Anticorruption

In order to comply with the key anticorruption rules in the KGHM Polska Miedź S.A. Group and in the companies of the KGHM Polska Miedź S.A. Group located in Poland and abroad, in 2020, the Management Board of KGHM Polska Miedź S.A. adopted a resolution to implement the Anticorruption Management System in the Divisions and Head Office of KGHM Polska Miedź S.A. and in the Subsidiaries in accordance with the PN-ISO 37001:2017 standard. In connection with the implementation of the ISO 37001:2017 standard, in 2021 the KGHM Polska Miedź S.A. Group adopted the new Anticorruption Policy. The implementation team prepared, including updating of the existing and development of new anticorruption regulations consistent with the requirements of the standard.

The basis for the Anticorruption Management System is Corruption Risk Management, which is based on identification and assessment of corruption risks in individual processes pursued by Group entities. The accepted procedures regulate the corruption risk management process in the Group, which includes management of corruption risk related to Supervised Organisations and Business Partners. They define detailed standards of handling corruption activities, including conflict of interest, giving and accepting business gifts, contacts with public officials or events that may constitute corrupt offers. They also define the liability for violating the Anticorruption Policy and anticorruption regulations.

Employees are prohibited from offering or accepting any material benefits in relation to the performance of professional duties. The only exception is giving and accepting business gifts in line with the local norms and cultural customs, provided that the giving and accepting of gifts cannot lead to a situation in which such behaviour could be considered as an attempt to exert pressure or persuade the recipient to act against their duties. Detailed rules pertaining to giving and accepting customary business gifts have been defined in the Procedure of Handling Actions of Corruptive Nature.

Business transactions in the procurement, sales and investment processes, including an option of a third party audit, in order to ensure that such transactions meet the highest standards of ethical and transparent business operations are subject to special control (due diligence of business partners). The reviewing of business partners, including in terms of corruption risk and possible conflicts of interest, is conducted in accordance with the “Procedure of review in procurement, sales and investment proceedings” implemented in 2019 and pursued by the Security Department at KGHM Polska Miedź S.A. An amendment to the aforementioned procedure was developed in 2022, which was positively reviewed by the KGHM Group Council. Introduction of the amendment by Management Board decision is scheduled in the first quarter of 2023.

Every year, educational and information campaigns and competitions are organized, and publications are prepared for employees concerning ethics and corruption prevention.

Since 2018, regular security and loss prevention training has been organized, including the topics of corruption prevention and conflicts of interest, for employees of all KGHM entities. The training covers all newly hired employees in KGHM entities. All materials and instructions are readily available to Employees on the corporate Intranet site via a dedicated tab devoted to ethics and corruption prevention.

Regular meetings and training sessions are also organized for the Ethics and Anticorruption Representatives (40 persons). In 2022, 9 such training sessions were held in the KGHM Polska Miedź S.A. Group in the scope of implementation of the AMS compliant with PN-ISO 37001.

In February 2022, due to the implementation of the Anticorruption Management System and introduction of new regulations, the e-learning courses on ethics, prevention of irregularities in the company (in particular corruption, abuse, discrimination) and accepting reports from Whistleblowers, which had been in force until then, were suspended. In 2022, activities aimed at creating a new online course, scheduled to be launched in the second quarter of 2023, were carried out.