In KGHM we support the initiative related to the global challenge of sustainable development and the reporting of ESG (Environmental, Social & Corporate Governance) data. To meet the needs of our stakeholders we created this section to make it easier to find in one place all information associated with the reporting of non-financial information by KGHM Polska Miedź S.A.
To satisfy and comply with the increasing informational demands from capital market regulatory institutions and from society in general, as well as demands from investment funds, banks, customers and suppliers, KGHM has committed to the preparation and publication of an expanded scope of information regarding our environmental impact in compliance with EU regulations and international initiatives on the reporting of emissions and greenhouse gas reduction goals.
In 2020, for the first time in its history, KGHM Polska Miedź S.A. took part in the CDP (Carbon Disclosure Project) initiative. The questionnaire developed by CDP incorporates elements such as the management of emissions, risks and opportunities associated with climate change and business strategies. Many of these elements, such as risk analysis and emissions optimisation plans, are an everyday part of the Company’s operations. In the near future, KGHM expects to develop more detailed plans regarding its corporate development and strategic objectives in the area of climate change and impact.
In the following documents, incl. spreadsheets we provide data describing our operations in terms of our environmental footprint, actions taken for the benefit and well-being of society and employees, and corporate governance.
ESG composite data
Data on tailings storage facilities operated by the KGHM Group
Carbon Disclosure Project 2020
In KGHM we are cognizant of our obligations and responsibilities in terms of sustainable corporate development. For many years we have been developing and implementing Policies and Codes which reflect our commitment and approach to our natural and social surroundings.
The following Policies and Codes have been implemented within the KGHM Group.
The ecological policy of KGHM reflects the company's concern for the natural environments in which it operates. KGHM undertakes a number of actions to minimise its impact on the natural environment.
The main tenets of the environmental policy are:
- Maintenance of all equipment used to protect the natural environment in good working order,
- Identifying new technological solutions limiting industrial impact on the environment and implementing them as and when required and feasible,
- Development of waste management technologies and a continuous increase in the share of recycled waste in the total volume of generated waste,
- Ongoing partnership with the local communities and government authorities for the benefit of the environment,
- Collaboration with the Ministry of the Environment in terms of the implementation of national environmental policy,
- Cooperation when preparing BAT (Best Available Techniques) reference documents for the non-ferrous metals industry, and
- Cooperation with the European mining industry and non-ferrous metals industry in sectoral organisations when preparing EU documentation on environmental protection.
Protection of the natural environment and minimising the impact of the company's operations is a priority for KGHM. Thanks to its comprehensive environmental policy, KGHM sets the highest environmental standards.
The KGHM Group is preparing a climate policy which will serve as a systemic approach to implementation of the Communication by the European Commission in the form of Guidelines on non-financial reporting: Supplement on reporting climate-related information (2019/C 209/01), together with the Guidelines of the Task Force on Climate-related Financial Disclosures (TCFD) (in that part concerning Metals and Mining). It will also include the following medium-term (2030) and long-term (2050) quantitative targets:
- A decrease in direct GHG (scope 1) emissions, as well as indirect emissions (scope 2 and 3),
- Improved energy efficiency,
- Increased use of energy from renewables,
- Minimalisation of activities in regions exposed to long-term or excessive physical risk,
- A higher share of products connected with activities meeting the criteria of having a substantial impact on mitigating the effects of climate change or capable of being adapted to mitigating the effects of such change,
- Commitment to the system of green financing arising from the new Green Bonds taxonomy announced on 19 June 2019.
Code of ethics
The Code of Ethics of the KGHM Polska Miedź S.A. Group is the main tool in our corporate culture which assists in the setting of priorities and establishing a collection of principles which are binding for all of our employees in their daily work. The Code of Ethics is a guide to proper conduct at work and helps us in our daily decision-making. It makes us stronger as a team. It also supports our image as a stable, responsible, and socially-engaged company.
Code of conduct
In June 2018 the Management Board of KGHM Polska Miedź S.A. adopted the Code of Conduct of KGHM Polska Miedź S.A. At the same time the Company declared its commitment to sustainable development, based on respect for ethical principles, transparency and best industry practice, and commitment to being a socially and environmentally responsible enterprise, grounded on the KGHM Group’s Code of Ethics. Both documents regulate behavior standards that the Company is guided by. The Codes are an integral, mutually interconnected whole, based on consistent assumptions and values followed by the Company.
