Annual
report 2020

External environment

Regulatory

General rules

The Polish telecommunications market is subject to wide sector regulation including the one established at EU level and transposed to national legislation. It is supervised by a National Regulatory Authority, the Office of Electronic Communications (UKE). As a general rule the telecom market is divided into separate markets for wholesale and retail services (so-called “relevant markets”). UKE analyses the level of competition within each of these markets and, based on this analysis, decides on the necessary level of regulations. As a former incumbent operator on the fixed services market, Orange Polska is designated an entity with significant market power and is subject to regulations in certain market segments. In particular OPL is obliged to prepare regulatory accounting separation statements and perform cost calculation for LLU and BSA services, which are to be verified by independent auditor annually. As such, this regulatory regime has a significant impact on some of the services we provide. On the mobile market, regulations are equal for Orange Polska and other big market players. Our activities are also subject to supervision by the Office of Competition and Consumer Protection (UOKiK).

We consider the following regulations to be the most important for our business at the moment:

  • Access to wholesale broadband services (also known as Bit Stream Access, or BSA) and physical access to last mile infrastructure (Local Loop Unbundling, or LLU) are mandatory under cost orientation obligation (verified by Margin Squeeze/Price Squeeze tests) and non-discrimination rules (including Chinese Walls), and this legislation covers both fibre and copper lines. Orange Polska is not obliged to provide BSA on fibre and copper infrastructure in 151 deregulated municipalities. LLU is not required in 51 deregulated municipalities.OPL, as other beneficiaries of public funds is also providing wholesale access to its network built within POPC programme based on BSA and LLU as well as access to infrastructure.
  • Regulation of call termination services. The level of termination rates will be established in Delegated Regulation, and the rates are expected to be implemented since 01.07.2021.
  • The single EU-wide maximum rate for voice call termination on a mobile network will be 0.2 cents per minute from 1 January 2024.The path to reach this level is as follows:
    • 0,7 ec / min – we estimate that the rate will apply from June 1, 2021
    • 0,55 ec / min from 1 January 2022 to 31 December 2022,
    • 4 ec/min from 1 January 2023 to 31 December 2023,
  • The maximum EU-wide rate for terminating a voice call in a fixed network is 0.07 EC / min from January 1, 2022. Until then, a transitional rate of (0,5 gr/min (0.112 EC / min)) will apply in Poland. We estimate that this rate will apply from June 1, 2021.

Obviously as a business entity we must also comply with administrative decisions and general law and regulations. Recently the legal environment has been changing dynamically UKE has recently issued a decision deregulating wholesale market of High Quality Access.

Further amendments to telecom rules are pending both at European and national level.

The regulatory regime over the past few years has been evolving toward a policy of balanced intervention. This is mainly related to changes in the structure of the overall telecom market in Poland and a much higher degree of competition in particular segments (e.g. the emergence of cable operators as important players in retail fixed broadband).

In particular, the Office of Electronic Communications (UKE) has issued decisions that will ensure symmetrical access to cable ducts and regulate access to in-house wiring operated by the largest infrastructure owners. The relevant regulatory obligations have been imposed not only on telecom operators, but also on the biggest cable TV operators.

At EU level, the list of markets susceptible for ex ante regulation of significant market player has been limited to two markets: Wholesale local access provided at a fixed location (LLU) and Dedicated capacity (incl. mobile backhaul). The implementation of the EC recommendation requires a new market review and relevant UKE’s decisions.

At national level, there are on-going legislative works (currently at the government level) on the draft law on national cybersecurity system. This draft law includes inter alia the assessment scheme of the so called high-risk supplier.

Economic

Changes in the Polish economy, such as GDP growth, inflation, unemployment, disposable income, interest rates or foreign exchange rates, can influence our ability to create value. Whilst these areas are outside of our direct control, we can use our hedging strategies to mitigate the potential adverse impact of market movements.

The outbreak of COVID-19 pandemy in 2020 affected significantly Polish economy. This was the first economy recession in Poland from 30 years however it occurred to be relatively shallow in comparison to West European countries. Still active pandemy and its consequences for the individuals and businesses make uncertainty the most common word among economy forecasts. Despite this fact, majority of prognosis indicate for economy rebound already in 2021 and its positive dynamics in the years to follow. That is possible thanks to COVID-19 vaccines and growing number of people in the society who are already resistant to the coronavirus.

