Ethics and compliance management

• Regular meetings and handling matters communicated to the Committee by all available channels;
• Current collaboration with Internal Audit Director and Director in charge of Security and Compliance;
• Meetings with the heads of structures from which notifications have been received in order to better understand the issue and formulate further recommendations.

• Defining a new approach of the Ethics Committee to ethics management within Orange Polska;
• Publishing a new, more transparent and user-friendly website of the Ethics Committee;
• Preparing for the implementation of a whistleblowing procedure and an internal procedure for report handling by the Ethics Committee in accordance with the relevant EU Directive and Polish regulations;
• Organising the Day of Ethics and Compliance, which included a webinar for employees, workshop for the Ethics Committee and broad communications about ethics and compliance standards and principles within Orange Polska.

In 2021, the Ethics Committee received 92 reports or questions. The most common matters raised were related to sales and customer relations, HR, and conflict of interest. Most notifications were sent to the Committee’s dedicated email.

Integrity and compliance are Orange’s fundamental values, which have contributed to the Group’s high reputation. The adoption of the Compliance Management Programme by Orange Polska confirms our willingness to operate in compliance with laws, regulations and market practices in an ethical and transparent manner. We follow the highest standards not only with respect to the quality and innovativeness of our services, but also in relations with our business partners and customers and between our employees. We aim to ensure an effective system for non-compliance risk management, threat identification and monitoring, and implementation of corrective actions. We actively prevent corruption and influence peddling, conflict of interest, fraud and any other situations involving our employees or business partners that could have negative consequences for Orange Polska.

One of the key elements of our Compliance Management Programme is the AntiCorruption Policy based on a zero-tolerance approach towards any forms of corruption in all our activities. It determines the rules of conduct and indicates prohibited behaviours which can be considered corruption or influence peddling. All our employees and all business partners of Orange Polska (co-operating companies, vendors, subcontractors, consultants and agents acting on our behalf) need to comply with anti-corruption standards. The correct application of Anti-Corruption Policy is supported by internal regulations. In particular, Anti-Corruption Guidelines of Orange Polska determine the policy concerning gifts and invitations, defining categories of benefits received or offered and a procedure for reporting them. The Compliance function carries out initiatives aimed at building awareness of the applicable rules among employees. By attending training and workshops, our teams can better understand the phenomenon of corruption and respond properly in problematic situations. Orange Polska has been mapping and regularly updating corruption risks.

To prevent potential risks of corruption, non-compliance with economic sanctions, money laundering, terrorism financing and fraud, Orange Polska applies due diligence procedures in relations with its business partners. It enables us to ‘get to know our partners’, control potential risks and make informed decisions prior to establishing business relationship with a prospective partner.

All employees and stakeholders can report their doubts or observed irregularities or violations of applicable laws via dedicated channels provided by Orange Polska, anonymously or openly, without fear of negative consequences. All such notifications are treated confidentially and verified and addressed with due diligence.