KGHM Polska Miedź S.A. has adopted an OHS Policy. The life and health of employees and workplace safety in general is the chief priority in the hierarchy of values of the KGHM Polska Miedź S.A. Group. For several years the Company has advanced its vision of „Zero accidents due to human and technical errors, zero occupational illnesses among our employees and contractors”. As a result of the adoption in December 2018 of a new strategy to the year 2023, in 2019 a conceptualisation of the strategy in the area of occupational safety was prepared through formulation of the Employee Safety Improvement Program „Think About The Consequences” as well as a Program to prevent the most common hazards to workplace safety by utilising innovative technology.
The Company applies high OHS standards, both towards its own employees as well as towards those providing services on the grounds of KGHM Polska Miedź S.A. Each of the Company’s Divisions has implemented a safety management system which is compliant with standards in force to date, and in 2019 preparations commenced to implement a new OHS standard compliant with the ISO 45001:2018 standard. All work stations have identified threats. The Company has assessed occupational risks and updates them continually. Working environments are continually monitored and periodic reviews and potential threat assessments are conducted, as well as reviews of equipment and required technical checks and approvals. Employees undergo systematic training and continually enhance their qualifications.
The KGHM Polska Miedź S.A. Group does not have in place a shared Diversity Policy in written form. Taking into consideration the international nature of our activities, cultural differences and specific natures of the Group’s industries, each company has been performing a number of actions in the area of respect for diversity. In view of the above, the independent Diversity Declaration has been defined at KGHM Polska Miedź S.A.
The Company complies with the prohibitions of discrimination and takes actions in order to ensure respect of diversity in the workplace. It creates an organizational culture based on mutual respect, equality, access to development opportunities and optimal use of employee talent regardless of ethnic origin, age, gender, nationality, citizenship, religious orientation, political convictions or trade union membership, among others. It aims at ensuring reasonable diversity both in the selection of personnel (including in the recruitment process), with special focus on knowledge, technical competence and social skills.
The Parent Entity guarantees the implementation of the diversity principle across the KGHM Polska Miedź S.A. Group, and promotes and popularizes these values among its stakeholders and business partners.
The management of diversity also pertains to members of the Supervisory Board and Management Board of KGHM Polska Miedź S.A. The management and supervisory teams are composed of persons of different gender, age and experience. More information on the approach to diversity in the supervisory bodies is presented in the Statement on Corporate Governance in The Management Board’s Report on the activities of KGHM Polska Miedź S.A. and of the KGHM Polska Miedź S.A. Group in 2019.
Declaration on human rights protection
The KGHM Polska Miedź S.A. Group does not have in place a shared Human Rights Protection Policy. Taking into consideration the international nature of our activities, cultural differences and specific natures of the Group’s industries, each company engages in a number of actions to protect human rights. Consequently, an independent Declaration on Human Rights Protection has been defined at KGHM Polska Miedź S.A.
KGHM Polska Miedź S.A. declares that it recognizes, respects and promotes human rights wherever it conducts its business. It does not tolerate any violations of human rights. We undertake to operate in compliance with the United Nations’ Universal Declaration of Human Rights and other norms and standards, including the statutory and executive regulations of the home countries of our business operations.
KGHM Polska Miedź S.A. is a global organization, aware of the importance of respect for human rights in the modern world. The Company accepts responsibility for protection and respect for fundamental human rights and implements such standards across the KGHM Polska Miedź S.A. Group. It also assumes that respect for human rights by other entities is a vital element of mutual relationships.
In compliance with the adopted principles, each employee and collaborator of the KGHM Polska Miedź S.A. Group is responsible for ensuring that in his/her closest environment human rights are respected, and any infringements are reported according to the agreed procedure. This Declaration is the basis of our approach to human rights. It supplements and consolidates the human rights issues contemplated in other policies and guidelines of the Company, such as the Code of Ethics, the Diversity Declaration, HR and the Responsible Supply Chain Policy.
