§ 1 Objective of the Information Policy
The Export Credit Insurance Corporation (hereinafter referred to as “KUKE S.A.”), fulfilling the mission of creating safe and stable operating conditions for Polish entrepreneurs by insuring export and domestic transactions and facilitating access to external financing, fosters full transparency and the utmost usefulness of the information provided.
The status of the national insurance agency and of export credit agencies (ECAs), as well as the market position of KUKE S.A. as the only insurance institution in Poland offering financial instruments guaranteed by the State Treasury and an entity belonging to the Polish Development Fund Group requires large-scale actions to be taken to satisfy information needs in the scope of financial instruments and other services offered to entrepreneurs. To this end, KUKE S.A. has established an Information Policy (hereinafter referred to as the “Policy”) that sets out the rules related to providing information and answers to all stakeholders, including shareholders, clients, and the media, as well as to the competent authority responsible for the supervision of the regulated market and to business partners.
In implementing the policy, KUKE S.A. is required to observe and protect insurance secrecy and business secrets.
§ 2 Organisation of the Information Policy
The policy was introduced pursuant to § 31 of the “Rules on Corporate Governance for Supervised Institutions" issued by the Polish Financial Supervision Authority on 22 July 2014 (hereinafter referred to as the “Rules on Corporate Governance”).
The Policy is adopted by a Resolution of the Management Board of KUKE S.A. and the activities pursued on the basis of the Policy are entrusted to the relevant organisational units of the Company.
§ 3 Bulletin of Public Information (BIP)
As an entity required to provide public information pursuant to the Act on Access to Public Information of 6 September 2001 (hereinafter referred to as the “Act”), KUKE S.A. makes available information to the public relating to the Company in line with the aforementioned Act, inclusive of posting the said information available on the Bulletin of Public Information (Polish: Biuletyn Informacji Publicznej, BIP) home page as well as on its own website.
§ 4 Method of Communication and Making Available Information on the Offer and Current Activities
The Company particularly uses the following information channels and forms of communication in the implementation of the Policy in the scope of providing information about KUKE S.A. and its activities:
- KUKE S.A. website;
- Information services and other social media;
- Materials and information concerning the product offering, client bulletins;
- Conferences and thematic seminars, trade fairs, exhibitions, and other events organised by KUKE S.A. or external partners;
- Press conferences, press releases and interviews in the media.
The Department of Communication and the Director of the Department of Communication who simultaneously exercises the function of the KUKE S.A. Press Spokesperson provide current information to media representatives. The task of the Press Spokesperson also includes answering the questions of media representatives concerning the current activities and plans of KUKE S.A., as well as the preparation of press releases and information, answering the questions of journalists, and participating in meetings with the representatives of the mass media.
§ 5 Scope of Information Posted on the KUKE S.A. Website
The main site for making information on KUKE S.A. available is the KUKE S.A. website: https://kuke.com.pl.
The scope of information that KUKE S.A. makes available on their website particularly includes:
- Information on the specificity of KUKE S.A. as an ECA;
- The legal grounds for its activities;
- Information on the Company bodies and Shareholders;
- Organisational structure;
- Statements and reports on activities;
- Information and the offer concerning the execution of tasks set and its own activities;
- Information and the offer in the scope of supporting government and local authority programmes;
- Information on international cooperation, including with foreign ECAs;
- Information resulting from the implementation of the environmental policy subject to the OECD Council Recommendation;
- Information on the actions being undertaken resulting from the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions;
- Information on the OECD Council Recommendation on Bribery in Officially Supported Export Credits;
- Information on the application of Corporate Governance;
- Information on the order of complaint procedures;
- Press releases and news;
- Conferences and other events organised by KUKE S.A.;
- Contact information (including contact details for the media);
- Bulletin of Public Information in the scope of specific information obligations;
- Information Policy.
