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In our activities, we ensure compliance with applicable laws, regulations and standards. We actively implement the compliance function, which results from the dynamic legal and regulatory environment, while ensuring the transparency of market and communication activities. Our approach is visible in the high standards of cooperation with shareholders, business partners and contractors.

We consciously manage a risk of non-compliance, also with internal procedures and regulations. In addition, we focus on the implementation of activities in accordance with accepted ethical and community standards, including in a field of counteracting corruption and abuse. We constantly endeavour to ensure the effectiveness, consistency and transparency of the Company’s documentation.

Our achievements in 2022

Monitoring and ensuring compliance with existing laws, internal regulations and voluntarily adopted standards.

Implementation of mechanisms mitigating a non-compliance risk.

Ensuring the efficiency, consistency and transparency of the Company's documentations.

100% of internal acts covered by the electronic supervision and documentation system.

Implementation of a Code of Ethics.

Plans for 2023:

  • Ongoing review of the Company’s statement on the Good Practices of Listed Companies.
  • Analysis of the necessity to align the remuneration policy of the Management Board and the Supervisory Board with the “Strategy for sustainable development of Sniezka”.
  • After the introduction of the Polish Whistleblower Act, education on the existing mechanism for reporting remarks:
    • 100% of a management staff,
    • 100% of employees.
  • Launching the reporting mechanism of law infringements.

We care about maintaining the highest standards within the organization, building an organization based on an effective management system and business ethics.

The approach to business ethics and detailed rules of conduct are regulated by the implemented “Śnieżka Capital Group Code of Ethics”.

The Śnieżka Capital Group Code of Ethics

The Code provides a clear set of standards that are a reference for employees in their daily decision-making. It is a practical tool for making the right choices. It is divided into four main sections – relations with employees, the environment, the environment and corporate governance and ethics. It also explains the basis for introducing the document and how it works in practice.

This part of the document defines the basic principles prevailing in the Śnieżka Group in the area of employees, such as:

  • care for the safety of employees,
  • counteracting discrimination and mobbing,
  • equal opportunities for promotion and career development,
  • creating a supportive and developing workplace,
  • prohibition of forced labor and children,
  • freedom to express one’s own opinion in the scope of one’s duties.

In addition, it indicates additional agreements, provisions and policies that the Group adheres to. International laws, such as the United Nations Universal Declaration of Human Rights, are the basis. An important function is also played by internal detailed regulations that discuss the above-mentioned issues (including the Diversity Policy and the Personnel Policy).

The Code pays particular attention to external stakeholders with whom employees deal on a daily basis. These include suppliers, customers and also local communities.

Relationships with suppliers and possible doubts as to a correct procedure are specified in the Purchasing Policy and the Supplier Code of Conduct. Our approach to the customer is first and foremost professional, and is based on the transparency of the Group’s activities. We want them to have the best possible knowledge of the products and services we offer, the quality of which we constantly improve.

In line with the Sustainable Development Strategy, we engage with local communities, mainly in the area of equal opportunities. Our approach is described in detail in our Community Involvement Policy, the implementation of which is based on three pillars:

  • Colour,
  • localness,
  • Children and youth.

The document indicates that issues related to care for the climate are inscribed in the overall activities of the Group. It is undertaken primarily by the Climate Policy and the Quality, Environment and Health and Safety Policy of the Śnieżka Capital Group. However, the commitment to ecological activities is also present in documents regarding product standards or relations with suppliers, as we monitor our impact on the natural environment at every stage of the life of our products.

This part of the Code deals primarily with the ethical aspects of doing business and dealing with contractors. It also refers to other internal regulations dealing more extensively with specific topics (such as the Information Policy). The following topics are addressed here:

  • counteracting corruption,
  • conflict of interests,
  • fair competition,
  • responsible communication,
  • protection of data and confidential information.

The standards contained in the Code apply to all employees of the Śnieżka Capital Group, regardless of their position, full-time employment, time and place of work or the type of tasks performed.

Izabela Chmiel Corporate Governance Officer

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