The pandemic outbreak has dynamically changed the market situation. After 4.5% GDP growth in 2019, the Polish economy noted GDP decline in 2020 –  according to the Central Statistical Office -2.7%. It’s worth to be noted that based on European Commission data this last year decline was one of the lowest among EU countries. The negative economic conditions were related to COVID-19 pandemic and resulted mainly from decline in domestic demand, investments as well as private consumption. Still under some restrictions Polish economy is expected to rebound in 2021 and following years. Poland’s economic outlook, especially nowadays, depends also on the condition of other European economies and the “new normal” economic climate in global markets.

Average annual CPI reached 3.4% in 2020, well above the inflation target (2.5%). This was the highest level noted since 9 years. Relatively high inflationary pressure (still above the National Bank of Poland’s inflation target) is expected to continue in the next few years, mainly due to a rise in electricity prices and administrative costs. Despite continued inflationary pressure, the Monetary Policy Council in the face of the pandemic lowered the reference rate to historically low level of 0.10%.

On Polish telecom market, price stabilization started in 2019 and continued in 2020 especially thanks to “more for more” strategy adopted by major players.

Acceleration of Polish revolution towards digital thanks to telecommunication services is expected to continue as those services occurred to be essential for individuals, businesses and institutions in COVID-19 reality. New sector investments will need to adopt to market current situation according to inflationary pressure and the rising convergence competition.

The labour market has been also negatively affected by the general macroeconomic climate hit by COVID-19 in 2020. At  the  end  of  December  2020 unemployment  rate  in  Poland  grew  to 6.2% (+1 pp. year-on-year). That was the effect of lockdown in the second quarter of 2020 and following coronavirus related restrictions harming the business sector. At the same time, an increase in wages in the enterprise sector was reported however the pace slowdown in yoy comparison (+5.4% year-on-year in nominal terms). A further increase in unemployment may be expected in 2021 as a result of the existing COVID-19 restrictions. Unemployment level will be triggered by business sectors prosperity, depending also from financial support (provided also by the EU budget and recovery plan).

In the face of the pandemic, the Polish central bank lowered the reference rate to its historic low of 0.10%. Monetary Policy Council do not expect to change its policy in 2021. This policy might be continued until the end of the term of office of the current Council, which ends in 2022. However, a potential increase in interest rates should not have any major influence on the debt service costs of the Group, as it maintains a high hedging ratio.

Foreign exchange rate fluctuations affect Orange Polska’s liabilities denominated in foreign currencies and settlements with foreign operators. However,  this  influence  is  greatly  contained  by  a  portfolio  of  hedging instruments held by Orange Polska. In 2020, the Polish zloty lost 8.4% against the euro and gained 1.1% against the US dollar. The Polish currency fluctuations were caused mainly by external factors. Any potential depreciation of the Polish zloty should not have a major influence on Orange Polska’s liabilities denominated in foreign currencies or settlements with foreign operators owing to a high hedging ratio.

Telecom Market

The Polish telecom market is mature, with high penetration in most segments. This sector is very important for the Polish economy, particularly in the digital age. Together with the IT and content industries, it shapes the information society and actively participates in the transformation of Polish companies.

The Covid-19 outbreak in 2020 made the telecom sector visible as never before, as it has significantly accelerated market changes towards digital solutions in Poland. Network quality was revealed to be essential for everyone, which is why we could observe higher market demand for fixed broadband connectivity, especially fibre services.

The telecommunications market is also evolving in terms of technology, as we are at the dawn of the 5G era and all the new solutions and services it promises to bring to the Polish market – a transformation of particular importance for business customers. To meet this great responsibility, the telco industry faces many business and technical challenges that will require large investments in infrastructure, now and in the coming years, in order to provide individual, public sector and corporate customers with fast and secure internet access (both wired and wireless), as well as new services and equipment to meet new requirements.

The Polish telecom market is characterised by high levels of competition and relative fragmentation. It is mainly driven by mobile services and a high degree of fixed-to-mobile substitution in both voice and broadband. In the past, these factors have had a critical impact on the overall performance of the market. The market landscape changed further in 2019 thanks to mobile operators increasing tariffs in a ‘more for more’ formula, with visible results also in 2020. This came as a consequence of the favourable economic situation in Poland in 2019, the very low prices of telecom services, the relatively equal market shares among major players and upcoming investments in 5G technology. That is why we expect market participants to continue to focus on value generation.

