Ethical standards in the KGHM Polska Miedź Group


The fundamental Ethical Standards are implemented through the principles of ethical conduct, which are described in the diagrams below:

Key Ethical Standards translating into principles of conduct in KGHM Polska Miedź S.A.

Division of ethical conduct rules

The communication and implementation of Ethical Standards in the KGHM Polska Miedź S.A. Group is facilitated by a system of codes, policies and procedures. Their implementation satisfies global corporate governance standards as well as the increasing expectations of our stakeholders, including our clients and financial institutions.

In accordance with the best corporate governance practices, we have adopted the following principles,policies and instructions, which introduce global, unified standards adapted to the laws applicable in alljurisdictions in which the KGHM Polska Miedź S.A. Group operates:

The Compliance Management Policy in the KGHM Polska Miedź S.A. Group serves as the framework of the compliance management system and an organisation-wide approach, based on recognised international standards and industry best practices. The adopted solution to the creation of the compliance system has been tailored to the specific nature of the Group and is an important business tool used to prevent the occurrence of events that could result in the imposition of sanctions. It enables the systematic identification, assessment and analysis of the risk of non-compliance or possible non-compliance with generally applicable law, internal corporate regulations and voluntarily adopted legal obligations and standards, including ethical standards, in order to design and implement actions to ensure compliance.

The purpose of the Competition Law Policy is to establish an operational framework for a system that will enable the maintenance of conformity with the competition law and is applicable in all the countries in which the KGHM Polska Miedź S.A. Group operates. Therefore, the Group undertakes an obligation to compete on the markets in a legal and ethical manner, as well as to prevent, counteract and detect violations in accordance with the applicable legal regulations.

The aim of the Procurement Policy is to establish the overarching principles that should be followed by all participants of the procurement process in the KGHM Polska Miedź S.A. Group, as well as the general regulations of this process. The Policy specifies supervision measures limiting the risk of irregularities in the procurement process.

The Anticorruption Policy establishes basic principles and standards, whose goal is to ensure compliance with the anticorruption regulations applicable in the jurisdictions in which the KGHM Polska Miedź S.A. Group operates and voluntary commitments to counteract corruption. The Group applies a zero tolerance policy towards corruption and bribery. The Policy includes a declaration by the top management of their full commitment to activities related to the maintenance and continuous improvement of the implemented Anticorruption Management System, compliant with the requirements of the PN-ISO 37001 standard.

The Responsible Supply Chain Policy is aimed at guaranteeing the selection only of responsible suppliers and at ensuring that the goods and services purchased by the KGHM Polska Miedź S.A. Group are not contributing to financing terrorism, and are manufactured or provided in accordance with basic human rights, labour standards, environmental protection and counteracting corruption.

The Security Policy sets forth joint principles and goals for the entities and organisational units of the KGHM Polska Miedź S.A. Group related to safety and preventing losses. Pursuant to its clauses, all of the Group’s employees act in accordance with basic principles: professional integrity, diligence in the discharge of professional duties, loyalty towards the employer, a results oriented approach, courage, teamwork, accountability, mutual responsibility for safety and preventing losses and avoidance of actions harmful to the employer.

In order to unify the approach to compliance defined as adherence to the requirements arising from existing laws (external and internal) or from voluntarilyassumed legal obligations and standards, since 2020 a Compliance Management Policy for the KGHM Polska Miedź S.A. Group together with a Procedure and Methodology for managing compliance in KGHM Polska Miedź S.A. as adopted by the Management Board of KGHM Polska Miedź S.A. has been in force. Possession of a coherent compliance system in the KGHM Polska Miedź S.A Group is a constituent of effective corporate governance management through, inter alia, more efficient response and readiness to regulatory changes, protecting reputation and building an ethical culture in the organisation, as well as increasing awareness and a sense of responsibility for compliance among employees. In 2021 activities related to improvement of the effectiveness of the compliance system were carried out, among others, in the selection of complementary IT solutions necessary for the implementation of the process. Support work and work aimed at raising the standards of compliance will be continued in 2022.

In order to improve the standards of maintaining compliance with the competition law, the Instruction of Conduct in order to prevent violations resulting from competition law, which is an extension and clarification of the content of the KGHM Polska Miedź S.A. Group’s Competition Law Policy updated in 2019, was approved by the Management Board of KGHM Polska Miedź S.A. and is in force from 2020. In December 2021, training was conducted for Local Plenipotentiaries for Competition Law in the KGHM Polska Miedź S.A. Group. Support work and work aimed at raising the standards of compliance with the competition law will be continued in 2022.

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