The KGHM Polska Miedź S.A. Group complies with the highest standards of production and business ethics and business activity. We are guided by those principles across our value creation chain, which is reflected in the Code of Ethics of the KGHM Polska Miedź S.A. Group. We are aware that the selection of responsible suppliers, especially as regards the sourcing of conflict minerals (such as gold, tin, tungsten and tantalum) and silver, is of key importance for conducting activity oriented on sustainable development. A document regulating these issues is the KGHM Group’s Responsible Supply Chain Policy. Its purpose is not only to guarantee the selection of only responsible suppliers, especially with respect to the conflict minerals listed above, but also to ensure that the goods and services procured do not contribute to financing terrorism and are manufactured or provided in compliance with basic human rights, labour standards, standards of environmental protection and preventing corruption.
The Parent Entity has fully implemented an internal responsible gold and silver supply chain management system which is comprised of the Responsible Supply Chain Policy in the KGHM Polska Miedź S.A. Group and the Procedure for assessing responsible supply chain for gold and silver in KGHM Polska Miedź S.A. In 2020, the Procedure for assessing the supply chain for gold and silver in KGHM Polska Miedź S.A. was updated to increase the efficiency of the process while maintaining compliance with the current LBMA Responsible Gold Guidance V8 and LBMA Responsible Silver Guidance V1. The system for managing the responsible gold and silver supply chain is subject to an annual, independent, external assessment to confirm the Company’s adherence to the principles of conflict-free gold and silver under the LBMA Responsible Gold Guidance and the LBMA Responsible Silver Guidance. The current Compliance Report of KGHM Polska Miedź S.A. and the Report on an independent assurance service is available on the website.
In order to ensure due diligence, the Parent Entity introduced an internal system of responsible supply chain management, which is comprised of the scope of the system’s application, the system’s organisation, the participants of the process, the criteria for acknowledging a business relationship as being a high risk relationship, the supply chain audit process (taking into account the procedure of business partner reliability assessment), transaction monitoring, documentation storage and employee training. The management of the process has been entrusted to the Head of the Corporate Risk and Compliance Management Department, reporting directly to the Company’s Management Board. An e-mail address firstname.lastname@example.org was also set up to which any comments and observations related to the supply chain may be sent by employees, business partners and other stakeholders. Responsible Supply Chain Policy in the KGHM Polska Miedź S.A. Group is available on the website.
The Risk of failure to adhere to established principles and standards of conduct with respect to counteracting corruption, business ethics and in the procurement process and the risk of incurring losses from actions which are harmful to the KGHM Polska Miedź S.A. Group was described in more detail in this Report in the section “Comprehensive Risk Management System in the KGHM Polska Miedź S.A. Group”.