According to our estimates, after stabilisation in 2018, the value of the Polish telecom market experienced growth in 2019, and remained at a stable level in 2020. Historically, the key factors that have influenced market performance over the past few years include:

 

  • A very high level of price competition in mobile services, exacerbated by several price wars in both B2C and B2B segments. This has led to prices in Poland being among the lowest in the European Union. The key disruptor was Play, a latecomer to the market, which pursued an aggressive strategy to gain market share.
  • The structural decline of fixed voice services, which was influenced mainly by rapid proliferation of affordable mobile services, partial regulation of this segment and unfavourable demographic trends.
  • Underdeveloped fixed broadband infrastructure, especially outside of big cities, which in combination with the rapid development of mobile services and strategies of mobile-only market players resulted in partial fixed-to-mobile substitution. Penetration of mobile broadband positioned as home Internet access is much higher in Poland compared with the EU average.
  • These trends have had a significant impact on Orange Polska compared to the overall market, and this has been reflected in many years of falling revenue. This was mainly due to:
    • The need to adjust to high price competition in mobile to defend market shares in both B2C and B2B segments;
    • Very significant exposure to fixed voice, as an incumbent operator;
    • Underperforming the overall market in fixed broadband due to regulations and weak infrastructure in big cities, resulting in the loss of market share to cable operators;
    • No significant exposure to the pay-TV market.

The market’s landscape changed again in 2019, with operators introducing tariff increases in a ‘more for more’ formula. The change was most marked on the mobile market, where three of the four MNOs decided to increase their tariffs in return for higher data allowances. The telecommunication market was quite resistant to COVID-19 market turbulence. With new regulations and imposed restrictions, both residential and business customers changed their service consumption patterns. Mobile data surged together with interconnection revenues while roaming services dropped and prepaid and equipment sales varied in selected quarters of 2020. Additionally, fast fixed broadband services reached historically high demand during the Covid-19 pandemic. 2021 is still driven by market uncertainty related to further waves of the pandemic. However, thanks to the vaccine process already underway, 2021 may have a more positive outlook for the market. The telecommunications market is heading towards fixed-mobile services convergence – a direction confirmed in 2020 by market operators.

We expect the following key trends to drive the market in the years ahead:

  • Significant investments in high-speed broadband infrastructure will continue and shape the telco market. All of the market’s MNOs have chosen to expand their product portfolios with fixed broadband services, through acquisitions, wholesale agreements or partnerships. Better infrastructure combined with growing data needs will drive the migration towards high-speed internet. Taking into account the economics of fibre network rollout as well as all network investment plans announced publicly so far (including Orange Polska FiberCo plans and governmental POPC programme), Poland’s fibre network is about to exceed 50% of households.
  • Convergence is increasingly recognised as the household business-winning formula. This is evidenced by the success of our Orange Love offer, the acquisition of Netia by Cyfrowy Polsat Group, T-Mobile buying wholesale access to our fibre network, the Play partnership with Vectra and the UPC launch of mobile services. In 2020 we also saw mobile players entering the POPC networks and the announcement from Play, after its acquisition by Iliad, that it would be moving towards the fixed broadband segment – further confirmation that convergence is the formula for the future.
  • The major shift on the Polish mobile market is towards 5G. This new technology will significantly change our environment and, thanks to new possibilities like AR/VR, will create new types of services. Individual customers will be able to enjoy new experiences through the likes of gaming, education and purchasing. 5G is also especially important for business customers in industry 4.0 solutions. Private networks (dedicated to large business accounts), AI and data analytics will create additional value and speed up companies’ digitalisation on the market.
  • Data consumption is on the rise, spurred by the proliferation of mobile devices and the rapid growth of data per customer, the latter being driven mostly by multimedia content and social media. We foresee data consumption continuing to grow at the current pace at least for the next few years while the smartphone revolution continues in Poland. Responding to customer expectations of the best possible, always-on Internet access requires a convergent approach to connectivity. That is why development of both fixed (FTTH) and mobile networks (4/5G) is crucial.
  • The trend towards digitalisation plays an increasingly important role in all spheres of people’s lives, and mobile services are no exception. The widespread adoption of digital solutions – such as app-only services and mobile shopping experiences, or customer care delivered via in-app chats or bots – will create a totally new level of operator-customer interaction.
  • ICT services are increasingly seen as synergetic with traditional telco business, strengthening the offer for B2B customers. This is especially visible in the latest market moves: Orange Polska’s acquisition of BlueSoft in 2019 and Craftware in 2020; Cyfrowy Polsat’s investment in Asseco Poland shares; the acquisition of 3S by Play as well as Orange and other market players’ investments in data centres.
  • Everything is moving online and into the cloud, enabling the evolution of such services as the Internet of Things, Smart Homes and Smart Cities. These solutions will support business, local authorities and customers in the switch towards a more environment-focused approach.
  • Marketing based on customer insights and using personal data is on the rise. It is both a source of new possibilities, and a challenge for cybersecurity and personal data protection.
  • The pay-TV market should remain relatively stable. Poland still has very strong linear TV. Of course OTT content is growing fast, but it should remain an add-on to linear TV, rather than a significant substitution factor.
  • We expect the gradual adoption of eSIMs on the market. Orange Polska launched this environmentally friendly product in December 2018 – the first MNO on the Polish market to do so.

