and understandable language is a condition of effective communication and good relations with the clients. PZU is a market pioneer in this respect. We have set up the Simple Language Department which makes sure that understandable language is a standard in our company. We simplify letters and client information, giving it graphically transparent form. Before sending an email or letter, our employees may check whether it has been written in accordance with the rules of simple language – everyone has access to a simple program which suggests an appropriate form. Also, we do not forget about training.”
Dorota Macieja, Member of the PZU Życie Management Board

A survey carried out in September 2020 by Norstat Polska has shown that PZU’s clients declare more frequently than other clients that they can easily find the information they need in the correspondence they receive and that the information is written using understandable language. This is the result of PZU’s consistent efforts to ensure understandable, clear and transparent communication with clients. The importance that PZU attaches to this area is confirmed by establishing the Simple Language Department in 2020 in place of the earlier team.

The Department performs its tasks, introducing language standards in communication with clients and in internal correspondence. It also develops letter templates, conducts numerous training courses for employees and promotes the principles of simple Polish during conferences, webinars and using internal communication channels: the PZU24 service, regular newsletters and the „Świat PZU” magazine. It is involved in external communication, promoting PZU as a company which attaches a lot of importance to ensuring that the information conveyed to clients is clear and understandable.

It cooperates with renowned academic centers: Institute of Simple Polish of the University of Wrocław and the Polish Language Institute of the University of Warsaw.

Tools and standards

PZU as the first insurer in Poland launched a special computer program „It is simple!” for analyzing texts from the linguistic perspective. Thanks to the program, PZU employees may check whether the texts they write do not contain incomprehensible phrases or whether the sentence they use is not excessively complicated and too long.

Understandable communication is also supported by:

  • „Simple language strategy at PZU”, i.e. a collection of universal rules applied in communication;
  • „Standards of correspondence with clients”, which sort out the templates of official communication with clients;
  • „Standards of internal correspondence”, which unify the existing form of communication within the company;
  • „Effective communication management policy”, defining the principles of communication with clients and within the organization along with the methods of their implementation and monitoring. The document supports consistency of communication between channels, processes or products, conscious management of interactions with clients, building positive relations with clients, improvement of client experience, and building and maintaining linguistic competences among employees.

Training courses and conferences

As part of the simple language workshops run by the authors of the Polish effective communication model, in 2020 over 400 PZU employees were trained. During the workshops they simplified complicated contents full of incomprehensible phrases from the language of finance.

A record-breaking number of over 1,600 PZU employees gathered at the annual Simple Language Conference. Linguists from the University of Warsaw and University of Wrocław, and customer experience specialists shared their knowledge and experience. Attendees were shown survey results according to which 89% of Poles expect companies to convey simple and understandable information and PZU ranks better than other companies in this respect.

The webinars organized by the Simple Language Department to share practical linguistic knowledge were as popular as the conference. At one of them participants learned how to speak to be understood from a well-known journalist, holding the title of the Champion of Polish Speech, Przemysław Babiarz.

Promotion in the media

The initiatives of the Simple Language Department brought around one thousand publications in the media which informed readers about the importance attached by PZU to simple and understandable communication with clients.

Some initiatives were unconventional. PZU’s joking spot „Down with the official tone!”, in which the use of understandable language was promoted by a singing bass-baritone singer from the Grand Theatre – National Opera in Warsaw, was shown by „Teleexpress” and the popular breakfast television program „Pytanie na śniadanie” on TVP. The spot reached approx. one million viewers through YouTube.

BEST PRACTICE

The PZU Simple Language Department, in cooperation with the Polish Language Institute of the University of Warsaw, undertook work on the publication of the „Encyclopedia of Simple Polish”. The prestigious publication will contain a dictionary of terms from the business and official language, prompt synonyms replacing the incomprehensible words and provide knowledge about simple Polish. The objective of the project is to promote PZU as a company which attaches a lot of importance to communicating with clients in a comprehensible manner.

Also cooperation with the popular YouTube channel „Matura to Bzdura” addressed mainly to youths was an innovative project. Its authors asked respondents in a street survey how much of the corpo-speech they understand and to what extent they can use simple language themselves. The episode created in cooperation with PZU entitled “How well do Poles speak Polish” had nearly 330 thousand views.

