Accountability for product and service quality

The Group also complies with voluntary obligations resulting from ISO and ASTM standards as well as from membership in international organisations such as International Copper Association, European Precious Metals Federation, Eurometaux, Euromines, the London Bullion Market Association, the European Technology Platform on Sustainable Mineral Resources, the European Innovation Partnership, and domestic organisations, including: the Polish Association of Listed Companies, Association of Non-Ferrous Metals Engineers and Technicians, the Economic Chamber of Non-Ferrous Metals and Recycling, the Polish Committee of the World Mining Congress, the Polish Chamber of Chemical Industry, the Polish-Canadian Chamber of Commerce, the Polish Chamber of Commerce for High Technology, and the Employers’ Organisation of Polish Copper. The KGHM Polska Miedź S.A. Group does not participate in undertakings which involve breaking the law and pose a threat to its reputation.

• We comply with the provisions of law and internal regulations in effect in KGHM Polska Miedź S.A.
• We keep our obligations written in contracts as well as verbal promises made to our clients, suppliers and social partners.
• We duly perform our professional duties.
• We do not offer or accept bribes or other material or personal benefits; we also do not cooperate with companies of doubtful reputation.

In accordance with its Code of Ethics, in relationships with its business partners KGHM observes the principles of ethical conduct. The KGHM Polska Miedź S.A. Group holds to high ethical standards not only its own employees, but also its business partners who receive and must familiarize themselves with the Code of Ethics.

In mutual relationships, the KGHM Polska Miedź S.A. Group follows the principle of “zero tolerance for corruption”. The Group has in place the Corruption Threat Prevention System which, in accordance with the Management Board decision, will be improved and adjusted to the PN-ISO 37001:2017 standard in 2021. KGHM puts special focus on transparency of transactions and prevention of conflict of interest. It monitors the supply chain and product life. Companies competing for cooperation with the KGHM Polska Miedź S.A. Group and those already working with the Group are assessed for, among others, corruption risk. KGHM conducts business with entities of proven reputation. Through appropriate procedural arrangements, the KGHM Polska Miedź S.A. Group prevents money laundering and the financing of criminal activities, including terrorism. It specifically protects the personal data of partners as well as commercial, technical or organisational information entrusted to it. The KGHM Polska Miedź S.A. Group is guided by the principles of fair competition.

There is a Competition Law Policy in the KGHM Polska Miedź S.A. Group. Its purpose is to establish the operational framework for the system to ensure compliance with the competition laws prevailing in all the countries of its operations.

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 conflict.minerals@kghm.com 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”.