Market acceleration towards digital, and the transformation of our customers’ daily online activities driven by Covid-19, are based on telecommunication services. Recovery in market value will be driven by expansion of fast broadband, stabilisation in mobile, and the decreasing impact of fixed voice on the overall performance.

We also believe that the strategy adopted by Orange Polska makes us better equipped to capture positive market trends than in the past, thanks to several key enablers:

  • Fibre network rollout: Our significant deployment of the fibre network is gradually closing the technological gap with cable operators, and has already contributed to our return to a growth path. Orange Polska believes that FTTH investments are the best possible fixed broadband investments – and the most environmentally sound, as this technology is up to five times more energy efficient than xDSL (per Gb). It’s clear to see that there is great market demand for a fast broadband network, and we are certain of the value in standing behind it. That is why we launched the FiberCo project with the aim to roll-out the FTTH access network to about 1.7 million households in Poland, predominantly in the areas without extant high-speed broadband infrastructure
  • Convergence: Orange Polska is a unique convergent operator in Poland and is pursuing this strategy mainly against cable operators, which have not yet adopted mobile services on a meaningful scale. In 2020, all MNO players on Polish market already started to offer fix & mobile convergence and have entered in wholesale deals with FBB infrastructure providers. The trend will accelerate in 2021 because of fixed infrastructure development (e.g. Orange Polska with FiberCo, POPC rollout), operators’ moves on infrastructure (Iliad and CPG selling the infrastructure to Cellnex) and finally Iliad entering the market and looking for access to fixed as the base for its convergent offer.
  • Focus on value: Since 2017 all of our commercial decisions have been driven by value creation. In particular, we have radically simplified mobile tariffs and structured them around a ‘more for more’ strategy.
  • Digitalisation: In 2019 we launched an innovative offer called Orange Flex. A fully digital offer supported by a phone app, it is flexible, too, enabling customers to adjust their mobile plans using their smartphones. Customers can also subsequently change packages depending on their needs with no loyalty agreements involved.
  • ICT: Orange Polska recognised a market need and in 2019 made the decision to acquire BlueSoft while in 2020 acquired 100% stakes in Craftware, strengthening its position in ICT and the B2B sector.
  • Innovations: We see enormous market potential in innovations supporting our products and services (also via partnerships) as well as new solutions in customer service (e.g. chatbot Max, paperless contracts)
  • Orange Goes Green: we are aware of our role and responsibilities in terms of climate change. We have set a goal of reaching Net Zero Carbon by 2040 through our internal actions and focus on new services.

On the other hand, we will be under further pressure from negative trends in legacy services and old technologies in fixed broadband. More details on our strategy are presented in the strategy section.

In 2020, these key enablers proved significantly important to Orange Polska’s activities through the year of the pandemic. Thanks to them we could not only deliver the services and products our customers need, but also support them with the appropriate service for this new market situation. We are convinced that thanks to those enablers, in 2021 we will be able to act in a sustainable way by providing both operating profitability and revenue growth.

