Policies and Codes

Policies and Codes of the KGHM Group

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.

Natural environment

EnvironmentAL POLICY

The prevention and minimisation of environmental and climate impact as well as the rational management of our natural resources are of fundamental importance for KGHM Polska Miedź S.A. in its efforts to achieve sustainable development, to meet the expectations of our stakeholders and to be responsible towards future generations.

The activities of KGHM Polska Miedź S.A., including those involving exploration, mining, processing and refining, comprise technical and organisational actions based on best available techniques which reduce our environmental and climate impact.

Meeting such high environmental standards is crucial to maintaining the Company’s competitive position amongst the world’s copper producers.

Our strategy places particular emphasis on ecologically-friendly production and on protecting the natural  environment and climate, as well as on pursuing a circular economy, including the increased use of recycled materials.

Based on continual improvement under the PN-EN ISO 14001 Environmental Management System, the Company’s senior management is committed to the following:

  • the continuous prevention and restriction of the Company’s environmental and climate impact by improving and developing our technological processes, modernising and replacing equipment and preventing pollution and breakdowns,
  • the rational utilisation of our environmental resources, such as land, water and forests,
  • the rational management of our natural resources,
  • restricting the amount of waste generated and the continuous development of waste management methods,
  • restricting emissions to the air, water and soil,
  • restricting greenhouse gas emissions, while taking into account critical economic aspects,
  • restoring terrain adversely impacted by our activities,
  • the prudent application of new solutions and innovations, taking into account during their design and implementation their environmental and climate impact,
  • meeting the adopted and justified expectations of our stakeholders,
  • adherance to legal requirements and respect for ethical principles,
  • the active support of efforts to ensure biological diversity and, if that is not possible, to undertake appropriate compensatory actions,
  • the responsible management of land and green terrain,
  • open and honest dialogue with and respect for local communities and indigenous peoples as well as appropriate governmental authorities, aimed at strengthening protection of the environment and climate,
  • the responsible management of chemicals,
  • raising the professional qualifications and awareness of employees with respect to protection of the environment and climate,
  • shaping the attitudes of employees, contractors, customers and local communities to be more ecologically conscientious.

This Environmental Policy, adopted by the Management Board of KGHM Polska Miedź S.A., shall apply to the Head Office and to all of the Company’s Divisions, and is publically available, known to and applied by all of the employees and other persons working on behalf of the Company.


KGHM Polska Miedź S.A. (hereinafter referred to as “KGHM” or the “Company”), as one of the largest global copper producers, will have a significant impact on the successful transformation into a low-carbon economy. The new role will stem from having to satisfy the growing demand for copper, which is a key component of the green economy of the future. Apart from supporting the transformation directly by providing the key resource, KGHM will also contribute indirectly to the reduction of greenhouse gas emissions. Furthermore, given this perceived reality, KGHM sees the potential for increasing its role in the global economy – generating new, previously unattainable opportunities to improve the competitive potential of the Company.

The above-mentioned vision is expressed by the Climate Policy of KGHM Polska Miedź S.A., which aims to convey the following objectives:

  • to define the ambitions of KGHM Polska Miedź S.A. regarding the reduction of its impact on the climate and to adapt the operations of the Company to fulfil these ambitions,
  • to describe how the Company’s operating model should be adapted to the existing and predicted climate change.

Read more:
Climate Policy of KGHM Polska Miedź S.A. - document - 2nd Edition
Climate Policy of KGHM Polska Miedź S.A. - leaflet - 2nd Edition


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. 

Safety policy

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.

Diversity declaration

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 2020.

Gender Pay Gap Ratio

The Gender Pay Gap Ratio (GPGR) for wages paid to employees of KGHM Polska Miedź S.A., calculated as the percentage difference between the average monthly remuneration of women and men for 2020, amounted to (-)12.3%.

The ratio was calculated as follows: GPGR=|(AMW/AMM)-1|*100%


AMW = average monthly remuneration of women in the company,
AMM = average monthly remuneration of men in the company.

The difference respecting the aforementioned ratio for the company compared to the base value of zero, meaning complete equality (0%) reflects the nature of the operations and the resulting employment structure. The conditions and nature of the work in mining and metallurgy mean that the share of women in total employment amounts to 7%. As a consequence of these conditions, any change in the structure of employment which would result in an alteration of the gender pay gap ratio is not possible. 

