Integrated Report 2023
  • GRI 2-11
  • GRI 2-12
  • GRI 2-13
  • GRI 2-14
  • GRI 2-15
  • GRI 2-16
  • GRI 2-17
  • GRI 2-18
  • GRI 2-19
  • GRI 2-20
  • GRI 2-23
  • GRI 2-24
  • GRI 2-25
  • GRI 2-26
  • GRI 2-27

Supervision of the sustainable development management is provided at the Capital Group of Grupa KĘTY S.A. by the Management Board. The Management Board prepares and implements the strategy, whereas the Supervisory Board continuously supervises the activities of the Company in all areas of its operations, including the performance of the business strategy as well as ESG strategy.

The membership structure of the Management Board, the Supervisory Board, and the  Supervisory Board Committees may be found in the ’Company and Capital Group organisational chart and management structure’,Supervisory Board and Supervisory Board Committees’ and ’Management Board’ sections. The Chairman of the Supervisory Board does not hold any managerial positions at Grupa KĘTY S.A. or any of the Capital Group companies.

Sustainable Development and ESG fall within the competence of the President of the Management Board.

Reporting to the President of the Management Board is the CSR Department with the CSR Director, who coordinates and develops processes in the area of the organisation’s impact on the society, environment, and ethics, and who is responsible for developing policies in these areas.

The main objective of the CSR Department functioning is to create and build structures, set out the directions of activities in the field of sustainable development of the Capital Group companies, increase the awareness of corporate social responsibility and ESG, and take actions outside the Capital Group.

 

  • aligning the organisation with market trends and requirements in the ESG area;
  • initiating and coordinating activities in the areas of CSR, ESG, and sustainable development;
  • coordination of the work of the Steering Committee for Sustainable Development and Corporate Social Responsibility (the ‘Committee’).

The membership, role and tasks of the Committee are defined in the Corporate Social Responsibility Procedure.

  • the Management Board of Grupa KĘTY S.A.,
  • Heads of operating segments,
  • CR Dekret CEO,
  • Business Ethics Ombudsman,
  • CSR Director.

The CSR Director is responsible for convening the Committee meeting and appointing new members (in reference to the Committee’s meeting schedule, new participants are invited to act as temporary members). The Committee meetings are held at least once a year. The Committee’s  main role is to supervise the performance of social and environmental processes, as well to care for the Company sustainable development, in reference to the adopted Mission, Vision and Values, as well as the ESG strategy.

In 2023 two Committee meetings were held. The main subjects discussed in the meetings were:

  • discussion of the ESG strategy, and progress in attaining goals, as well as update of the performance of objectives with regard to: Increase in the number of Aluprof-systems-constructed buildings with environmentally-friendly certificates;
  • Committee recommendations in the area of social activity;
  • discussion and adoption of actions aimed at raising the level of ethical awareness – training for the employees in the subject of ethics through the eOK in-house platform;
  • legal and market environment affecting the scope of mandatory disclosures.

The CSR Director, together with the Sector Managers who are responsible for ESG processes at the Capital Group, including: the Director for Quality and Environmental Protection, Chief HR Specialist, IR Director, Compliance and Risk Management Director, and Chief Specialist for Supervisory Board Assistance, prepare strategic ESG projects and policies for the Committee meetings, which are further submitted to the Management Board for decision.

The policies governing the Company approach to ESG areas include but are not limited to: the Code of Ethics, the Climate Policy, the Respect for Human Rights Policy (referring to the European Convention on Human Rights), the Code of Conduct for the Suppliers of the Grupa KĘTY S.A. Capital Group, and the Occupational Health and Safety Policy. They are treated as foundations for the supervision of due diligence processes. Strategic topics are implemented into policies and procedures. The policies are signed by all Members of the Company Management Board and Heads of the operating segments, and published in the Company OrangeBook Platform, i.e. a system for managing strategic processes.

OrangeBook contains a set of procedures, policies, instructions, recommendations, and orders, representing the most important guidelines and assumptions for the strategic and operational management of the Capital Group.

In order to maintain a consistent and effective oversight and control system, once a year a review is carried out with regard to the Capital Group procedures and policies compatibility with those published in the OrangeBook. During the review, compliance is confirmed or reasons for any non-compliance are analysed.

As a signatory of the Global Compact initiative, the Capital Group undertakes actions to support 10 goals, and includes the Global Compact principles in the relevant policies and procedures. The 05.30_Ethical Business Principles Procedure maps the process of due diligence with regard to respecting the 10 Global Compact principles.