The Polish telecom market is fragmented, both in mobile and fixed segments. In 2020, the mobile market changed as Play was taken over by French operator Iliad, which  may  have  a  significant  impact  on  the  market  dynamics  in  the  future.  According to official announcements, Iliad is planning Play’s expansion to the fixed market, which confirms the underlying market trend towards convergence. It is not yet clear how Play intends to build the reach of its fixed-line services. The whole market is visibly turning towards mobile-fixed combinations.

Orange Polska is the leading telecom operator in Poland operating in all market segments. We have the largest customer base in both fixed and mobile segments.

Supply chain

We aim to build strong, long-term relationships with our suppliers. We want our relations with suppliers and business partners to be based on transparent principles and a mutual obligation to abide by ethical standards.

We take an active part in the implementation of the Orange Group’s global supplier assessment programme, QREDIC. The results of the assessment are used in the process of negotiating with and selecting suppliers at the global level; for example, for subscriber devices or network equipment purchases. A supplier is disqualified if the assessment reveals definite non-compliance with ethical and environmental standards.

At the global level, Orange Group is a founding member of the Joint Audit Cooperation (JAC), an association which groups together telecommunications operators to control, evaluate and develop the implementation of CSR principles by global suppliers of the ICT sector. The initiative aims at ensuring compliance with ethical, environmental and health and safety standards, as well as a ban on child labour across common suppliers. In 2020, 76 new audits were conducted within the JAC framework.

Local suppliers are required to sign up to a compliance clause, which is included in agreements with our company. The clause includes an obligation to comply with ethical and responsible conduct rules, particularly concerning human rights, environmental protection, sustainable development and anti-corruption. In addition, an anti-corruption clause is included in all purchase agreements.

In 2020, we cooperated with 3,317 suppliers in Poland, including subscriber and network equipment suppliers, network contractors, IT equipment suppliers, personnel outsourcing agencies and media houses. We strive to build our relations with suppliers on the basis of long-term contracts providing for transparent terms of cooperation. Over 97.9% of purchases (by value) are executed under long-term framework agreements. We are working towards effecting all payments to suppliers within due time. The timely payment rate is 88,6%. The standard term of payment to suppliers is up to 30 days (96% of agreements).

We follow a competitive and open procurement policy. The transparency of our supplier selection process is ensured by the Procurement Process Code, a set of rules which must be followed by all procurement organisation employees in their direct and indirect contacts with suppliers. The Code includes procurement procedures which transparently regulate supplier selection, contracting and confidentiality. In 2019, a separate corporate social responsibility clause was included in all contracts. In 2020, 100% of buyers from the procurement department of Orange Polska completed online training dedicated to the main CSR aspects in procurement.

Currently, over 71% of orders (by volume) are placed electronically, via an online procurement tool that automatically analyses submitted offers. Moreover, suppliers who want to cooperate with Orange Polska can register to join a database of potential suppliers, allowing them to participate in the company’s procurement processes.

Social

Poland’s standard of living has been improving steadily over the years.

The COVID-19 pandemic that struck the world in 2020 hampered the developments but Poland’s economy in macroeconomic terms seems less affected than those of other European countries.

At the end of the third quarter of 2020, the employment rate in Poland stood at 69% (4,6 p.p. less than in 2019, first fall since 2004), and for the first time was above EU average of 67,8%. However, the rate in Poland varies considerably across educational attainment levels and with respect to gender.

The pandemic only exacerbated the problem. While the employment rate for people with tertiary education rose despite the lockdowns (up to 88,2% as compared to 83,4% in the entire EU27 area), it remains much lower and rapidly shrinking for those with primary and lower secondary education. Only 25% of working age Poles with the lowest level of educational attainment were  employed in Q3 of 2020 (the number nearly halved over 12 months and is about 20 p.p. below EU average). In case of women in this educational category the rate stands at mere 16,2%, and it is even lower for youngest of them – only 8,2% is employed (against UE average of 35%). Other problems of the labour market include steep rise in self-employment which replaces job contracts (6,4% over the course of 2020), and rapid loss of jobs under fixed-term or civil contracts (by 14,3% – which stands for nearly 400 thousand jobs). In the light of these facts the surprising fall of unemployment rate to 3,3%, reported by Eurostat  in December 2020 (with UE average of 7,5%), might suggest that wider groups of Poles are pushed towards insecure employment forms or are deterred from seeking employment whatsoever.