§ 6 Making Available Reports Required by Law and Information on Activities Guaranteed by the State Treasury
The Company makes available the Solvency and Financial Condition Report of KUKE S.A. within the prescribed time limits and in accordance with the applicable laws, and makes available and posts the information required by law related to the solvency and financial condition of KUKE S.A. on the KUKE S.A. website which are available for a period of at least 5 years from the time of their publication. Along with the Solvency and Financial Condition Report (hereinafter referred to as the “SFCR”) that KUKE S.A. posts in compliance with the disposition of Article 284 of the Act on Insurance and Reinsurance Activities of 11 September 2015, the Company discloses the statistical data concerning the out-of-court proceedings mentioned in Chapter 4 of the Act on the processing of complaints by financial market entities and on the Financial Ombudsman of 5 August 2015, pursuant to Article 288 of the Act Insurance and Reinsurance Activity.
Pursuant to Article 290, item 3 of the Act on Insurance and Reinsurance of 11 September 2015, KUKE S.A. publishes the statutory auditor’s report containing the opinion of the statutory auditor who carried out the audit of the Solvency and Financial Condition Report.
KUKE S.A., apart from the information required by the provisions of the law in relation to the SFCR, discloses general information as to the fact that activities guaranteed by the State Treasury are being carried out pursuant to the Act on Export Insurance Guaranteed by the State Treasury of 7 July 1994 in the “Report on Activities of KUKE S.A. in the Scope of Export Insurance Guaranteed by the State Treasury” and, in the SFRC, discloses the balance of commission and costs related to carrying out such activities. Additionally, the Company publishes the Annual Report in which it discloses, among others, the results of KUKE S.A. in the scope of specific fields of activities, financial performance, new insurance solutions, and other significant information.
Furthermore, KUKE S.A. includes information in the SFCR that the cash held on the separate bank account used for handling the activities guaranteed by the State Treasury is not factored in to the calculation of the capital requirement pursuant to the rules of the Solvency II regime.
§ 7 Information Principles for Clients
The Company communicates with Clients using the form on the website, electronic communication, written communication or telephone communication. Communication with Clients is carried out through selected organisational units, pursuant to their competencies.
The Clients of KUKE S.A. may use the website intended for the exchange of information between them and KUKE S.A., enabling the performance of online services and other activities, access to which is possible through the Company website.
In the insurance distribution process, the Company ensures that the Clients are properly informed about the offering and fosters the highest possible level of services as well as the highest level of competences of the persons carrying out the distribution and agency activities and those responsible for the training of insurance brokers.
Information concerning the products offered by KUKE S.A. in the scope resulting from the provisions of the law and the guidelines and recommendations of the supervisory body are available on the KUKE S.A. website: https://kuke.com.pl/rozwiazania.
KUKE S.A. also communicates with Clients through advertising and information materials. The information materials conveyed to Clients are phrased in an unambiguous and reliable manner that does not raise any doubts as regards their interpretation and does not contain any misleading information. Advertising or marketing materials are clearly labelled as such.
When preparing the information and advertising materials, the Company is guided by the principle of the fair and competent provision of information about products. Information and advertising materials concerning the products and services offered by the Company are prepared and made available in accordance with the applicable provisions of the law and in line with the rules of fair competition.
KUKE S.A. ensures Clients have access to information materials in paper, electronic or any other form agreed with them, including to the provisions of the concluded insurance agreement.
§ 8 Complaint Processing Rules and Time Limits
Excellent customer services constitute a priority for KUKE S.A., hence, all complaints are thoroughly analysed and investigated so that the products and the handling processes meet the highest requirements of Clients. Complaints related to services rendered by KUKE S.A. can be filed by:
- Telephone using the Infoline No. +48 22 108 99 70;
- Electronically, via the online form on the KUKE S.A. website: (https://kuke.com.pl);
- Mail, to the postal address of the head office of KUKE S.A. or a Regional Sales Office of KUKE S.A.;
- Orally or in writing during a visit to the head office of KUKE S.A. or the Regional Sales Office of KUKE S.A.
