Ethics and values

GRI: 102-16
GRI: 102-17
GRI: 103-2
GRI: 103 1,2,3
GRI: 205-2
GRI: 415-1

Our values comprise moral standards, business ethics and culture, innovative solutions and social responsibility, reflecting the way the Grupa Kęty S.A. Capital Group operates

Michał Malina

Business Ethics Ombudsman of the Capital Group of Grupa Kęty S.A

The ethical processes at our organisation have been constantly developed. The changing business culture, increased standards with regard to respecting human rights or corruption prevention obliged the Capital Group of Grupa Kęty S.A. to apply even higher diligence with regard to building professional and ethical business. The ethical area is supervised by the CSR Director (division of the General Director) and the Business Ethics Ombudsman. They submit their proposals of actions for the popularisation of the Code of Ethics and corporate culture to the Steering Committee for Sustainable Development and Corporate Social Responsibility, based on the ethics and respect for the generally assumed values, as well as initiate and participate in the process of creating training schemes in the areas related to ethics and the organisational culture of the Capital Group of Grupa Kęty S.A. Additionally, in each business segment the Business Ethics Committees have been appointed. In 2021, the process was joined by the total of 17 people (Ethics Committees at the Segments, the Business Ethics Ombudsman, and the CSR Director). The work of the Business Ethics Ombudsman at the Grupa Kęty S.A. Capital Group as well as participation in the work of the Business Ethics Committees are social functions performed free of charge.

OUR

The Capital Group of Grupa Kęty S.A. runs business in accordance with the highest ethical standards, following a developed system of values based on professionalism, ethics and mutual respect.

The organisation uses documents, policies and detailed procedures defining the ethical issues and ethically sensitive processes. The most important among them is the Code of Ethics, i.e. the Principles of Business Ethics and Conduct at the Capital Group of Grupa Kęty S.A. The document comprises the basic standards commonly accepted by the companies of the Capital Group of Grupa Kęty S.A. It regulates the approach of the company and its employees to such areas as the market, environment, local communities and internal relations. The Code of Ethics clearly defines and governs the organisation’s approach to the participation in public life, by way of the following declaration: ‘We maintain transparent relations with local government officials and representatives of the political stage, free from corruption and improper pressures’.

Read also:

Catalogue of procedures and policies

In 2021, the Company did not make any donations to political parties.

A policy related to the Code of Ethics is the Anti-bribery Policy, which presents our approach to the subject of corruption. As stated in the Policy, Grupa Kęty objects any activities having the hallmarks of corruption, and actively prevents corruption occurrence. Our activities and decisions always comply with law, and any decisions regarding cooperation are solely based on subject-matter grounds. The purpose of the introduced policy is to limit the risk of corruption occurring both in external and internal relations of the Company. This refers to all employees of Grupa Kęty and its subsidiaries, as well as people and entities acting on their behalf and for their benefit.

In 2021, the Company-created training courses in preventing corruption, legal liability and documents binding at the organisation had continued. The training was completed by all managerial staff (directors and managers), as well as employees participating in corruption-sensitive processes. Unfortunately, we may reliably report only 27 people, as the other participants have not been included in the post-training report due to an error in the IT system. The error has already been removed, and in the 2022 report the number of the people trained in that area will be much higher, as this is an annual, cyclical training at our organisation. We have a broad perception of the ethical issues – the Company also has a series of binding procedures and policies. The ethical issues fall within the competence of all business areas of the organisation. There are also other documents, including:

Diversity Policy and Procedure
Respect for Human Rights Policy
Risk Management Policy and Procedure
Internal Control Procedure
Internal Audit Procedure
Ethical Business Principles Procedure
Code of Conduct for the Suppliers Procedure

Reporting Intercompany Transactions Procedure
Transfer Pricing Procedure
Procurement Procedure
Human Resources Policy and P
Human Resources Policy and Procedure
Supplier Contracts Procedure

The provisions of the Code of Ethics binding at the Capital Group reflect a method for reporting official breaches and a possibility to share any doubts regarding behaviour – messages may be submitted through a number of channels: directly to the Business Ethics Ombudsman, in the form of a letter, or e-mail sent to a special e-mail address – all these channels are listed in the Code of Ethics. The Company does not operate any separate helplines or hotlines, but there is an electronic channel enabling direct contact between the employees and the appointed Member of the Management Board.

In 2021 the Business Ethics Ombudsman received no reports on the Code of Ethics violations with regard to human rights infringement. In 2020 the situation had been the same. By way of vigilant monitoring of processes, we consider critical the following situation regarding risk monitoring: Risk of non-compliance with the principles of ethics, resulting in non-ethical culture of the organisation and claims on account of breaching the Code of Ethics. The ERM Team responsible for the risk is going to analyse the current internal and external blockers (risk limiting actions), and consider the improvement of communication.

For us, the ethical issues comprise also the aware use of natural resources and care for the well-being of future generations. In the 2021-2025 Strategy we put great emphasis on the environmental and climate-change prevention aspects. ‘We assume full responsibility for the influence of our actions on the environment. We abide by the ecological limitations imposed by legal regulations. We concentrate on searching for solutions, which eliminate the negative impact at its source. We invest in research and development as well as searching for environmentally-friendly technologies’, this is one of the clauses of our Code of Ethics. In the ‘Environmental Responsibility’ chapter, we present our commitments and actions taken for the protection of the natural environment in more detail.

In 2021, we also commenced the process of broader impact of the Grupa Kęty S.A. Capital Group with regard to responsibility within the supply chain. For that purpose the Company issued the Code of Conduct for the Suppliers. The code specifies the major requirements for the suppliers of the Capital Group of Grupa Kęty S.A. with regard to running ethical and fair activities, ensuring safe and hygienic working conditions, respecting human rights, assuming liability for the quality of products and for the natural environment. The progress in applying the document at the suppliers’ has been presented in the ‘Supply Chain Characteristics’ chapter.

In 2021, the Company carefully monitored the legislation process with regard to the Act on the Protection of Persons Reporting Breaches of Law. The process has not yet ended, therefore, the Company continues the organisation preparation to the new regulations on the basis of the current bill.

We have been preventing the conflict of interest and have introduced a Policy in that regard, in which we present the methods of prevention, identification and solving the conflict of interest, as well as the principles of excluding policy-subjects from the participation in considering a matter related to or threatened with a conflict of interest.

ESG management

Supply chain