Ethical and anti-corruption processes

The ethical area is supervised by the CSR 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 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 operating segment the Business Ethics Committees have been appointed. In 2022, the process was joined by the total of 18 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.

A policy related to the Code of Ethics is the Anti-corruption Policy, which presents our approach to the subject of corruption. As stated in the Policy, Grupa KĘTY S.A. 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 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. The policy is available in the ‘OrangeBook’ strategic processes management system, and for external stakeholders at corporate website.

In 2022, the Company-created training courses in preventing corruption, legal liability and documents binding at the Capital Group had continued (including Anti-corruption Policy). The training was completed by 600 employees, including all managerial staff (directors and managers) and employees participating in corruption-sensitive processes. 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:

The Code of Ethics binding at the Capital Group provides for the methods of reporting official violations and doubtful behaviours. 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 Code of Ethics is available in electronic form in the ‘OrangeBook’ strategic processes management system. Moreover, special information boards presenting the key values covered by the Code of Ethics and the methods of reporting breaches are displayed in production departments. 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.

Further to the internal analysis of the 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 as well as introduction of internal and external blockers, in 2022 the Business Ethics Ombudsman did not receive any reports of the Code of Ethics breaches, including human rights infringement. The matter was discussed in the meeting of the Committee for Sustainable Development and Corporate Social Responsibility. The Committee obliged the Business Ethics Ombudsman to prepare a training course for the employees in respect of the Code of Ethics. It will be held in 2023 and reported in the next year’s Statement.

In 2022, we also continued the process of broader impact of the Capital Group with regard to responsibility within the supply chain. The Company carried out a questionnaire survey among the suppliers covered with the ‘Code of Conduct’. A description of the initiative has been presented in the Responsibility within the supply chain section.

In 2022, 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.