ESG Report

Ethics and compliance

Code of ethics, or the highest standards every day

  • 103-1
  • 103-2
  • 103-3
  • #10

Compliance and preventing corruption are the main area of responsibility for every company, including Allegro. This extends to our operations as well as all our employees and entities we work with on a daily basis.

In both our main companies, we have introduced a governance, risk and compliance management system, which includes standards of conduct, corruption prevention, competition law compliance, prevention of conflicts of interest, information and data protection, prevention of unlawful discrimination and protection of company property and know-how of Allegro.pl and Ceneo.pl.

We approach our risk management system very seriously and established a compliance framework as shown below to ensure that all necessary measures have been implemented:


  • Regulatory / Public Affairs
  • Risk Management
  • Policies
  • Training, communication, awareness sessions
  • Process integration
  • Lessons learned
  • Compliance implementation
  • Established responsibilities


  • Reporting:
    • anonymously or personally via system to CSO
    • personally to HR, Legal, CSO, Line Manager
    • personally via mail to Chairman
  • Controls
  • Monitoring and compliance approvals
  • Review controls and compliance audits
  • Internal audits


  • Crisis management
  • Business Continuity Management
  • Disciplinary sanctions
  • Remediation

Guidelines that include the procurement policy, tender procedure, controlling procedure and legal procedure have also been introduced and are intended to minimize all unauthorized practices, violations of the law, corruption and fraud, especially with regard to purchasing practices or other adverse consequences of non-compliance within the Group.

At Allegro.pl, we operate in a transparent manner and to the highest ethical standards, in particular thanks to our policies and regulations.

  • 102-16
  • 102-17
  • G-P2
  • G-P4

The Allegro Code of Ethics consists of:

  • Transparency Policy
  • Anti-discrimination and Anti-bullying Policy
  • Whistleblowing Procedures
  • Antitrust Compliance Policy
  • Anti-money Laundering and Countering Terrorism Financing Policies
  • Security Policy.

Allegro has introduced the following regulations and processes:

  • Anti-corruption Rules
  • Gifts and Benefits Regulations
  • Diversity Policy
  • Inspection Procedure
  • Agreements Procedure
  • Tax Governance Policy
  • Supplier Verification Procedure and Suppliers Code of Conduct
  • Training Policy
  • eu Charity, Social and Sponsoring Activities policy
  • Human Rights Policy
  • and more.

The Ethics Committee oversees compliance with the Code of Ethics, examining and resolving the reported violations. Composition of the Ethics Committee

  • HR Director or HR Business Partner
  • Head of Legal or a designated lawyer
  • Manager of the division the reported violation concerns
  • Representative of employees selected by the Employee Representation
  • Chief Security Officer (CSO).

The Code of Ethics is periodically reviewed and is available to employees

Being an ethical company also involves complying with the law. At Allegro, we operate within the law and we stay abreast of all relevant changes and industry regulations. We keep adjusting our services, policies and processes accordingly.

The Allegro whistleblowing system is available to the company’s employees and contractors. It is subject to the guidelines for handling complaints and grievances related to non-compliance with the Code of Ethics.

Reporting complaints and grievances  2021 2020 2019
Anti-money Laundering, Countering Terrorist Financing and Export Control Policy and Financial Sanctions Manual 0 0 0
Transparency Policy  2 2 2

The company has introduced mandatory training in compliance and ethics

An ethics and compliance training and communication plan has also been developed and is being implemented.

New employees get to know our Code during a session of the mandatory OnBoarding Stay Safe/Stay Fair training. Once a year, our employees participate in training on our Code of Ethics policies (Transparency Policy, Anti-Discrimination and Anti-bullying Policy, Whistleblowing Procedures, Antitrust Compliance Policy, Anti-money Laundering and Countering Terrorism Financing Policies, Security Policy) and personal data protection in order to improve their knowledge, build competence and raise awareness.

All employees are obligatorily trained on all policies during the onboarding session. All employees are required to adhere to the policies. Every year, we also provide obligatory training on the policies to every employee, including contractors. Ethics training is held through a number of channels, including e-learning, email, a dedicated internal platform (Intranet), meetings, posters, competitions and other forms of communication.

Whistleblowing and whistleblower protection

At Allegro, we have a whistleblowing system for reporting irregularities. It guarantees confidentiality and safety of the whistleblowers, including protection from retaliatory action. Our system is open and accessible for everyone in the company (notifications can also be submitted anonymously via a special form available online). It is subject to the guidelines for reviewing complaints and grievances against Code of Ethics violations.

We have launched a special online platform, introduced a dedicated online form and made a special email address and phone number available. Every notification is reviewed and acted on where appropriate. In 2021, we had two notifications concerning our Transparency Policy. We investigated both thoroughly and penalized the transgressing employees appropriately.

  • 205-2
  • G-P3

All employees are obligatorily trained on all key policies during onboarding training. All employees also sign a declaration where they undertake to adhere to the policies. Every year, we also organize mandatory training for all our employees.

  • 205-1
  • 205-3

At Allegro, we are well aware of the fact that the procurement process can create corruption risks. This is why procurement departments are screened for corruption risks and are subject to anti-corruption supervision. Not a single case of corruption was recorded in 2021.

We ensure the highest quality and safety of products offered on the Allegro platform, as well as service and delivery quality. We work very closely with UOKiK and local consumer advocates. In response to their specific needs, we have set up a dedicated email address that makes it easier for them to contact our employees.

  • 419-1

In 2021, Allegro was not subject to a single financial penalty or sanction for legal non-compliance or violating the rules governing supplies or the use of products and services.

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