Our management approach

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We operate ethically at the Grupa Azoty Group. We are a responsible corporate citizen that stakeholders can trust. We operate in line with the adopted rules of conduct, which are consistent with the values embraced by all Grupa Azoty Group companies. The way we operate is based on the Code of Ethical Conduct, which sets out the priorities in fostering good employee conduct and building relations with our external stakeholders. The document specifies what conduct is to be expected from the Grupa Azoty Group and its employees. We take all declarations contained in the Code of Ethical Conduct with the utmost seriousness and feel obliged to fulfil them, so that the way we operate fully reflects our commitments defined in the Code. The Code also applies to our customers, business partners, shareholders and other stakeholders. The Code of Ethical Conduct is part of our compliance management system enabling effective control and supervision of compliance with the laws, internal regulations, industry standards and good practices. The right to implement the system and to monitor its operation and effectiveness rests with the Compliance Officer.

Grupa Azoty Group Code of Ethical Conduct is a public document available on our corporate websites.

Grupa Azoty Group Code of Ethical Conduct

• defines the ethical values and principles applying to the conduct of business with stakeholders, suppliers and local communities,
• declares the intention to ensure equal employment, promotion and training opportunities for our employees,
• describes the procedure for reporting incidents involving ethics violations to a line manager or the Compliance Officer,
• defines measures to manage conflicts of interest and corruption risk.

We strive to ensure that each of the many thousands of our employees knows and observes the Code in their everyday work. The heads of individual organisational units of the Group are required to familiarise their subordinates with the applicable internal regulations. As of 2020, all new employees and suppliers wishing to collaborate with our Group are required to confirm in writing that they have read our Code of Ethical Conduct and the related policies. Following policy updates, in 2021 such confirmations were also required from persons hired before 2020.

Good management – understood as responsible management of the Grupa Azoty Group’s tangible and intangible assets based on a cost-benefit analysis. All our assets are managed so as to maximise benefits to our shareholders and other stakeholder groups.

Professionalism – making every effort to ensure that our management approach, as well as operating standards and control systems are well designed, effective, and support the delivery of our business strategy. For us, to be professional is to apply the highest standards of care and to make proper use of our expertise, skills and business competence in day-to-day work.

Cooperation – arranging our mutual relations with stakeholders so as to maximise benefits to the Grupa Azoty Group, with due regard to and respect for the other party’s interests. This involves communication aimed at achieving a win-win situation, building mutual trust, and pursuing common goals. 

Respect – refraining from any acts or decisions and from making any statements that could violate another person’s dignity. It involves a duty on our part to respect any nationality, race, gender, age, disability, religion, political views, sexual orientation, as well as different beliefs and opinions. 

Transparency – we openly communicate all our decisions and actions, their underlying circumstances, as well as our expectations and standards. We are guided by this approach in all areas of our activity, except for those which must remain confidential for business or legal reasons.

Responsibility – whatever we do, we are committed to the safety and well-being of our employees, customers and other people who may be affected by our activities, to protecting the natural environment and improving the quality of life of local communities where we operate, and to exercising due care for tangible and intangible resources we have been entrusted with.

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In 2021, there were no pending lawsuits regarding breaches of fair competition rules against any parent company of our Group.

Trade unions

We manage relations with trade unions in a responsible and lawful manner. We respect the right of employees to associate in trade unions. We also want to foster good relations with trade union representatives, based on dialogue and understanding of mutual needs. No works council has been appointed at any of the Grupa Azoty Group’s plants.

Number of trade unions and number of employees who are members of trade unions

BEST PRACTICE

Grupa Azoty Puławy has in place a Dialogue Forum, i.e. regular meetings between the employer and all trade unions active at the company during which information on key aspects of Grupa Azoty Puławy’s operations is presented, and employee-oriented proposals and initiatives are discussed. The company has also established a collective bargaining agreement negotiation team to discuss amendments to the provisions of the collective bargaining agreement and to consult them with trade unions. The negotiations concern proposals put forward by the employer or by the trade unions.