[GRI 417-1]

Internal requirements concerning the labeling of products and services and information regarding them

 All of the PZU Group products belonging to the four major product categories (life insurance, non-life insurance, health and investment products) satisfy the statutory requirements:

  • within the scope of general policy conditions: the PZU Group directly applies the Insurance and Reinsurance Activity Act. Additionally, the product development procedures refer to a clause on the mandatory preparation of general terms and conditions of insurance;
  • with respect to KID (Key Information Document) the PZU Group directly applies the PRIIP regulation and the product development procedure;
  • with respect to the Insurance Product Information Document (IPID), the PZU Group directly applies the clauses of the Insurance Distribution Act as well as the principles regarding the product management system and the product development procedure.

[G4-FS13], [G4-FS14]

Responsible network of salespersons

The PZU Group has created the geographically biggest financial services sales network in Poland. It also ensures high quality service.

The PZU sales and service network includes:

  • 410 branches with convenient access across the country with 189 in small communities;
  • 10 thousand tied agents and agencies;
  • over 3.2 thousand multiagencies;
  • nearly 1.1 thousand insurance brokers;
  • electronic distribution channels.

The PZU Group’s clients in Poland have also access to Bank Pekao’s distribution network (713 branches) and Alior Bank’s distribution network (674 branches, including 180 traditional branches, 7 Private Banking branches, 13 Corporate Banking Centers and 474 partner centers; additionally, at yearend 2020, Alior Bank had 51 branches in Romania). Both banks have professional call centers and mobile and internet banking platforms.

When it comes to bancassurance and strategic partnerships, the PZU Group collaborates with 13 banks and 21 strategic partners. The PZU Zdrowie network has approx. 2,200 partner and 130 own centers.

Cooperation with the banks within the PZU Group (Alior Bank and Bank Pekao) forms an additional platform for PZU to build lasting client relations. At the end of 2020, more than 9 thousand banking advisors (5.3 thousand in Bank Pekao and 4.1 thousand in Alior Bank) received the KNF license and had qualifications to sell PZU’s insurance products.

Structure of PZU branch network

The network of 410 standardized PZU branches is evenly distributed across Poland in carefully selected locations. PZU branches are the only distribution channel ensuring in each outlet comprehensive sales and aftersales service of PZU Group’s non-life, life and pension insurance and investment products. The offering in PZU branches is targeted at individual clients as well as businesses from the small and medium-sized enterprise (SME) segment.

Structure of the PZU tied agent network

Improvement of the professionalism and quality of customer service in the agent’s offices, and increasing their physical presence in the field are the priorities of the network development. Attractive equipment and marketing signage of the offices, training on service quality standards, substantive support for the sales teams and even financial support from PZU – all this helps agents to attain the highest level.

It is also important to universalize agents who sell the products offered by the PZU Group. They become professional advisors at each stage of the client’s life. As a result, clients may insure their property, buy medical and life insurance and take care of their pension – all from a single agent. Already now most agents running offices offer comprehensive client service regarding the products of the entire PZU Group and their offering is constantly expanded.

The leasing offering of the tied agents in cooperation with Pekao Leasing in 2020 was expanded by another PZU Group company – Alior Leasing. Agents offer car and property leases for machinery and equipment for the SME segment.

Agents offer also Individual Retirement Security Accounts (IRSA). In 2020, clients paid in over half a million zloty under agreements concluded via tied agents. Tied agents also take part in acquisition of Employee Pension Schemes. In 2020, they entered into nearly six thousand ECS management agreements for PZU TFI in Polish corporates.

Tied agents started to offer new products: PZU Cover for Farmers and PZU Thinking about Life and Health. Tied agents also obtained the possibility of insuring the entire family on a single policy.

In 2020, thanks to agents, over 380 thousand clients opened accounts in the mojePZU service, which is a convenient remote service tool. Agents may send an insurance offer to the client who will accept it, enter into a contract and pay for it without the need to meet in person.

Already more than 20 thousand clients of tied agents use the innovative solution PZU GO.

BEST PRACTICE

Portfolio Development Teams

The tied agent channel actively participates in all changes being introduced. To support these activities, two-person Portfolio Development Teams were appointed in each Sales Area.

As at the end of 2020, PZU had 1.5 thousand tied agent offices in Poland. However, over 3 thousand out of approx. 5.5 thousand tied agents had authorizations to sell PZU and PZU Życie products.

