The Code also defines the communication of its provisions, including provisions related to raising concerns by value chain workers. The document expresses the clear expectation of the Śnieżka Group so that each of its suppliers can communicate the practices and principles described in the Supplier’s Code of Conduct to all of its employees and subcontractors and pursue an active communication policy in this respect. Confirmation of knowledge and compliance with the Code is a requirement for cooperation with the Group, and the undertaking reserves the right to verify that its direct suppliers comply with provisions therein. This verification may be carried out in various ways, such as self-assessment surveys or audits at the supplier’s facilities, with sufficient advance notice. Further information regarding this subject can be found in chapter Business.
Value chain workers
Area management
[S2-1]
The dual materiality assessment conducted by Śnieżka Group identified one potentially negative impact on value chain workers related to the lack of active communication of existing channels for reporting unethical behaviour.
The channels for raising concerns by value chain workers are described in the Supplier’s Code of Conduct of the Śnieżka Group adopted throughout the undertaking.
- responsible management of environmental issues,
- compliance with human and employee rights protection standards,
- work safety,
- social involvement,
- compliance of the conducted business activities with the provisions of the law.
The document was approved by the boards of the companies, which are also responsible for implementing its provisions within the undertaking. The provisions of the regulations refer to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights and cover all of the Group’s suppliers, regardless of the type of activity, method of order fulfilment, place of operation or cultural differences. In the undertaking’s opinion, compliance with the principles of the document constitutes the basis for common business relations.
The Code is a publicly available document, posted on the Śnieżka Group website and attached to contracts with suppliers. No consultations were conducted with the key stakeholders when establishing the content of the Code.
- comply with international standards for the protection of human and employee rights, in particular the prohibition of forced labour, slavery, child labour under the age of 15 and the provision of special care to employees under the age of 18;
- counteract discrimination based on sex, race and ethnicity, age, religion, psychosexual orientation, worldview, disability and type of employment;
- counteract mobbing and harassment;
- respect workers’ rights to freedom of association and collective bargaining where permitted by local law.
Additionally, the Group’s Respect for Human Rights Policy declares that the undertakes will make every effort to respect and promote human rights in relations with business partners and defines expectations towards them, including: ensuring freedom of assembly, eliminating exploitation, forced labour, human trafficking and child labour, and preventing discrimination and respecting the rights of local communities. The Policy provisions are based on the Universal Declaration of Human Rights.
The Group has not recorded any cases of human rights violations in the value chain and, if they occur, it is committed to taking action to eliminate such violations or, in extreme cases, to terminate cooperation with the contractor.
[S2-2]
The Śnieżka Group engaged value chain workers in the stakeholder survey. The Group sent a survey to suppliers, the questions of which concerned, inter alia, the social area, and were answered by representatives of the surveyed entities. The survey included open-ended questions concerning the area of human rights. Additionally, the parent company conducted a self-assessment survey among suppliers, containing questions about employee rights and the employment of minors. The survey allowed for verifying the effectiveness of the actions taken, determining the level of security and knowledge of the procedures in force in the Group among its suppliers. It is planned to conduct a similar self-assessment among suppliers of other companies by 2026.
In the Śnieżka Group, there is no entity operationally responsible for the engagement of value chain workers, but it is planned to assign this role to the Procurement Department.
The Group is not party to the global framework agreement or agreements with world trade union federations regarding respect for the value chain worker’s rights.
[S2-3]
The Śnieżka Group has not implemented a formal policy to deal with the occurrence of serious negative consequences for the value chain workers. The Group companies treat each such case individually and act in accordance with the law, in particular the Labour Code, respecting the individual needs of the value chain workers.
The channels through which the value chain workers can raise concerns are defined in the Supplier’s Code of Conduct and described in chapter Business herein. The Śnieżka Group obliges its suppliers to provide their employees with information about the provisions of the Supplier’s Code of Conduct and to upload it on a publicly available website. The method of considering and monitoring concerns from the value chain workers is the same as the method of considering concerns from own workforce and is described in chapter Business. The Group has not implemented any mechanisms to assess the familiarity with the tool or the level of trust of the value chain workers in the channels for raising concerns provided by the undertaking.
[S2-4]
Due to the nature of its activities in this area, the Group has not applied all the disclosures required by the Minimum Disclosure Requirements for activities and resources (MDR-A). The Śnieżka Group conducts on-going monitoring of possible reports through available channels for raising concerns. In 2024, the undertaking did not receive any reports of violations from the value chain workers and therefore no action was taken or resources allocated to this area. Due to the lack of reports, the Group does not plan to allocate funds in 2025 to finance activities that have material impacts on the value chain workers. In 2024, the Group companies did not undertake additional initiatives or processes aimed at ensuring a positive impact on the value chain workers. During the dual materiality assessment, the Group also did not identify any material risks or opportunities related to the value chain workers. Therefore, the Group does not intend to take any actions in this area in 2025.
In the Group’s assessment, its own practices do not cause or contribute to any material negative impact on the value chain workers. The undertaking conducts its business activities with care for the environment, the local community, employees and other stakeholders As highlighted in chapter Business, the condition for cooperation between suppliers and Śnieżka Group is so that they can become familiar with the Supplier’s Code of Conduct and submit a declaration of readiness to comply with it, in which they declare their readiness to undertake ethical business activities throughout the entire value chain.
The basis for these activities constitute the Sustainable Development Strategy, the Code of Ethics and internal policies. The Group companies also apply internationally recognised standards such as the UN Global Compact and the UN Guidelines for Multinational Enterprises. In 2024, the Group recorded no serious human rights issues or incidents related to its upstream or downstream value chain.
Targets related to value chain workers
[S2-5]
The Group has not set targets related to the identified potential impact on the value chain workers related to the lack of active communication regarding channels for reporting unethical conduct within the Group. The possibility of raising concerns, channels and protection of the whistleblower are described in the Code of Ethics and the Supplier’s Code of Conduct.
The Group does not monitor the effectiveness of its policies and actions regarding material impacts on the value chain workers. The planned mitigation action is to improve the exposure of the unethical behaviour channels for raising concerns on the Śnieżka Group website in order to increase its visibility.