We are guided by the principle of protecting the dignity of work, including in matters relating to fair pay, the right to rest and equal access to training. In the Company, we do not accept any form of violation of personal dignity and gender equality, including: discrimination, harassment, abuse and other actions that violate the rules of social coexistence. We combat all forms of modern slavery, forced labour and torture. The Company rigorously respects the prohibition on the employment of minors. Whilst protecting all rights relating to personal dignity, we also respect, protect and promote family and parental values (the right to live with family).
Table of contents
Human rights policy in KGHM S.A.
GRI
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2-25
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2-26
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3-3
In KGHM we pledge to protect, promote and implement human rights wherever we carry out our activities and towards all entities on which we have a direct or indirect impact.
On 27 April 2022, the Management Board of KGHM Polska Miedź S.A. adopted for application the “Human Rights Policy in KGHM Polska Miedź S.A.” The Policy is publicly available (inter alia on the Company’s website) and known by employees and other persons working for the Company. We pledge to conduct our business in a manner consistent with the International Charter of Human Rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Declaration on the Rights of Indigenous Peoples and the OECD Due Diligence Guidance on Conflict-Affected and High-Risk Areas. We declare that respect for human rights by other entities with which we cooperate is an important factor to be taken into account when establishing mutual business relations.
KGHM’s Human Rights Policy is compliant with the implemented Corporate Risk Management Policy and Procedure and contains the identified risks regarding potential human rights violations in the Company’s operations along with their mitigation, including measures to reduce or mitigate potential risks.
Key human rights in the Company’s operations:
The right to benefit from just and favourable working conditions
The right to privacy
The right to working conditions that meet health and safety requirements
The Company’s Management Board accepts ongoing dialogue with employees as an obligatory norm, including in terms of the implementation of human rights protection, fully respecting activities protecting the rights of persons performing work, in particular such activities as: organising speeches, associations, or the possibility to form and join trade unions in the Company. The employees of KGHM Polska Miedź S.A. are associated in several dozen trade unions. Trade unions, while fulfilling their tasks, also have the right to report and investigate violations in the area of human rights protection with the Company’s management.
At the same time, the commitment of the Company’s Management expressed in this Policy is fully realised by promoting the same attitude among the Company’s employees.
Occupational health and safety, due to the nature of the Company’s activities, constitutes a priority of the adopted Human Rights Policy. In every Division of the Company there is a Social Labour Inspector who has the right to intervene in the event of risks or violations. There are also departmental Labour Inspectors in the divisions with an extensive organisational structure. Reported issues in the area of occupational health and safety are also resolved by the Occupational Health and Safety Committee, which consists of representatives of the employer, the Social Labour Inspector of the company, the occupational physician and trade union representatives.
We continue our dialogue with local governments and communities located in areas where KGHM’s activities may have an impact. This dialogue also concerns the protection of human rights. We prioritize the reduction of all risks to the community resulting from the Company’s activities (including the reduction of the risk of compromising the right to health through consistent implementation of the Climate Policy and the Environmental Policy). We actively support the development of local communities and respect their culture by respecting the rights of indigenous peoples (which is of great importance in the case of the international companies of the Group over which KGHM Polska Miedź S.A. exercises ownership supervision).
All employees of the Company have been familiarised with the adopted Human Rights Policy of KGHM. Over 7,000 members of the KGHM staff underwent online training (internal e-learning platform) on human rights and the adopted Human Rights Policy, as well as the tools for its observance in KGHM.
Moreover, numerous communication activities have been carried out, both addressed to employees (workshops, webinars, publications in internal media, so that each employee who does not have the access to a computer at work can also learn more as regards the implemented Policy) and external stakeholders (publications in nationwide media, participation in initiatives promoting human rights in business).
We do not tolerate any forms of discrimination, particularly due to gender, race, age, ethnicity, religion, disability, beliefs, sexual orientation, social status, marital status, impairment, membership in political parties and trade unions or employment status. We apply objective and fair employee assessment criteria based on the primacy of knowledge, professional competencies, social skills and the quality of work provided. Our remuneration and incentive criteria are clear.
At KGHM, we manage diversity to create an organisational culture based on mutual respect, equal treatment, access to development opportunities and use of employee potential. Our approach to managing diversity is defined in the “KGHM Declaration of Diversity”.
The entire KGHM Polska Miedź S.A. Group implemented an Anti-Abuse Procedure, enabling the effective prevention of personal abuse in the workplace. The procedure describes a catalogue of actions designed to prevent abuse, actions to be taken if abuse does occur, and defines obligations of the employer and employees in this respect. The Procedure applies to all employees of the KGHM Polska Miedź S.A. Group, regardless of the type of contract or position held. Every employee who believes they have experienced or have witnessed behaviour displaying features of abuse, has the right to lodge a report. Such a report is lodged in a process defined in the Procedure for Disclosing Improprieties and Protecting Whistleblowers, using dedicated channels, subject to the stipulation that in this case it is necessary to disclose personal details of the reporting employee, the employee(s) who may been subjected to abuse and the employee(s) committing actions or behaviour displaying the features of abuse. The case is examined by the Ethics Committee of the relevant entity of the KGHM Group. Employees are familiarized with the content of the procedure at the time of hiring and periodically, as part of classroom and e-learning training courses.
A tool supporting the Employer in counteracting abuse, discrimination and violation of employee rights and social co-existence standards is the Ethics Commissions appointed in KGHM Polska Miedź S.A. Group entities examining suspected non-compliance with ethical standards applicable in the KGHM Group. In this respect, no cases of discrimination on various grounds were reported during the reporting period. The work to support and raise ethical and corporate governance standards will continue in 2023.