The agency agreement governs the fees of PZU agents. The principles are clear and transparent and ensue from the results of their work and engagement. The following make up their compensation:

  • commission specified in the agency agreement depending on the agent’s segment;
  • bonus for performing the sales contract (quarterly);
  • bonuses and awards earned in sales contests and campaigns.

Development training

The restrictions introduced due to the pandemic determined also the way in which agents were trained – all workshops were held remotely. In total, in 2020, nearly two thousand agents participated in 325 development training courses, including 82 courses organized for 480 persons as part of the Academy for Adepts.

Support during the pandemic

In 2020, due to the COVID-19 pandemic, agents received from PZU additional support which ensured safety both to agents and to their clients. PZU equipped their offices with Plexiglas screens, 7 thousand liters of disinfectant, 55 thousand facemasks and 168 thousand disposable gloves. Thanks to intensive promotion of the mojePZU portal, agents were well prepared for effective sales using this tool, which was particularly important in the initial phase of the pandemic.

BEST PRACTICE

PZU develops and promotes the agents’ online presence:

  • it sets up their websites, which we then put up on the www.agentpzu.pl website;
  • prepare Google “business cards”;
  • from 2020, PZU has also been offering Facebook profiles, co-managed by PZU. The visit statistics and information from agents confirm that these efforts help them reach a broader group of clients.

Statystyki odwiedzin oraz informacje od agentów potwierdzają, że działania te pomagają w dotarciu do szerszej grupy klientów.

Complaints and grievances

The „Principles for accepting, recording, examining and reporting the grievances submitted by clients”, together with guidelines determining the organization of the complaint handling process, are define precisely the whole procedure. These principles are an element of the product management system at PZU.

Complaint handling stages:

  • immediate examination of the circumstances of the case;
  • assessment of the viability of the issues raised;
  • taking a position;
  • ptaking actions to rectify identified omissions, if any;
  • replying the client and external institution if the institution lodged a complaint on the client’s behalf.
BEST PRACTICE

Grievances and complaints related to the work of agents are accepted by PZU in any form. Clients decide on their own whether they want to use a traditional letter, e-mail, form on PZU’s website or by phone with an employee or directly in a company outlet. No notification is examined by the unit or person to whom it directly pertains. The Complaints Handling Section specially appointed in the corporation’s structures deals with them. The employees of this section field each notification as quickly as possible. In standard cases clients wait for a response for no more than 30 days. In cases that are particularly complicated this timeframe is extended but does not exceed 60 days. If it finds that an agent has breached his or her duties, PZU may curtail the scope of the power-of-attorney extended to enter into insurance contracts, or terminate the agreement. In the event of serious breaches the Security Department is the appropriate unit to react.

144 grievances were submitted to PZU in 2020 against agents. 23 of them were recognized in full and 22 were recognized in part. These grievances pertained to improper employee conduct, giving incorrect information and the organization of an agent’s work. PZU Życie, in turn, received 37 grievances. 6 of them were recognized in full and 5 were recognized in part. These grievances pertained predominantly to failure to provide proper information on product characteristics and giving incorrect information.

Information about the causes of the grievances is analyzed also by the persons responsible for the areas to which they pertain. This is aimed at taking actions which may eliminate the causes of the complaints and their sources in the future. This applies in particular to product offer development, sales, distribution channels, external partner network (including cooperation with service providers and contractors), customer service, claims handling and marketing.

Responsible marketing communication

The PZU Group attaches a lot of importance to proper shaping of the brand image and the advertising message associated with the product offering. Consequently, it advertises its products and services responsibly, in accordance with the rules laid down in the “PZU Code of Ethics in Advertising”. The Code is a collection of additional standards, independent of the provisions of law and the guidelines of the Polish Financial Supervision Authority. All actions covered by the provisions of the Code should be compliant with the law and good practices, based on social responsibility, and consistent with the principles of fair competition.

The main rules in the Code:

  • advertising does not contain discriminatory contents, respects human dignity and does not challenge animal rights;
  • the message is not misleading and does not take advantage of the clients’ ignorance;
  • the data presented are true and documented.
BEST PRACTICE

PZU Code of Ethics in Advertising

The recipient of a proposal delivered as part of direct marketing has the possibility of identifying that the proposal is advertising. PZU does not present proposals which can be easily mistaken for a bill, invoice or similar document.