The abovementioned trends might undermine the effects of recent efforts to eradicate poverty and reduce inequalities in the country. Since 2015 increase in the minimum wage, changes in civil contracts and – above all – programmes of social benefits for families (PLN 500 monthly allowance per each child, PLN 300 yearly allowance for school starter kits) have radically improved the situation of many vulnerable groups, particularly those of lower social and economic status. As of 2020, crisis in the labour market, increased inflation that diminishes the impact of social transfers (purchasing power of 500+ fell by 10% since 2016) and risk that social programmes would push women out of the job market become more prominent.

Such developments are especially worrying, as income inequality rates that were steadily falling in Poland since 2005 started rising again even before the pandemic, in 2019. The Gini coefficient of income inequality, which measures the distribution of (equivalised) disposable income across the society, has been falling from almost 35.6 in 2005 to only 27.8 at the end of 2018, but started moving up in 2019, reaching 28, 5 – still well below EU average. This trend would be even more alarming if we take into account work of some economists, who argue that for Poland inequality levels calculated based on tax data might be even 25% higher than the official statistics based on declarations – thus placing Poland among least equal societies in EU (see Blanchet, Chancela, Gethin, 2019).

In addition, Poland is still facing the problems of a rapidly ageing population. The unfavourable demographic trends are already reflected in a decline in the working-age population. The percentage of elderly people in the entire population is expected to grow from 20.9% in 2010 to 58% in 2050, according to the European Commission’s Country Report Poland 2016. In addition to that, number of births fell by 5% in 2020, reaching lowest level in 15 years. The economic effects and temporary failures of healthcare system during the pandemic will undeniably strengthen this trend.

In the reality of pandemic, internet access is not only a convenience, but by no doubt a precondition of full participation in social, cultural and professional life. According to the Central Statistical Office, as of 2020 more than 9 out of 10 Polish households had access to the internet. Almost the same share of them (89,6%) had a broadband connection – a fairly steep rise since 2019, when 83,3% of households had it. The biggest improvement in broadband adoption over 2020 could be seen in rural areas and small towns, nearly closing digital divide to the biggest cities in this respect. Especially mobile broadband gained unprecedented traction with almost 67% of Polish households accessing fast internet by its means (rise by 12,4 p.p. since 2019).

Since the internet became the main means of functioning in many fields of life, digital exclusion touching certain social and demographic groups becomes an especially urgent problem. Use of the internet and modern technologies varies with social and demographic factors, especially age, professional activity, and education. The internet is used by the great majority of young people and very few seniors. Digital divide starts in the 55+ age group, but the most affected group is those aged over 65 – with only 40% of them regularly using the Internet. Education level plays a major role as well, with 98,2% of Poles with tertiary education regularly online, compared to 75,6% of those with upper secondary and 67,8% with primary or lower secondary education. The problem is also greater than average among unemployed, with nearly 20% of them not using the internet regularly in 2020.

What might be worrying in the face of recurring lockdowns and economy shutdowns, is the level of digitalization of Polish enterprises. Even though at the end of 2020 98,6% of enterprises in Poland had broadband internet access, their overall level of the digital intensity index is one of the lowest in EU, with 60,4% of them rated as “very low”. Before the pandemic 30% of Polish enterprises didn’t have a website (7 p.p. more than the EU average), and mere 16,5% of them were selling goods and services online (as of 2019), which is well below EU average as well.

As a telecommunications company, we must respond to the diverse needs of our customers, both the older ones, who are less convinced of the need to adopt new technologies, and the younger ones, who are used to constant online presence and try to keep up with the latest technological trends. Telecommunications expenditure is a permanent component of any household budget, and we try to ensure that each customer, regardless of their income, can find a suitable offer for them and their relatives. Nowadays, it is no longer network access itself but rather the ability to use new technologies wisely and safely which has become a social challenge.

Human Rights

Owing to the nature of our business model and supply chain, we follow the human rights policy formulated at the international level by the Orange Group. In addition to the general framework of the International Labour Organization conventions, the Universal Declaration of Human Rights and the Global Impact principles, Orange Group complies with the UN Guiding Principles on Business and Human Rights adopted in 2011.