The Declaration is implemented in the following manner:
- Each employee provided with access to a computer receives the adopted declaration electronically, via the Company Document Circulation System, while employees with no access to a computer for work purposes are informed of the declaration implementation via extranet (accessible to all employees) and by their direct superior.
Infringements are reported as follows:
- Employees have the right and obligation to report an infringement of the Declaration on Human Rights Protection to their direct superiors;
- Employees may report infringement to the trade unions operating in the Company (in KGHM Polska Miedź S.A. there are 15 trade unions, which have established 48 company trade organizations; the trade union membership percentage ratio in the Company is 88.6%). KGHM Polska Miedź S.A. acts in compliance with the Collective Bargaining Agreement;
- Infringements may be reported to the Occupational Safety and Health Committee;
- Employee Council Institutions are present in the Company, and in the case of Whistleblowers (Ethics Hotline) report to the State Labour Inspection Service (PIP).
Responsible supply chain policy
The KGHM Group is fully cognizant of the fact that the selection of responsible suppliers, especially as regards the sourcing of conflict minerals (such as gold, tin, tungsten and tantalum), is of key importance for conducting activity oriented on sustainable development.
Consequently, in December 2015, KGHM launched an internal system of responsible supply chain management by formally adopting the KGHM Polska Miedź S.A. Group Responsible Supply Chain policy and the Responsible Gold Supply Chain Audit Procedure in KGHM Polska Miedź S.A. In 2019, the Company updated the Supply Chain Audit Procedure with respect to gold and silver with a view to ensuring compliance with LBMA Responsible Gold Guidance V8 and LBMA Responsible Silver Guidance V1. The system is subject to regular independent external audits.
It is important to underline the fact that the KGHM Group does not tolerate, support, contribute to or benefit from:
- Violating the principles of occupational health and safety,
- Child labour or any form of forced labour,
- Violating the right of association,
- Violations of international humanitarian law,
- War crimes, genocide or any crimes against humanity, including indigenous peoples,
- Money laundering and terrorist financing.
The Remuneration Policy for the Members of the Management and Supervisory Boards of KGHM Polska Miedź S.A. is aimed at achieving the business strategy of KGHM, as well as the long-term interests and stability of the Company.
There is a Competition Law Policy in the KGHM Polska Miedź S.A. Group. Its purpose is to establish the operational framework for the system to ensure compliance with the competition laws prevailing in all the countries in which the KGHM Polska Miedź S.A. Group operates.
KGHM Polska Miedź S.A. is guided by high ethical standards across the procurement process. The Code’s main message is to guarantee the professionalism and honesty of the persons responsible for the procurement process. The document also contemplates issues such as preventing conflicts of interest as well as equal treatment of suppliers to ensure compliance with the principles of fair competition.
The procurement procedures in effect in KGHM are precisely defined in the Procurement Policy and business partners are selected in accordance with the principle of equal treatment.
In tender documentation, the Company reserves the right to audit its suppliers and to assess their activities in terms of compliance with human rights and regulations governing the hiring of minors. External entities are also checked in order to secure the interests of KGHM, in the context of money laundering, breaches of fair competition rules, prevention of conflict of interests, etc.
Procedure for counteracting money laudering and the prevention of fraud and extortion…
...in trading transactions regarding the sale of products and the procurement of ore and copper-bearing materials of KGHM Polska Miedź S.A.
KGHM uses a diverse range of external counterparty verification in the procurement, sales and investment processes, which are regulated by a number of consistent and uniform internal policies and procedures. This procedure covers verification methods used for the purposes of trading transactions. To protect its image and the Company’s security, KGHM takes measures to prevent the Company from being used by third parties for unlawful purposes, such as money laundering, financing of terrorism or VAT extortion.
The security measures undertaken in this respect consist of:
- Client identification and verification of its identity based on the data provided by the Client, publicly available information and/or reports of credit bureaus,
- Undertaking, with due diligence, actions to determine the ownership as well as organizational structures or the Client’s links to other entities, in order to identify the Beneficial Owner of the transaction and verify its identity, using publicly available information and/or reports of credit bureaus,
- Obtaining information on the Client’s objective and intended character of the business relationship, using publicly available information,
- Monitoring of the business relationship with the Client, including completed transactions, in order to check if they are consistent with the Company’s knowledge of the Client and its business profile, and - if possible - examining the source of funds.
