Counteracting corruption

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The Anti-corruption policy broadly defines the understanding of corruption and bribery in the Śnieżka Group, emphasizing that not only corrupt activities are prohibited, but also any activities contrary to the principle of fair competition, constituting crimes or offenses related to economic transactions. The policy prohibits promising, proposing, soliciting or giving material or personal benefits, accepting benefits from contractors or giving unauthorized preference to certain contractors. The policy also prohibits the Group companies from building relationships with public administration in a way other than meeting legal requirements.

The Śnieżka Group allows – in the case of establishing or maintaining appropriate business relationships – customary gifts that do not constitute significant value. In accordance with the provisions of the Anti-Corruption Policy, accepting or giving a gift should be accompanied by the certainty that such action will not result in negative consequences for any of the parties. It is not permissible to accept or give gifts before establishing a business relationship. Any circumstances related to accepting a gift or participating in any form of meeting at the expense of the giver should be reported to the direct superior of the employee to whom the situation applies. The Group prohibits accepting or giving gifts in the form of money.

Pursuant to the provisions of the Policy, the Company should be represented by two people when working on key contracts. In order to ensure the transparency of the purchase process, the Anti-Corruption Policy recommends the principle of selecting the offer that is most favourable in terms of price and feasibility.  Except for justified cases, this selection should be made from among at least three written offers and be preceded by negotiations. Communication conducted by the Group’s employees should be preserved in a manner that allows it to be precisely traced, and business contacts with contractors, clients and co-workers should be documented through archived correspondence.

All information about behaviour inconsistent with the Policy can be submitted through the channels described in the Internal Reporting Procedure and the Procedure for Considering Notifications currently applicable in the following companies: FFiL Śnieżka SA, Śnieżka ToC and Poli-Farbe Kft. Notifications of events bearing the signs of corruption are received and considered by one team common to the Group companies, which includes the FFiL Śnieżka SA Compliance Officer and the Corporate Governance Officer, who is also responsible for supervising the Policy.

The Śnieżka Group has not adopted a separate procedure for submitting reports on the results of investigations to the administrative, management and supervisory bodies. In the Anti-Corruption Policy, the Group undertakes to notify law enforcement authorities of any violations of the law, and the issues of reporting the results of internally conducted proceedings are regulated in the Procedure for Considering Notifications.

All anti-corruption procedures are communicated to employees by sharing documents in the internal document management system, notifying them of their availability and introducing the obligation to read the content. Information about the implementation of selected policies is also published in internal newsletters. The Group’s anti-corruption stance is known to suppliers and described in the Supplier Code – FFiL Śnieżka SA obtained declarations from its key suppliers about getting familiarized with the Supplier Code and observing the principles contained therein.

In 2023, the Group did not conduct anti-corruption training.