Prevention and detection of corruption and bribery
The Śnieżka Group has appropriate documents (described at Area management), aimed at preventing the risk of corruption and bribery. These include primarily the Anti-Corruption Policy, the Code of Ethics and Procurement Policy, and relevant provisions are also included in the Supplier’s Code of Conduct.
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Detecting and responding to corruption-related incidents is regulated in the Internal Reporting Procedure and the Report Handling Procedure. These documents introduce a confidential channel for raising concerns, including those resulting from corruption and bribery. In companies where these documents are in place, concerns are received and reviewed by one team common to the Śnieżka Group (more information on this topic can be found at Area management in the section on whistleblower protection).
For the parent company, the Internal Reporting Procedure provides for additional channels for raising concerns: by e-mail or letter to the CEO, and if it concerns a team member or a member of the Management Board of Śnieżka SA – by e-mail or letter to the Supervisory Board of Śnieżka SA.
The Śnieżka Group does not have a separate procedure for presenting the results of the above activities to the administrative, management and supervisory bodies. However, in companies where whistleblower protection principles have been adopted as part of the Internal Reporting Procedure and the Report Handling Procedure, reporting the results of the investigation is regulated in the latter of these documents.
Every investigation, regardless of its outcome, ends with a written report. The report is signed by all members of the investigation team. The chairman of the team presents the report to the Management Board of a given company of the Śnieżka Group in which the concern was raised.
The report constitutes the basis for providing the whistleblower with feedback on the follow-up actions taken, unless the feedback was provided before the report was issued as a result of an extended investigation.
A person employed at the Śnieżka Group company in which the concern was raised, each time recommended by the team in a report and appointed by the Management Board of that company, is responsible for monitoring the implementation of the recommendations.
The Śnieżka Group companies communicate all the procedures discussed in the form of a notification about entering the document in the internal system supporting the management of corporate documentation, together with the obligation for employees to familiarize themselves with them. Additionally, in order to build awareness and strengthen the message, the introduction of selected policies is communicated in the form of internal newsletters. Moreover, individual Group entities have obtained declarations from their key suppliers that they have read the Supplier’s Code of Conduct and comply with the principles contained therein, and key documents are available on the Group’s website.
In 2024, the Group companies did not organise any training in the field of counteracting corruption and bribery. In the entities described above that have adopted the whistleblower protection procedures, mandatory training in the internal reporting system was conducted. All persons exposed to the risk of corruption and bribery, including Members of the Management Board, were obliged to take part in it. Members of the Supervisory Board were trained in 2023, and during the reporting period they were kept informed about work on adapting the applicable procedures to Polish law.
In 2025, the company plans to conduct mandatory training for groups of employees most exposed to the risk of corruption and bribery.
Expenditures scheduled in connection with the implementation of the procedures were incurred in 2022 and included the remuneration of external advisors. Currently, the Group does not intend to carry out any anti-corruption activities that would require significant financial resources.
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