The Anti-Corruption Policy in effect in the KGHM Polska Miedź S.A. Group was adopted in July 2018, pursuant to the Resolution of the Management Board of KGHM Polska Miedź S.A. The Policy establishes detailed standards of conduct in corruption-prone situations and identifies the criminal liability in case of abuse. The KGHM Polska Miedź S.A. Group underscores its commitment to fighting corruption in business, by the way of adopting and uncompromising observance of the “zero tolerance for corruption and bribery” rule. Employees are prohibited from offering or accepting material benefits in relation to the performance of professional duties.
The only exception is giving and accepting business gifts in line with the local norms and cultural customs, provided that the giving and accepting of gifts cannot lead to a situation in which such behavior could be considered as an attempt to exert pressure or persuade the recipient to act against their duties. Detailed rules pertaining to giving and accepting of customary business gifts have been defined as an instruction under the Corruption Threat Prevention Procedure. Employees are required to avoid any actions or decisions in a situation of a conflict of interests. Particular control under the Policy is over business procurement transactions, including an option of a third party audit, in order to ensure that such transactions meet the highest standards of ethical and transparent business operations. The KGHM Polska Miedź S.A. Group Entities and their Employees may be held accountable for actions of persons or entities acting on their behalf or for them.
The Policy also states that the Group Entities and their representatives are obliged to observe all statutory provisions, guidelines of administration bodies and other state authorities, as well as domestic and international legal acts designed to fight corruption. The Policy also states that KGHM Polska Miedź S.A. and the Group Entities and cooperating entities are obliged to follow international legal acts designed to fight corruption, e.g. the U.K. Bribery Act of 2010, the U.S. Foreign Corrupt Practices Act, Canadian Corruption of Foreign Public Officials Act of 1999 and guidelines contained in international agreements, e.g. the OECD Convention or the guidelines of UN Global Compact as regards responsible business and fight with corruption.
The document stipulates that Employees of the Group and external partners are obliged to report any suspicion of breaches to the Policy and the Corruption Threat Prevention Procedure, directly to the Security Department of KGHM Polska Miedź S.A. or via the dedicated channels of abuse reporting.
Every report is confidential and followed up with due diligence. The KGHM Polska Miedź S.A. Group uses a range of tools to effectively implement the Policy’s objectives, including first of all procedures, instructions, remedies and control mechanisms, which specify in detail the standards of conduct in corruption-prone situations.
The actions taken by KGHM to protect the natural environment, to care for its employees, their families and the people of the regions where we operate, while applying the highest corporate governance standards, have for many years been a key element of our corporate identity. Our efforts have been recognised by prestigious international institutions such as FTSE Russell, MSCI and by our own Polish exchange – the shares of KGHM are a component element of the FTSE4Good Index Series and the WIG-ESG index. In 2020, for the first time in its history, KGHM participated in the Carbon Disclosure Project, entailing communication of the company’s environmental footprint in terms of greenhouse gas emissions. For our initial report we provided CDP with responses to the Climate Change questionnaire. In subsequent stages of the project we intend to expand our reporting to include information in the Water Security and Forests questionnaires.
What are KGHM’s plans for the immediate future as regards reducing CO2 emissions?
The following actions have aided in the reduction of direct emissions by KGHM:
- The construction and start-up of a new flash furnace smelter at the Głogów Copper Smelter and Refinery;
- The long-term increase in the share of scrap as charge material (among others through the use of the RCR scrap processing furnace at the Legnica Copper Smelter and Refinery; the processing of relatively clean scrap means lower carbon dioxide emissions and is in line with the principles of closed economy operations);
- Technological improvements (e.g. in terms of fuels).