Every complaint should contain information that will help identify its author (company name, telephone number, and email address). Where possible, the complaint content should also include the Policy/Claim number that the complaint concerns, which will ensure a streamlined and efficient course of the complaint handling process.
The Company responds to complaints without undue delay, however, not later than within a term of 30 days from the day of receiving the complaint. Confirmation of complaint receipt is sent at the Client’s wishes.
If the granting of a response within the term specified above is not possible, the Client will be notified on the reasons for the delay, the circumstances subject to further clarification, and on the expected date of providing a response within a term of up to 30 days from the date of receipt of the complaint, however, not later than within a term of 60 days from the date of receipt of the complaint.
The Client will receive a response to the complaint in writing, sent by registered mail or, at the request of the complainant, in electronic form to the email address provided.
Once the complaint procedure has been exhausted, the dispute may be submitted to out-of-court dispute resolution and, in the case of natural persons, to the Financial Ombudsman (detailed information and contact details are available on the following website: https://rf.gov.pl). The Financial Ombudsman is entitled to conduct proceedings for the out-of-court settlement of disputes between the client and the financial market entity mentioned in the Act on the processing of complaints by financial market entities and on the Financial Ombudsman of 5 August 2015.
In the event of the claims resulting from the complaint not being accepted, the Client may also bring an action against KUKE S.A. to an ordinary court of general jurisdiction, or to the court with jurisdiction over the place of residence or registered office of the insurer, policyholder or beneficiary under the insurance agreement. In the case of agreements for the granting of guarantees, the action may be brought before a court resulting from the agreement.
A claim that does not constitute a complaint may be filed in any manner (in writing, orally or electronically) in a form that permits the identification of the filing person and the subject of the claim that does not constitute a complaint.
In the scope of insurance and reinsurance activities, KUKE S.A. is subject to the supervision of the Polish Financial Supervision Authority; whereas, in the scope of activities guaranteed by the State Treasury, it is subject to the supervision of the Minister competent for economic affairs.
§ 9 Out-of-Court Resolution of Disputes
KUKE S.A. strives to amicably settle any disputes with its Clients. An out-of-court resolution of a possible dispute is possible at the request of the Client.
§ 10 Information Principles for Shareholders
In view of the shareholding structure (the shareholders of KUKE S.A. are the State Treasury represented by the Minister competent for economic affairs and Bank Gospodarstwa Krajowego), informing the Shareholders and transmitting information intended for Shareholders is carried out directly, in accordance with the provisions of the Commercial Companies Code and, among others, by posting it on the Company’s own website, in the place designated for communication with Shareholders, and all announcements coming from the Company required by law or the Statute.
The Company ensures equal access to information for Shareholders and provides information to Shareholders in accordance with the principles set out in the Statute or the universally applicable provisions of the law, guided by the developed best practice actions in the scope of mutual cooperation, the guidelines specified in the Rules on Corporate Governance, as well as the guidelines of the Shareholders, without undue delay or within the time limits provided for in the universally applicable provisions of the law, in electronic or written form, at the choice of the Shareholders.
§ 11 Protection of Personal Data
KUKE S.A. attaches the utmost importance to respecting the rules of law in the area of personal data protection:
- The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (General Data Protection Regulation, OJ. EU. L.2016.119.1);
- The Act on the protection of personal data of 10 May 2018 (unified text, Journal of Laws of 2019, item 1781).
Personal data is processed at KUKE S.A. in order to fulfil its statutory tasks and objectives and secondary purposes, and only to the extent that is strictly necessary.
The disclosure clauses applied by KUKE S.A. concerning the processing of personal data are available on the following website: https://kuke.com.pl/en/processing-of-personal-data.
§ 12 Final Provisions
This Policy is updated immediately after any amendments have been introduced in the provisions of the law and in the procedures and standards affecting it. The Director of the Department of Communication is responsible for updating the Information Policy.
28 October 2021