Compliant in action - zero tolerance for corruption!
Ensuring a fair and transparent model for the conduct of Lubelski Węgiel Bogdanka S.A.'s business requires a “zero” tolerance policy for corrupt activities. Corruption and related abuses entail criminal liability for those who engage in such practices and consequences for the company itself. Acceptance of corrupt activities makes it difficult to conduct business activities, limits the ability to promote services and products, can prevent the award of public contracts, and creates the risk of severe financial penalties. In particular, the Company’s employees are prohibited from such activities as: peddling - accepting a material or personal benefit or its promise, bribery - giving a personal or material benefit to a person performing a public function, influence peddling - prohibition of invoking influence and position in the Company when undertaking to broker a deal in exchange for a personal or material benefit, managerial bribery - employees may not demand or accept a material or personal benefit or its promise, in exchange for abuse of powers granted to them or failure to fulfill a duty incumbent on them that may cause damage to the company, manipulation in tenders - employees may not, in order to gain a financial benefit, thwart or obstruct a tender or enter into an agreement with another person acting to the detriment of the owner of the property, or the person or institution for whose benefit the tender is held.
Employees may not offer, give, promise, demand or accept financial or personal benefits that could be perceived as illegal, unethical or inappropriate, which are intended to influence the terms of a transaction and given in cash or its equivalent (e.g. gift cards, vouchers).
Suspected corruption incidents can be reported using anonymous reporting channels as violations of laws and ethics through the Compliance Policy Department. Employees who report irregularities may not be subjected to consequences in the form of termination of their employment contract or service relationship. No form of discrimination or harassment will be tolerated against those who report their concerns or suspicions about potential corruption in good faith. All applications will be reviewed and thoroughly investigated.
Compliant in action - legitimacy of reporting violations
The comprehensive functioning of the Compliance Management System (Compliance) at Lubelski Węgiel “Bogdanka” S.A. includes activities aimed at supporting and promoting ethical behavior, in compliance with the law and with the Company's ethical procedures and standards. One of the elements of this system is the whistleblowing, or violation reporting policy, under which violation is understood as any act or omission that leads or may lead to damage or loss of reputation for the Company, its customers or Employees, in particular, these may be unlawful, dishonest or unethical acts that violate the law and applicable internal acts.
Early detection of a violation and the corrective actions applied as a result lead to a mitigation or complete elimination of the Company's reputational risk, and a culture of openness and honesty leads to increased trust and is a clear signal of zero tolerance for behavior contrary to laws or ethical standards. It should be emphasized that the reporting of violations through the established information channels must be done in the absolute belief of the reporting person that the information is true. According to the prevailing Whistleblowing Policy, submitting information being aware that the report is unfair, that is, submitting false information with the purpose of discrediting another person, causing conflicts and misunderstandings, jealousy, attempting to exert harassment on a co-worker, or simple malice, is treated as reporting in bad faith, which may result in disciplinary consequences. Please note that each of our Company's employees is responsible for adhering to the Compliance culture, although to many of you it may seem that these are contrived regulations, in practice, thanks to the proper functioning of this system, each of us can feel safe in performing our work.
Compliant in action we take care of our future!
Please be advised that as of 1 September 2020, the LWB Whistleblowing Procedure will be in effect. It demonstrates the Company's commitment to supporting and promoting ethical behavior that complies with the law and the Company's procedures and ethical standards. By violation we mean any act or omission that leads or may lead to damage or loss of reputation for the Company, its customers or Employees, in particular, these may be unlawful, dishonest or unethical acts that violate the law and applicable internal acts.
In accordance with the Procedure violations should be reported to the relevant Management Board member or to the Compliance Policy Department. It will be possible to report a violation:
a) electronically to email address ...@lw.com.pl,
b) by traditional correspondence; traditional correspondence may also be submitted through the contact boxes located at each
of the three mining fields;
c) in the form of a verbal report - by telephone using the designated telephone numbers to the Compliance Policy Department.
Lubelski Węgiel “Bogdanka” S.A. ensures that Employees may report any identified violations in the Company in a manner that ensures protection of the reporting person's identity and that there are no consequences in connection with the report or actions taken as a result of such reports, provided that they are not false or submitted in bad faith.
The above Procedure is necessary to ensure that our Company enforces laws and Stock Exchange Standards.
Anti-corruption guidelines for public administration
Anti-corruption guidelines for public administration on unified institutional solutions and rules of conduct for public officials and persons entrusted with top executive functions (PTEF).
Documents to download:
CBA Guidelines December 2020 [DOWNLOAD]
WSE Compliance Standards
Standards recommended for compliance management systems as regards preventing corruption and protection of whistleblowers in WSE listed companies.
Documents to download:
WSE Compliance Standards [DOWNLOAD]