The largest drop in emissions was recorded at the Głogów metallurgical facility thanks to a change in technology from shaft furnace to flash furnace smelting. This change in technology lead to a total decrease in CO2 emissions (indirect and direct) by around 25%. Further reduction of KGHM’s carbon footprint will mainly be based on the consumption of electricity generated to an ever greater degree from low- or zero-emission sources. This in turn leads to lower indirect emissions, which, jointly with the trend towards electrification (increasing use of electricity as a source of energy for industrial processes) which also result in the long term to substantially lower direct emissions.
Over the next 24 months the KGHM Polska Miedź S.A. Group plans to bring on-line solar power plants of over 10 MW, which on an annual basis will enable a decrease in emissions of CO2 and other nitrogen and sulphide compounds and of dusts of more than 8 thousand tonnes.
KGHM ZANAM, a company belonging to the KGHM Group, is investing in a solar power plant with a capacity of 3 MWp. The photovoltaic power plant was opened in December 2020 and is the first such power plant in Poland which will operate based on 4.0. technology. The facility will be fully computer-controlled and automated, equipped with a Control Room and built under the guidelines of the International Energy Agency for the construction of solar power plants.
We are also considering investments in wind farms, though this is dependent on changes in the regulatory environment.
What actions are being taken by KGHM to encourage their suppliers to cut emissions?
Due to increasing demands by regulators and society in general, including investment funds, the Company is in the process of preparing to publish an expanded scope of information on its environmental impact in compliance with guidelines announced by the EU and by international initiatives on the reporting of emissions and GHG reduction goals.
In 2020, for the first time in its history, KGHM Polska Miedź S.A. participated in the Carbon Disclosure Project (CDP). The questionnaire contains elements involving the management of emissions, risks and opportunities, business strategy, etc. Many of these elements, such as risk analysis and emissions plans, are an everyday part of the Company’s operations. In the near future, KGHM expects to develop more detailed plans regarding its corporate development and strategic objectives in the area of climate change and impact.
Is KGHM aware of any regulatory activities which could facilitate the process of reducing the company’s carbon footprint?
Regulations which could aid in reducing KGHM’s carbon footprint can be divided into two groups. The first involve technical changes which could facilitate operations in the company based on its own sources of energy and its own distribution system. These include:
- Amendment of the legal definition of direct lines to the demands of RES and power purchase contracts (simplification of the process of obtaining direct line status for generation sources connected to plant networks);
- Streamlining regulations for the functioning of Closed Distribution Systems (removing from companies such as KGHM – which hold the status of Distribution System Operator, but are not professionally involved in this sector – administrative obligations unrelated to its own activities);
- Minimising bureaucratic obstacles arising from rules for the functioning of power systems – such as regulations for the balancing of energy and regulatory accounts;
- Reinstituting support for high efficiency cogeneration systems for internal company use – a strong stimulus supporting investments in low-emission natural gas cogeneration.
The second group of regulations involves the financing of investments in new generation sources and power networks. In particular we believe that an energy-intensive industry investing in its own generation capacity should be allowed to utilise the funds accumulated in the Modernisation Fund and the Fair Transformation Fund.
We also wish to point out that the quickest method to reduce emissions is by investing in renewable energy sources. Solar power plants can be built fairly rapidly, but unfortunately the preparatory procedures are much more time consuming. It is worth considering changes to the requirement to include in municipal planning documents the need for permission for solar power plants with capacity above 100 kW (perhaps 500 kW in future based on a draft bill to alter the RES law). For example, consideration could be made of foregoing such a requirement for industrial terrain or areas designated for economic activity.
In terms of energy from wind power it is crucial to enable investments in technically advanced and economically mature solutions. The wind turbines available today require the use of tall masts, which is directly bound to the need to liberalise the so-called 10H principle. The directions of changes currently announced are a good example of this.
What do KGHM feel are the barriers and difficulties involving the implementation of initatives related to decreasing CO2 emissions?
Barriers to transformational initiatives are in the first instance the availability of technology and its costs. There remains a lack of economical and applicable solutions for the capture and storage of carbon dioxide (CCS). Without cheap technology it is impossible to completely eliminate emissions. Much can be achieved by applying low- or zero-emissions energy sources, but to successfully do so financing remains a critical element (preferably non-refundable grants, in terms both of capital expenditures and operating costs), as well as appropriate regulatory support.