Structure of diversity amongst management and supervisory staff of the Company as at 31 December 2021

Structure of gender diversityWomenMen
Supervisory Board27
Management Board-6
Structure of age diversity<40 years40-50 years51-60 years>60 years
Supervisory Board-423
Management Board-42-
Length of experience in KGHM Polska Miedź S.A.<5 years5-10 years11-20 years>20 years
Supervisory Board61-2
Management Board41-1

human rights pOLICY

We recognise that the protection of human rights is strategically important. In order to ensure that all human rights are fully protected and that this Human Rights Policy is up-to-date, continuous monitoring and analysis of the value chain is conducted. This Human Rights Policy is compliant with the implemented Corporate Risk Management Policy and Procedure and contains the identified risks regarding potential human rights violations in the Company’s operations along with their mitigation. Despite the limitations specific for the mining, steel and metal refining industries, we strive for continuous improvement of attitudes. This Policy is supported by the Company’s existing regulations and procedures which form part of this document.

KGHM Polska Miedź S.A. is a global organisation, aware of the role played by human rights in the contemporary world. As a company that plays a crucial role in the Polish economy, we accept the responsibility to protect and respect all internationally recognised human rights.

In KGHM Polska Miedź S.A. we pledge to protect, promote and implement human rights wherever we carry out our activities and towards all entities on which we have a direct or indirect impact. KGHM Polska Miedź S.A. does much more to protect human rights than is required by domestic law. We pledge to conduct our business in a manner consistent with the International Charter of Human Rights1, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Declaration on the Rights of Indigenous Peoples and the OECD Due Diligence Guidance on Conflict-Affected and High-Risk Areas. We declare that respect for human rights by other entities with which we cooperate is an important factor to be taken into account when establishing mutual business relations.

Any questions, comments and irregularities concerning human rights violations, can be reported through a Whistleblower Platform, which is accessible to all at the following link (for English choose EN): https://liniaetyki.kghm.com/web/liniaetyki/kanaly/

Statement on Respect for the Rights of First Nations and Indigenous Peoples

Responsible supply chain policy

As a KGHM Group we are committed to the highest standards of products’ manufacturing, business ethics and business conduct in our day to day operations. We follow these rules in our value chain creation process, which is reflected in the KGHM Group Code of Ethics.

KGHM is fully aware that the selection of responsible suppliers is crucial for conducting activities oriented towards sustainable development.

To ensure the highest standards regarding obtaining metals from conflict-affected and high risk areas, KGHM has adopted risk-based due diligence, which allows to identify high-risk business relationships based on the criteria set out in the The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, The LBMA Responsible Gold Guidance, The LBMA Responsible Silver Guidance and Joint Due Diligence Standard for Copper, Lead, Nickel and Zinc implemented in KGHM’s Smelting/Refining Divisions.

We do not tolerate, support, contribute to or benefit from:
• any forms of torture, cruel, inhuman and degrading treatment,
• any forms of child labour or of forced or compulsory labour,
• minorities discrimination,
• violations of international humanitarian law,
• war crimes, genocide or any crimes against humanity,
• violating the rights of indigenous peoples,
• money-laundering and financing of terrorism,
• all forms of corruption and other activities related to economic crime, including financial fraud,
• degradation of cultural and natural heritage sites,
• violating health and safety rules,
• violating the right of association,
• other serious human rights abuses.

KGHM have formalized our responsible supply chain management system by approval of the KGHM Polska Miedź S.A. Group Responsible Supply Chain policy, the Responsible Gold Supply Chain Audit Procedure in KGHM Polska Miedź S.A. and the “Due Diligence Procedure For Copper And Lead Supply Chain at KGHM Polska Miedź S.A.”

The system is audited on a regular basis by a 3rd party.

Corporate Governance

Management System – ISO Standards

Management systems according to ISO standards are internationally recognised standards that indicate to companies the optimal way to operate. Implementing and improving systems is therefore not a fad, but an essential tool for ensuring competitiveness. ISO certification proves that the company meets certain requirements and standards, and because they are international standards, the organization gains recognition around the world. The current state of implementation and certification of standardised management systems in the Head Office and Divisions of KGHM Polska Miedź S.A. is presented at Management System site.


The Corporate Risk Management Policy of the KGHM Polska Miedź S.A. Group describes the approach to risk management, the basic principles involved and the process of corporate risk management in the KGHM Polska Miedź S.A. Group. This comprehensive approach to risk management is consistent with the strategy of development, continuous striving for operational excellence and the principles of sustainable development and responsible business. It was designed so as to be able to support the Company in building a rugged corporate structure.