Personal Data Protection Policy (in KGHM Polska Miedź S.A.)
KGHM Polska Miedź S.A. has a Personal Data Protection Policy in place. The Policy lays down the rules of processing and securing personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR).
The duty to protect personal data processed by KGHM Polska Miedź S.A. and to apply the Policy covers all persons with access to personal data, regardless of their position, place of work and type of employment relationship.
The Policy is consistent with other internal regulations regarding security of information and IT systems applicable in KGHM Polska Miedź S.A.
In 2022, work was undertaken to update the Policy. These activities were aimed at systemically updating the formal content of the documents in the context of the development of KGHM Polska Miedź S.A., the evolving interpretation of regulations and the developed standards of approach to personal data protection in the context of market practices. In addition, their purpose was to make the procedures and practices actually used by KGHM Polska Miedź S.A. more flexible and to facilitate the application of principles and the performance of duties related to personal data protection.
At KGHM Polska Miedź S.A., there is an expert DPO Team, whose purpose is to support the fulfilment of the obligations imposed in the area of personal data protection.
In 2022, activities were carried out to raise KGHM employees’ awareness of personal data protection, including, among other things, continued e-learning training on GDPR. In addition, a number of employee information activities were carried out, for example, publishing articles, newsletters, and a podcast on data protection rules.
GRI
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3-3
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2-27
As a socially responsible company, KGHM Polska Miedź S.A. applies due diligence procedures and attaches importance:
- to adhering to ethical norms and responsible business activities expressed in, among other things, prohibition of corruption, prevention of conflicts of interest, protection of the environment and responsibility for the product and its quality, anti-money laundering and financing of terrorism;
- to respecting human rights, worker and labour standards, including those related to occupational health and safety, among others;
- to complying in terms of, among other things, meeting its obligations to pay public tributes, not entering into business relationships with entities covered by or originating from sanctioned territories, and aiming to counter illegal and unethical sourcing from conflict and high-risk territories.
KGHM Polska Miedź S.A. wants to cooperate with business partners who share the same values and expects customers and suppliers to commit to the above principles by signing the so-called Customer Cards and Supplier Cards.
The Internal Audit Department follows the international internal audit standards. The standards cover 14 areas, with ethics being one of them. When performing internal audit tasks, the risks of potential fraud, conflict of interests or other activities which are not compliant with the Code of Ethics and other internal regulations are analysed. Any areas with increased risk of unethical behaviour are consistently identified and taken into account in the development of the annual audit plan.
The Compliance Management Policy in the KGHM Polska Miedź S.A. Group sets forth the framework of the compliance management system and the approach encompassing the whole organisation, based on recognised international standards and best industry practices. The solution selected to build the compliance system has been adapted to the unique nature of the Group’s operations and is an important business tool used to prevent occurrences that might result in sanctions being imposed on the Group. 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.
In order to have a consistent approach to ensuring compliance, defined as adherence to requirements arising from external (laws in force) and internal regulations or voluntarily-adopted legal obligations and standards, since 2020 a Compliance Management Policy for the KGHM Polska Miedź S.A. Group, adopted by the KGHM Polska Miedź S.A. Management Board, together with a Compliance Management Procedure and Methodology in KGHM Polska Miedź S.A., have been in place. Having a consistent compliance system in the KGHM Polska Miedź S.A. Group is an element of effective corporate governance management by among others more efficient reaction to and preparedness for regulatory changes, protecting reputation and building an ethical culture in the organisation as well as increasing awareness and a sense of accountability for compliance amongst employees. In 2022, work was conducted to improve the effectiveness of the compliance system, among others to implement complementary IT solutions indispensable for the process and building effective tools for prioritizing applicable legal requirements. The work supporting and raising standards of the compliance function will be continued in 2023.
The Competition Law Policy establishes an operational framework for a system that enables 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.
In order to improve the standards of compliance with the competition law, in 2020 the Management Board of KGHM Polska Miedź S.A. adopted instructions to prevent violations under competition law, which expand on and detail the Competition Law Policy in the KGHM Polska Miedź S.A. Group. In December 2022, training was conducted for Local Competition Law Representatives in the KGHM Polska Miedź S.A. Group. The work supporting and raising the standards of compliance with the competition law will continue in 2023.
A measurable effect of the implementation of the procedures and provisions adopted in the various Policies is the relatively low number of violations of laws and regulations. The GRI 2-27 indicator for this scope reflects the information reported by individual companies and the results of surveys conducted among the top management of Group companies, members of the Management Board and Supervisory Board of KGHM Polska Miedź S.A., as well as among representatives of key business areas at the Head Office of KGHM Polska Miedź S.A. The questionnaires were conducted as part of a survey of minimum guarantees for the purpose of assessing taxonomy compliance and pertained to: human rights, labour law, corruption and bribery, consumer protection, competition law, personal data protection, tax matters, environmental protection and energy law. The results of the questionnaire with respect to the Parent Entity, including members of the Management Board and Supervisory Board, indicate that there were no significant violations within the scope covered by the questionnaires.
Values of selected GRI Standards illustrating compliance with laws and regulations in the KGHM Polska Miedź S.A. Group in 2022
| GRI indicator | Issue | Result |
| 2-27 | Significant instances of non-compliance with laws and regulations | 2 |
| Fines | 8 | |
| Non-monetary sanctions | 0 | |
| Number of fines for instances of non-compliance with laws and regulations that were paid during the reporting period, and a breakdown by time of the event | 7 | |
| Monetary value of fines for instances of non-compliance with laws and regulations that were paid during the reporting period, and a breakdown by time of the event [PLN] | 31,314.1 PLN |