Code of ethics

The Śnieżka Group operates in strict compliance with ethical and social standards and effectively counteracts corruption and abuse. Compliance with regulations is ensured by comprehensive policies, procedures and other internal regulations, and in addition, a Corporate Governance department has been established in the structure of FFiL Śnieżka SA, responsible for the implementation of tasks related to overseeing the compliance of activities with the law.  Corporate Governance is also responsible for the corporate governance cascade in the Group companies.

The Code of Ethics – applicable in the Group since 2022 – contains standards of conduct for all employees of the Group. Its purpose is to facilitate making the right choices by identifying patterns and ethical norms that are essential to the Group’s operations.  The content of the Code is available at: https://sniezkagroup.com/serwis-esg/polityki-i-dokumenty-esg/ and in the Group’s internal IT system.

This document integrates the most important regulations regarding the sustainable development of the Śnieżka Group. When setting general patterns of conduct, the Code of Ethics refers to individual policies and regulations implemented within the Group companies. The unit overseeing compliance with it is the Management Board of FFiL Śnieżka SA.

Areas regulated in the Code of Ethics:

  • Employee relationships
    • health and safety of employees (Personnel Policy, Quality, Environmental and Health and Safety Policy)
    • a friendly workplace (Personnel Policy)
    • counteracting discrimination and mobbing (Diversity Policy and the Regulations for Counteracting Mobbing, Discrimination and Harassment)
    • forced labour, child labour and freedom of assembly (Policy of Respect for Human Rights)
  • Environment relations
    • Relations with suppliers (Procurement Policy, Supplier Code)
    • Customer relationships
    • Relations with local community (Social involvement policy)
    • Natural environment (Quality, Environmental and Health and Safety Policy of the Śnieżka Group, Climate Policy)
  • Corporate governance and ethics
    • counteracting corruption (Anti-Corruption Policy)
    • conflict of interest (Anti-Corruption Policy)
    • responsible communication (Information policy)
    • protection of data and confidential information (Information Policy, Digital Security Policy)

  • Good practice

    The Code of Ethics contains a practical guide for employees who have second thoughts how to behave in a given situation. The document prompts six simple questions that can assist an individual to make the right decision:

    • Is it legal?
    • Is it in line with our organizational values?
    • Is this appropriate?
    • Do I have good intentions?
    • Would I be proud to tell my friends, co-workers or anyone else about it?
    • Could my action jeopardize someone’s life, health, safety or reputation?

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  • Reporting violations

    Objective of sustainable development strategy

    Strategic objectives:

    • Management of the anti-corruption and fraud area

    Operational objectives for 2023:

    • Implementation of a dedicated tool

    Achievement of objectives:

    • Implementation of the EY Virtual Compliance Officer tool

An integral part of the Code is information on how to report behaviour inconsistent with the values of the Śnieżka Group. Violations can be reported via the confidential reporting channel on the website www.sniezkagroup.com, by e-mail to zgloczenia.zarzad@sniezka.com or by letter addressed to the President of the Management Board. The Śnieżka Group undertakes to protect employees and business partners revealing violations of the law or the provisions of the Code of Ethics against the adverse effects of a decision to disclose irregularities and to apply applicable law to persons violating the personal rights of employees and their business partners.

The channels for reporting violations are the same for all companies and are included in the Code of Ethics. Additionally, in 2023 at FFil Śnieżka SA and Śnieżka ToC, and in 2024 at Poli-Farbe Kft., the Internal Reporting Procedure and the Procedure for Considering Notifications were implemented. These procedures create an additional system for reporting and considering irregularities and violations, including: internal codes, policies, procedures and instructions.

A reporting individual may submit a notification via the dedicated online tool EY Virtual Compliance Officer, intended for reporting, available at https://sniezkagroup.vco.ey.com/. A link to the tool is available on the corporate website of each company (FFil Śnieżka SA, Śnieżka ToC, Poli-Farbe Kft.).

The EY Virtual Compliance Officer online tool also enables to report anonymous notifications, with the possibility of communication between the team accepting notifications and the reporting person by means of anonymous logging in by the reporting person using a generated token.

Notifications are received and considered by one team common to all companies, which includes the Corporate Governance Officer and Compliance Officer employed at FFiL Śnieżka SA.

Team members underwent training/workshops on the internal reporting system as part of the project to implement EY Virtual Compliance Officer procedures and online tool, in cooperation with external consultants from EY.

Employees were informed about the launch of the channel in an internal newsletter. Each person employed at FFiL Śnieżka SA and Śnieżka ToC was also obliged to complete a dedicated online training in the reporting system by March 1, 2024, while by the end of December 2024 the same training will also be conducted at Poli-Farbe. The procedures governing the reporting system are also available to employees in the intranet document management system.

  • Good practice

    Through the EY Virtual Compliance Officer, it is possible to submit information on a named or anonymous basis. Those who do not wish to reveal their identity can still communicate with the team accepting notifications and can log in anonymously using a special token. Not only can the system be used by employees, but also by contractors and persons acting on their behalf and job candidates. Thus, it meets the assumptions of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law. The criterion for accepting and considering notifications is their connection with the employment relationship or other legal relationship constituting the basis for the provision of work, or the performance of services or functions in a given company, under which information about the violation was obtained.

Whistle-blower protection

The Śnieżka Group has not implemented and does not plan to implement a separate whistle-blower protection policy. These rules are regulated in the Internal Reporting Procedure, a document consistent with Directive (EU) 2019/1937 of the European Parliament and of the Council. The Internal Reporting Procedure prohibits retaliation against the reporting person, persons assisting in submitting the notification and persons associated with the reporting person. The whistle-blower is protected provided that they act in good faith, i.e. at the time of reporting, they have reasonable grounds to believe that the information about the violation is true.

One of the measures to protect the above-mentioned person is to protect their identity and to protect information that could directly or indirectly help identify them.  In addition, the Internal Reporting Procedure contains a list of examples of actions that constitute unfavourable treatment that may be considered retaliatory action against the reporting person.

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