The Compliance Management Policy of the KGHM Polska Miedź S.A. Group describes the approach to compliance management, the basic principles involved and the process of compliance management in the KGHM Polska Miedź S.A. Group. We recognise compliance as an important element of our effective operations and we have a compliance management process which is linked to the process of managing corporate risk in the KGHM Polska Miedź S.A. Group. The compliance system is an important business tool used to prevent the occurance of events which could lead to sanctions.


The Continuity of Operations Management Policy of KGHM Polska Miedź S.A. describes the approach to continuity of operations management, the basic principles involved and the process of continuity of operations management in KGHM Polska Miedź S.A. We recognise the continuity of operations as an important element of our effective operations and we have a continuity of operations management process which is linked to the process of managing corporate risk in KGHM. The continuity of operations management system is an important business tool used to increase the Company’s ability to deal effectively with crisis situations by minimising the impact of catastrophic events, protecting KGHM’s reputation and its shareholder value.

Energy Policy

Efficient and effective energy management is of fundamental importance for sustainable development, the Company’s values and occupational safety. KGHM Polska Miedź S.A.'s primary goal in terms of energy management is to pursue a rational energy management policy while ensuring the highest quality of the products and services provided, safe working conditions and the highest standards of environmental protection and at the same time guaranteeing the security of power supply to the facilities and installations. Our ambition is to continuously increase the share of renewable sources of energy and internal generation to cover our energy needs - by 2030 we want 50% of the power consumed by the company to be supplied from our own generating sources, including renewable energy.

The basic principles of energy management at the Company, the aspirations and the management staff's commitment are included in the Energy Policy of KGHM Polska Miedź S.A. (translation in progress)

Remuneration policy

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.

Competition policy

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.

Procurement policy

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.

Anti-corruption policy

As a result of the implementation by the KGHM Polska Miedź S.A. Group of an Anti-Corruption System in compliance with the PN-ISO37001 standard, in December 2021 the Management Board adopted a resolution regarding a new Anti-Corruption Policy.

Under this policy, the KGHM Polska Miedź S.A. Group emphasises its commitment to fighting corruption in its business by the adoption and uncompromising observance of the “zero tolerance for corruption and bribery” rule whilst at the same time remaining compliant with laws in force as well as voluntary strictures aimed at combating corruption.

The adopted Policy applies to all of the employees of the Company and of the KGHM Group, as well as to our business partners, including suppliers and customers. The Policy forbids participation in any activity suspected of involving corruption of any sort, including the offering, promising, granting, accepting, demanding or otherwise seeking of undue material benefits, whether of a financial or non-financial nature, in particular as regards the carrying out of one’s official duties. The Policy also forbids the taking of any actions against persons who refuse to grant or accept undue material benefits.

Under the Policy, anyone who takes part in or witnesses an activity which is suspected of being corrupt in nature, or who possesses information regarding such an event, is obliged to immediately report this information, whilst senior management are obligated to ensure that secure, dedicated channels of communication are provided to whistleblowers, as well as to ensure that such whistleblowers are protected from retribution.

The Policy provides for disciplinary actions to be taken towards individuals who commit breaches of the anti-corruption rules.

Persons have been appointed in every KGHM Group entity who are tasked with ensuring compliance with the anti-corruption rules, and who have been granted the appropriate level of authority whilst maintaining their independence and impartiality.

The Policy has been communicated and is generally available to all employees, third parties and other persons working for or on behalf of our organisation.

Under the principle „prevention first and foremost”, in the KGHM Group we manage the risk of corruption by identifying and eliminating those factors responsible for increasing such risk through the implementation of adequate oversight mechanisms. As part of the Anti-Corruption System, a resolution of the Management Board of KGHM Polska Miedź S.A. was adopted on new procedures to manage corruption risk, ensuring the compliance of the activities undertaken by entities in the KGHM Group with the adopted Anti-Corruption Policy. Among others, these procedures regulate questions such as business gifts, situations potentially involving corruption and conflicts of interest.

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 in the Corruption Threat Prevention Procedure.

Employee training programs on ethical conduct and regular audits of ethical standards and anti-corruption practices

Since 2017, regular security and loss prevention training has been organised, which included the topics of corruption prevention and conflict of interest, for employees of all KGHM entities. The training covers all employees newly employed in KGHM entities. Topical training is also organised. In 2018, a specialised training course was carried out, addressed to senior management and their representatives (40 people). All materials and instructions are readily available to Employees on the corporate Intranet site via a dedicated tab devoted to ethics and corruption prevention.