10 Global Compact principles

Item Global Compact Principle Related procedures/documents
1 Promotion and protection of human rights adopted by the international community
  • OB_02_Respect for Human Rights Policy
  • OB_03_Occupational Health and Safety Policy
  • OB_40.00_Personal Data Protection
  • OB_40.10_HR Policy
  • OB_40.30_Staff Development
  • OB_40.31_Staff Training
  • OB_05.00_CSR Policy
  • OB_05.10_Code of Ethics
  • OB_40.11_Diversity Policy
  • OB_40.12_Dignity at Work Policy
  • OB_20.00_Code of Conduct for Suppliers of the Capital Group of Grupa KĘTY S.A.
2 Elimination of human rights violations at the Company
  • OB_05.02_Respect for Human Rights Policy
  • OB_40.00_Personal Data Protection
  • OB_40.20_Staff Recruitment and Adaptation
  • OB_40.30_Staff Development
  • OB_40.50_Remuneration Policy
  • OB_00.40_Intellectual Property Management
  • OB_40.11_Diversity Policy
  • OB_40.12_Dignity at Work Policy
  • OB_20.00_Code of Conduct for Suppliers of the Capital Group of Grupa KĘTY S.A.
3 Respect for the freedom of association
  • OB_05.10_Code of Ethics
  • OB_05.02_Respect for Human Rights Policy
  • OB_20.00_Code of Conduct for Suppliers of the Capital Group of Grupa KĘTY S.A.
4 Elimination of all forms of forced or compulsory labour
  • OB_05.02_Respect for Human Rights Policy
  • OB_05.10_Code of Ethics
  • OB_40.50_Remuneration Policy
5 Abolition of child labour
  • OB_05.10_Code of Ethics
  • OB_40.20_Staff Recruitment and Adaptation
  • OB_20.00_Code of Conduct for Suppliers of the Capital Group of Grupa
  • KĘTY S.A.
6 Effective elimination of discrimination in respect of employment and occupation
  • OB_05.02_Respect for Human Rights Policy
  • OB_40.20_Staff Recruitment and Adaptation
  • OB_40.30_Staff Development
  • OB_40.31_Staff Training
  • OB_40.32_Competence Management System
  • OB_40.33_Staff Periodical Assessment
  • OB_40.34_Language Competence
  • OB_40.35_Management by Objectives
  • OB_40.50_Remuneration Policy
  • OB_40.80_Personnel Administration
  • OB_40.90_Occupational Health and Safety
    OB_05.10_Code of Ethics
  • OB_40.11_Diversity Policy
  • OB_40.12_Dignity at Work Policy
7 Preventive approach to natural environment
  • OB_05.01_Climate Policy
  • OB_05.10_Code of Ethics
  • OB_05.00_CSR Policy
  • OB_80.90_Performance of legal duties related to environmental protection
  • OB_80.91_Identification of environmental aspects, monitoring and measurement
  • OB_20.00_Code of Conduct for Suppliers of the Capital Group of Grupa KĘTY S.A.
8 Undertaking initiatives to promote environmental responsibility
  • OB_05.01_Climate Policy
  • OB_05.10_Code of Ethics
  • OB_05.00_CSR Policy
  • OB_05.20_Corporate Social Responsibility
9 Applying and spreading environmentally friendly technologies
  • OB_05.10_Code of Ethics
  • OB_05.00_CSR Policy
  • OB_80.92_Control of processes encompassing major environmental aspects
  • OB_80.91_Identification of environmental aspects, monitoring and measurement
  • OB_20.00_Code of Conduct for Suppliers of the Capital Group of Grupa KĘTY S.A.
10 Working against corruption in all its forms, including extortion and bribery.
  • OB_05.10_Anti-corruption Policy
  • OB_40.20_Staff Recruitment and Adaptation
  • OB_40.31_Staff Training
  • OB_05.10_Code of Ethics
  • OB_20.30_Purchases
  • OB_20.40_Strategic Purchases
  • OB_20.50_Investment Purchases
  • OB_20.55_Service Purchases
  • OB_20.00_Code of Conduct for Suppliers of the Capital Group of Grupa KĘTY S.A.

Other procedures are also described in the ‘Environmental responsibility’ and ‘Ethical and anti-corruption processes’ sections.

The strategy, policies and other documents relating to ESG area are available for the internal purposes of the organisation in the ‘OrangeBook’ strategic processes management system, and for the external stakeholders at: https://grupakety.com/ in the Sustainable Development section.

Maintaining the standards of communication with the market and the stakeholders, the Company publishes results forecasts on a quarterly basis and organises conferences for capital market participants. The Company reports its impact on the environment and the society in the ‘Non-financial Information Statement’, as part of the Report of the Management Board of Grupa KĘTY S.A. on the operations of the Company and the Capital Group, available at: https://grupakety.com/en/investor-relations/grupa-kety-on-wse/interim-reports-and-presentations/, and also in its integrated report at: https://raportzintegrowany2023.grupakety.com/.

