Ethical and anti-corruption processes

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 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 2023, 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.

In 2023 there was held a training in the Methods of handling internal explanatory proceedings, given by an external experts to the members of the Business Ethics Committee, with the aim to ensure proper competencies of the Committee Members.

The organisation uses policies and detailed procedures defining the ethical issues and ethically sensitive processes. Of key importance 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’. In 2023, the Capital Group did not make any donations to political parties.

As stated in the Policy, Grupa KĘTY S.A. objects to 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.

In 2023, as many as 1,291 employees, including managerial staff (directors and managers), took part in a training course regarding the Code of Ethics binding at the Capital Group of Grupa KĘTY S.A. and the related policies (Anti-corruption Policy, Conflict of Interest Prevention Policy, Diversity Policy, Dignity at Work Policy) through the eOK internal training platform. At the same time 122 people participated in the Anti-corruption Policy training run by external experts.

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.

The Code of Ethics binding at the Capital Group provides for the methods of reporting 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’. Moreover, special information boards presenting the key values covered by the Code 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 a Member of the Management Board.

In 2023 the Business Ethics Ombudsman received 3 reports, two of them referring to violations with regard to dignity at work. Following the investigation carried out by the Ethics Committee, violations were not confirmed in two cases, and in the third case there were no proceedings held due to an overly general nature of the report and reference to matters which are not related to the work performed.

In 2023, 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.