The Group’s activities with respect to safeguarding fundamental human rights focus on three main areas:

  • relations with employees;
  • relations with suppliers; and
  • privacy and freedom of expression.

These areas are all addressed in the Orange Polska Code of Ethics. We respect all people and their right to privacy. We accept diversity in terms of background, race, gender, culture, age and marital status as well as religious beliefs, political views and membership of social or professional organizations.

We use a Supplier Code of Conduct at Orange Polska. The Code has been developed at the Orange Group level and adapted to national laws and regulations. It seeks to encourage compliance with and respect these laws and regulations, and ensure that they are faithfully and effectively enforced. Suppliers are required to respect human rights and avoid being complicit in human rights abuses of any kind.

The Code covers the following areas:

  • social responsibility: freedom of association and the right to collective bargaining, forced labour, child labour, diversity and non-discrimination, remuneration, working hours and health and safety;
  • environmental responsibility: environmental protection, natural resources and waste management; and
  • prohibited business practices: anti-corruption policy, competition, sponsorship, political contributions, money laundering, data security and data protection.

The Code has been published and incorporated into our contracts with suppliers. We are currently working on a human rights policy specific to Orange Polska.

We also launched an e-learning training on human rights that was completed by 100 % of the purchasing team. Rights related to diversity are covered by our diversity management policy, privacy and data protection by our customer safety policy.

A separate corporate social responsibility clause is included in all contracts. Pursuant to the clause, the parties undertake to comply with, and ensure that their employees, suppliers and sub-contractors comply with all national, European and international rules associated with standards of ethical and responsible behaviour, including standards on human rights, environmental protection, human health and safety, and sustainable development. They also undertake to combat any infringements of human rights and fundamental freedoms, as well as any risks to the health and safety of persons and the environment. In addition, they declare that they will require their employees, suppliers and sub-contractors to refrain from using child labour or forced labour, and shall combat any discrimination. The clause has been included in all new purchasing contracts since 2019.

Orange Polska takes all issues related to human rights very seriously, paying particular attention to the rights to privacy and personal data protection. In order to prevent theft or unauthorised modification or processing of personal data of its customers and employees, or personal data entrusted by Orange Polska, we have implemented security measures consistent with international standards. In addition, we are introducing a process to identify and prevent violation of rights and freedoms of data subjects.

Environmental

Digital technology is used daily by 6 billion people worldwide. The ICT sector (fixed and mobile networks, Internet of Things (IoT) devices, VPNs, data centres, as well as user devices: smartphones, computers, set-top boxes, etc.) accounts for about 3.6% of global energy footprint and about 1.4% of global CO2 emissions(1).

Orange Polska is sensitive to global challenges related to the natural environment and natural resources. We have set ambitious goals and are taking concrete actions to reduce our environmental impact, both direct and indirect. Our target is to become net zero carbon already by 2040 with respect to our own direct and indirect emissions as well as value chain emissions.

In addition to the efforts we make to reduce the impact of our own operations on the environment, as a provider of telecommunication services we can significantly contribute to reducing the negative impact of business activities of others. Digital technology is now integrated into all sectors of human activity, and developing its sustainable uses is becoming our daily challenge. Moreover, by radically transforming the industrial world, digital technology also creates the potential for more innovative and sustainable solutions to the challenges posed by energy use and ecological damage.

Modern digital technologies are a major tool to solve climate issues. Telecommunication services support green transformation and offer solutions which enable our customers to reduce their carbon footprint. Tele- and video-conferences decrease business travel (especially by plane), while IoT solutions, particularly in the Smart City domain, optimise consumption of resources (e.g. electricity or water) and reduce emissions and pollution thanks to smart management and monitoring systems for municipal services (e.g. utilities supply, city lighting, parking places, city bikes or waste collection).

Use of new technologies is a huge opportunity on the one hand, in terms of economic and social development and finding more eco-friendly solutions; on the other hand, it presents a challenge when it comes to the rapid obsolescence of products and increased demand for energy. It poses a problem about what to do with devices that are no longer wanted and provokes us to think about eco-efficiency inside the Company as well as relations with our suppliers. It also means educating customers and encouraging them to return ICT devices they no longer use.

(1)Source: Malmodin and Lundén, Sustainability Journal 2018, International Energy Agency.

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