The corporate website comprises the contact details of the CSR Director and the IR Director as persons designated for contacts in matters related to the ongoing ESG Strategy. In 2023, no critical comments were received regarding the Company activities in that area. In case any negative impact is identified, the Company commits to carry out corrective actions.

Apart from the contact details of the CSR and IR Directors published on the corporate website, the Company  does not have a formalised channel for monitoring enquiries regarding the ESG management system for external stakeholders.

Internally, there are two formal channels through which each employee may contact the Management Board and the Supervisory Board. The first is the path indicated in the Code of Ethics – for reporting violations in the environmental, corruption, and employee areas.

The second is the internal procedure OB.00.26_Internal Control System, specifying the possibility to report the perceived irregularities and violations directly to a Member of the Management Board or, in justified cases, directly to the Supervisory Board.

In addition, through the ‘Green Group’ – employee suggestions programme, employees at all levels are invited to submit proposals to optimise processes and co-create the climate policy of the Capital Group. In 2023 there were 27 suggestions reported.

In the area of awareness raising and communication of the relevant ESG aspects, the Company issues its ‘Aluway’ newsletter, which periodically, at least once a month, describes the current activities of the Capital Group companies in the social and environmental area.

Further, each new or updated procedure or policy is communicated to the employees in the internal OrangeBook handbook, whereas training courses in the Code of Ethics, anti-corruption policy, GDPR regulations, or cyber security are available on the internal eOK platform.

The Company employees involved in the ESG strategy development process and responsible for its individual areas benefit from a wide range of expert resources (seminars, webinars) as well as dedicated subject-matter workshops. In 2023 there were held two workshops for broadly understood managerial staff devoted to corporate sustainability reporting (Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 and Commission Delegated Regulation (EU) 2023/2772), whereas the CSR Director held internal training and presentations devoted to ESG. The managers of all operating segments took part in the training courses.

With regard to the Company Management Board, ESG issues are communicated and discussed in the meetings of Committees for Sustainable Development and Corporate Social Responsibility. In 2023 there were held two training courses. The first of them was run by the Compliance and Risk Management Director with regard to new regulations which are going to affect processes at the Capital Group within the perspective of the coming years, including: Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence (CSDD) Directive proposal, Diversity in Boards of Directors and Supervising Bodies, ‘Equal Pay’ Directive, 'Fit for 55′ legislative package. The other one was run by the CSR Director and was devoted to double materiality analysis in compliance with the European Sustainability Reporting Standards (ESRS).

At the same time, ESG subjects were discussed several times by the Audit Committee of the Supervisory Board of Grupa KĘTY S.A.

The principles of remuneration of Grupa KĘTY S.A. Management and Supervisory Boards Members are stipulated in the Remuneration Policy of the Management Board and Supervisory Board Members of Grupa KĘTY S.A. (adopted on 20 August 2020 by Resolution No. 19/20 of the Annual General Meeting of Grupa KĘTY S.A., and amended by the AGM Resolution No. 18/2022 of 25 May 2022) which is available at: https://grupakety.com/en/investor-relations/corporate-governance/policies/.

The remuneration of the Management Board Members consists of fixed and variable components, as well as in‑kind benefits. The variable remuneration is partly dependent on the performance of non-financial goals (GHG emissions reduction, OHS improvement, social engagement), whereas the goals attainment is assessed as a factor of the oversight of the organisation’s impact on the environment, the society and the economy.

The Company has adopted the Conflict of Interest Prevention Policy, which applies to all employees of the Capital Group of Grupa KĘTY S.A., including the Management Board of Grupa KĘTY S.A. (‘Policy Subjects’). The policy covers the methods of prevention, identification and solving the conflicts of interest, as well as the principles of excluding a Policy Subject from the participation in considering a matter related to or threatened with a conflict of interest. The policy is available at: https://grupakety.com/en/sustainable-development/society/documents-and-policies/.

In 2023, the Capital Group has not recorded any material instances of non-compliance with laws and regulations. The Group has an extensive compliance system in place, including regular risk assessments, training programmes as well as monitoring and reporting mechanisms to ensure legal compliance.

In 2023, no major fines or non-monetary sanctions were imposed on the Capital Group for breaches of laws and regulations. Our commitment to maintaining high standards of ethical conduct and corporate responsibility reflects a strong culture of compliance, and our continuously monitored and improved compliance practices allow us to operate in a responsible and sustainable manner.