In 2019, on-site training on anticorruption was conducted by an expert from the Central Anticorruption Bureau for persons in managerial and executive positions as well as persons responsible for the procurement processes in companies in the KGHM Group. 5 training courses were held in total, attended by 143 persons.

Regular meetings and training sessions are also organised for the Ethics and Anticorruption Representatives (40 persons). In 2020, 5 such training sessions were held. The objective was to improve the abilities of the Representatives and to share knowledge. The Representatives are responsible for the organisation and performance of training sessions on ethics and anticorruption in KGHM’s companies.

In 2020, KGHM Polska Miedź S.A. launched two e-learning training modules on ethics, prevention of irregularities (in particular, corruption, abuse, and discrimination) and receiving whistleblower reports in its Head Office and Divisions:

1.       for senior management, the Ethics and Anticorruption Representatives and Members of the Ethics Committee – 636 people completed the training and 98 are currently undergoing the training (as at 31 December 2020).
2.       for remaining employees with access to the e-learning platform – the training was completed by 4,452 people and 1,207 are currently in training (as at 31 December 2020).

As a result of the decision of the Management Board to implement the Anticorruption Management System in the Divisions and Head Office of KGHM Polska Miedź S.A. and in the Subsidiaries in accordance with the PN-ISO 37001:2017 standard, online training workshops were conducted in the last quarter of 2020 on the requirements of this standard for Ethics and Anticorruption Representatives and Management System Representatives in KGHM Polska Miedź S.A.

1.       Practical interpretation of the requirements of the Anticorruption Management System standard according to ISO 37001: 3 one-day training sessions, number of participants: 71;
2.       Internal Auditor of the Ethics and Anticorruption Management System based on the international standard ISO 37001, the KGHM Polska Miedź S.A. Code of Ethics and the draft standard ISO/DIS 37002:2020: 2 two-day training sessions, number of participants: 34;
3.       Anticorruption Management System Representative according to ISO 37001: 1 two-day training session, number of participants: 17;

In 2019-2020, a number of communication activities were also carried out, addressed to the employees of the KGHM Group, promoting ethical standards and contributing to the culture of the organization:

  • 6 educational films were published on the topic of the Code of Ethics, abuse prevention, the Whistleblower Platform and protection of Whistleblowers, rules of acceptance and giving of business gifts, as well as prevention of corruption and conflicts of interest,
  • several articles on related topics were published in the company magazine Curier and in the Group’s Intranet,
  • a special supplement focusing on Whistleblowers was published in Curier,
  • the updated Anticorruption Manual was published in an electronic version,
  • the “ABCs of Conflict of Interest. Corporate ethical handbook of KGHM” was developed, published and distributed; the publication presents a concise description of conflicts of interest and the company’s regulations for preventing this phenomenon.
  • a questionnaire was developed allowing employees to carry out on their own a voluntary, individual assessment of the risk of conflict of interest,
  • an information campaign on the handing of business gifts was conducted.

Privacy policy and personal data processing policy (website)

The Privacy Policy describes principles of informing the Users of the website about the aspects of obtaining, processing, using and securing data about website users, while the Personal data processing policy contains information on processing by KGHM Polska Miedź S.A. of personal data. 

Information on the execution of the tax strategy

Information on tax strategy

The following „Information on the execution of the tax strategy PGK KGHM II” (in Polish), has been published and prepared in compliance with art. 27c of the Act dated 15 February 1992 on corporate income tax. In terms of the tax group (in respect of which KGHM is the parent entity), the aforementioned information required by law on topics such as: the type of tax obligations performed, procedures involving management of tax obligations and the form of cooperation with the treasury office. Also included is information on the level of taxation paid by the KGHM Group as well as other estimations, assumptions and judgements described in the Company’s annual and half-year financial statements, prepared in accordance with IAS and IFRS.

Information on the execution of the tax strategy for 2020 [PDF] (original version in Polish).
Information on the execution of the tax strategy for 2021 [PDF] (original version in Polish).

Tax Policy

The Tax Policy of KGHM Polska Miedź S.A. is a codified collection of best practices applied by KGHM in the process of calculating and executing its tax obligations. The Policy represents a response to the growing expectations for greater corporate transparency, articulated amongst others in the form of GRI guidelines. It is also a critical element in the process of strengthening the Company’s image, attesting to the heightened interest in issues related to social questions and corporate governance, as well as in monitoring the aforementioned questions related to ESG ratings.