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Employees covered by collective bargaining agreements

¹ At Grupa Azoty Kędzierzyn, the collective bargaining agreement does not apply to the Management Board members and senior executives.
² At Grupa Azoty Police, the collective bargaining agreement does not apply to the Management Board members.
³ At Grupa Azoty S.A., the collective bargaining agreement does not apply to persons employed under managerial contracts.

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The Grupa Azoty Group takes a zero-tolerance approach to corruption. All employees must strictly observe the Anti-Corruption Code, which further specifies the anti-corruption rules set out in the Code of Ethical Conduct. The Anti-Corruption Code expressly and in a manner that leaves no room for misinterpretation prohibits any direct or indirect types or forms of corruption. Offering, providing, promising or authorising the provision of any financial benefits, as well as accepting such benefits in any form, is prohibited at all levels of the Grupa Azoty Group’s organisational structure. Our Code also prohibits nepotism, cronyism, and provision of benefits to political parties or candidates for public offices.

The Code is available to all employees, including on the corporate intranet in the COMPLIANCE MANAGEMENT section. The section contains the definition of misconduct, relevant regulations and information on dedicated red mailboxes located on the premises of our companies, together with photographs of their location.

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The Anti-Corruption Code requires all employees who suspect corruption, nepotism or cronyism to report their concerns within seven days to the Compliance Officer. Employees can report such misconduct through a dedicated channel described in the Whistleblowing Policy. In addition, the home page on our intranet features the ‘Report misconduct’ section. Clicking the button opens a page with an address to which any instance of misconduct can be reported, and a link to the Whistleblowing Policy.

We follow and expect our business partners to follow our anti-corruption rules. Signing an agreement/contract with the Grupa Azoty Group is conditional on the acceptance of our anti-corruption rules. This requirement follows from the Business Partners Code of Conduct. Our trading partners must confirm in writing that they are not involved in fraudulent tax practices and that the products they offer are not derived from criminal activity and are not traded in carousel fraud.

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In 2021, 93% of our employees read the Code and the anti-corruption procedures. All newly recruited employees are required to read those documents and acknowledge this fact by signing a relevant representation. Such representations are filed on a monthly basis. We also make sure that senior management of the Grupa Azoty Group are familiar with the anti-corruption rules. Members of the management boards of the Group companies confirm this fact when taking office.

We also make sure that senior management of the Grupa Azoty Group are familiar with the anti-corruption rules. Members of the management boards of the Group companies review those rules when taking office. In 2021, all members of the management bodies read the organisation’s anti-corruption policies and procedures.

BEST PRACTICE

In 2021, all employees of our leading companies who supervise the work of at least one employee were required to take part in compliance training covering internal anti-corruption regulations. They must also become familiar with materials prepared by the Polish Central Anti-Corruption Bureau (CBA) concerning business corruption.

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In 2021, there were no cases of corruption or fraud at Grupa Azoty Group companies.

Investigation into fraudulent acts against Grupa Azoty Police

The Szczecin District Prosecutor’s Office continues to investigate possible criminal offences, including fraud and failure to comply with obligations to the detriment of the company. According to announcements issued by the Prosecutor’s Office in connection with presentation of further charges and application of preventive measures, extensive evidence was gathered in that case (including expert opinions and documents relating to the proceedings conducted by the Polish Financial Supervision Authority), which indicates that an offence was perpetrated in connection with the acquisition and performance of an agreement for the acquisition of shares in African Investment Group S.A. by Grupa Azoty Zakłady Chemiczne Police S.A. The criminal acts involved, among other things, intentional overstating of the value of shares in African Investment Group S.A., and failure to meet the terms of payments during the performance of the share purchase agreement, which allegedly led to a disadvantageous disposal of the company’s assets by spending more than USD 28 million until August 2015.

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Number of employees who have read the organisation’s anti-corruption policies and procedures, by employee category

⁴ In 2021, 1,970 (87%) employees of Grupa Azoty S.A. read the organisation’s anti-corruption policies and procedures. The Company does not aggregate such data by employee category.