The Code also regulates the event sponsoring rules. It clearly stipulates that they may not infringe good practices, expose facilities of historical or artistic importance to harm, or exert negative impact on the natural environment.
BEST PRACTICE

The marketing activities are subject to opinions of the Legal Department and Compliance Department (for compliance risk, including with regard to compliance with the law – risk of misleading the consumer, use of messages infringing the addressees’ interests) and pertinent departments responsible for given products (consistency of the message with the facts – risk of misleading the consumer). Experts check, among other things, whether a given message entails a risk of PZU and PZU Życie suffering a loss of their good name.

The Legal Department’s opinions on marketing and communication activities are based on the principles set forth in separate internal regulations regarding the organization and provision of legal assistance in PZU and PZU Życie.

BEST PRACTICE
Action synergy

Caring for better understanding of the users’ purchase path, the number and quality of interactions with the PZU brand, products or services, and aiming to adapt the communication more effectively to the user, PZU implemented a new analytical and media platform. Thanks to the platform, all activities conducted as part of direct marketing are centralized. Data on the effectiveness of the advertising channels are collected in one place thanks to which they can be easily compared. Implementation of the platform make it possible to build user segments and create a communication strategy with an appropriate advertising message to specific segments

Responsible marketing communication is also supported by:

  • „Marketing Policy” which defines the aims, standards and principles of conducting marketing activity in the PZU Group. It focuses on ensuring consistency of all marketing activity and the message, as well as compliance with the prevailing provisions of law, in particular with the regulations on protection of competition and consumers and fighting unfair competition, as well as the guidelines of public authorities;
  • The „Rules for giving opinions on marketing activities and activities in internal and corporate communication”, which regulate the procedure for issuing opinions by the Compliance Department on marketing materials from the perspective of the compliance risk.

In Bank Pekao, key regulations pertaining to the marketing as regards compliance risk assessment are: „Policy for New Product Implementation Process at Bank Pekao S.A.” and “Rules for developing marketing communication at Bank Pekao S.A.”

BEST PRACTICE
Grab the Internet by the horns

In this unique year of 2020 marked by the COVID-19 pandemic, Bank Pekao as a leader of banking digitization, decided to launch an exceptional social marketing campaign entitled “Grab the Internet by the horns” aimed at building a new virtual dimension of social relations. The campaign, addressed to older persons and senior citizens, highlighted the possibilities and convenience offered by using the Internet and provided interesting informational and educational contents, including on the use of electronic banking.

The aim of the campaign was to educate and activate older clients (aged over 55) and engage their relatives in actions aimed at improving clients’ safety through, among others, making payments using online banking, using cashless transactions and limiting visits in bank branches.

In accordance with the prevailing laws, PZU Group companies are obligated to provide reliable and timely information regarding policies, events and claims paid in motor insurance to the Insurance Indemnity Fund. Due to an amendment of the act on mandatory insurance, Insurance Guarantee Fund and the Polish Motor Insurers’ Bureau, as of 13 November 2017, an obligation was introduced to send data on concluded TPL/MOD insurance contracts during the activity (~on-line) to the Insurance Indemnity Fund. Being aware that such data are used both in the company’s internal processes (among others for prevention of insurance fraud using an anti-fraud system), and in market solutions successively built using such data (among others integration with the Central Records of Vehicles and Drivers (CEPiK), analyzing the continuity of TPL or persons who are not insured), the PZU Group pays special attention to the quality, completeness and timeliness of transfer of the information in order to draw maximum business benefits and care for its image. The efforts of PZU Group employees are appreciated. For five years PZU has been ranking first in the IIF ranking of Insurance Companies.

In 2020, the ranking was divided into categories depending on the size of the company. PZU ranked first among companies which report high volumes of records (over 2 million) and second in the Leader Ranking with the ultimate ratio of 92.18% (increase from 90.80% in 2019). LINK4, in turn, with 90.82%, ranked second in the group of companies reporting a medium volume of records to IIF (from 280 thousand to 2 million records). The ultimate ranking is the function of, among others, the quality and completeness of the data, and timeliness of data transfer, and may amount up to 100%. The minimum acceptable level in the ranking is 80%.