Percentage of employees who have read the organisation’s anti-corruption policies and procedures, by employee category

⁵ In 2021, 1,970 (87%) employees of Grupa Azoty S.A. read the organisation’s anti-corruption policies and procedures. The Company does not aggregate such data by employee category. The percentage was calculated as the ratio of the employees who read the procedures to the total number of employees as at December 31st 2021 and those who left in 2021.

Number of management body members who read the organisation’s anti-corruption policies and procedures

Percentage of management body members who read the organisation’s anti-corruption policies and procedures⁶

⁶ The figures reported reflect only the number of employees as at December 31st 2021.

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At the Grupa Azoty Group, we sometimes permit offering and accepting gifts as this is believed to help forge and foster business relationships. However, we also realise that some gifts may be seen as a form of corruption or may compromise the reputation of the Grupa Azoty Group. For this reason, we have developed and implemented the Gift Policy across the Group. It specifies in detail the general principles set out in the Code of Ethical Conduct and the Anti-Corruption Code. Our Policy provides employees with knowledge of what gifts may be given or received in connection with their work. Offering or accepting gifts must always be justified by business circumstances and the value of a gift may not exceed PLN 200. Gifts must be presented in a transparent manner and may not affect the recipient’s objectivity or freedom of judgement. It is forbidden to regularly present gifts to one person (with a value in excess of PLN 400 in one year). Our employees are not allowed to offer gifts to persons who hold public offices, except for precisely defined official situations in which flowers, cards or items bearing the Grupa Azoty logo worth up to PLN 200 may be presented.

We are committed to ensuring that our employees’ private social, family or financial relations do not affect their professional decisions. Our Conflicts of Interest Policy defines potential conflict of interest situations and provides guidance on the steps to be taken when they occur. All employees are required to inform their respective line managers at least seven days in advance of situations where making a decision could give rise to a conflict of interest.

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We want to respond promptly to any instances of misconduct that may occur at our Group. To this end, we have implemented a coherent and effective Whistleblowing Policy. Addressed to all stakeholders of our companies, the Policy is applicable at each level of the Group’s organisational structure. Our employees are obligated to immediately report their concerns about possible misconduct:

• in person to the line manager or to a permanent Member of the Management Board;
• by telephone to the Compliance Officer;
  by email on a 24/7 basis to: sygnalista@grupaazoty.com;
• by letter sent through traditional post or put in one of the red mailboxes located on the premises of the Grupa Azoty Group companies.

Unless otherwise stated by the reporting person, all incoming reports will be treated as confidential. We guarantee full anonymity – the identity of a whistleblower may only be disclosed if such disclosure is an obligation imposed on the relevant Group company under generally applicable laws. We do not seek to establish the identity of persons who have not provided their details in misconduct reports. Persons reporting their concerns in good faith will not face any retaliatory action. In particular, they will be protected against any form of discrimination, bullying, intimidation, ostracism and other types of improper or unequal treatment by companies of the Grupa Azoty Group or other employees. Any reported instance of misconduct is investigated by way of an internal procedure.

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In 2021, Grupa Azoty Police received three misconduct reports.  The Whistleblowing Policy Team conducted investigations, which identified one unconfirmed case of workplace bullying, one case of harassment and a case of violation of ethical standards between two employees. Following relevant proceedings, a recommendation was issued to develop and put in place a procedure for counteracting discrimination, workplace bullying, harassment, including sexual harassment, and other undesirable behaviour. It was also recommended that regular training be prepared and provided to all company employees to raise their awareness of discrimination, workplace bullying, and other undesirable behaviour, as well as on methods to prevent such behaviour and its consequences.

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Number of incidents of discrimination⁷

⁷ According to the GRI standards, discrimination is understood as an act and the result of treating people unequally by imposing unequal burdens or denying benefits rather than treating each person fairly on the basis of individual merit. Discrimination may also include harassment, understood as repeated comments or acts that are unwelcome to the person being the target of such behaviour. The summary includes incidents of discrimination on the grounds of race, colour, sex, religion, political views, national origin or social background as defined by the International Labour Organisation, and other relevant forms of discrimination involving employees and external stakeholders.