GRI Content Index

GRI Standard Title	Disclosure Number	Disclosure Title	Reference
FOUNDATION	101
GENERAL DISCLOSURES	102
	102-1	Name of the organisation	Our company
	102-2	Activities, brands, products and services	Our company
	102-3	Location of headquarters	Contact
	102-4	Location of operations	Our company
	102-5	Ownership and legal form	Our company
		Since November 1998, shares of Orange Polska S.A. (formerly Telekomunikacja Polska S.A.) have been listed on the primary market of the Warsaw Stock Exchange (WSE) within the continuous listing system. The Company’s shares are included in the following indices: WIG20 and WIG30 large-cap indices; WIG broad-market index; WIG telecommunications industry index; and WIG – ESG Index (continuation of RESPECT Index) of socially responsible companies. In 2021, Orange Polska S.A. was included in a prestigious group of socially responsible listed companies WIG-ESG.
	102-6	Markets served	Our company
	102-7	Scale of the organisation	Orange Polska in 2021 in numbers
	102-8	Information on employees and other workers	Social data
	102-9	Supply chain	Our external environment
	102-10	Significant changes to the organisation’s size, structure, ownership or supply chain in the reported period.	No changes
	102-11	Precautionary Principle or approach	Our approach to reporting
	102-12	External initiatives, declarations or principles concerning economic, environmental or social issues, which the company has signed or which it appplies.
		Broad Alliance on Digital Skills in Poland, Memorandum of Co-operation for Improving Service Quality in the Telecommunications Market, Cell Phone Safety Good Practises, Partnership for Environment (http://www.gridw.pl/partnerstwo ), Programme Accessibility Plus https://www.funduszeeuropejskie.gov.pl/strony/o-funduszach/fundusze-europejskie-bez-barier/dostepnosc-plus/partnerstwo-na-rzecz-dostepnosci/. Declaration of Cooperation for the Safety of Children on the Web ( https://www.gov.pl/web/cyfryzacja/razem-przeciw-cyberprzemocy-wobec-dzieci ). These initiatives are voluntary.
	102-13	Membership of associations
		Domestic organisations: Employers of the Republic of Poland, „Lewiatan” Confederation, National Chamber of Commerce, Polish Chamber of Information Technology and Telecommunications, French-Polish Chamber of Commerce, Responsible Business Forum, Business Centre Club, Foundation for the Development of Radiocommunications and Multimedia Technologies, Association of Stock-Exchange Issuers. Membership of these organisations is of strategic importance for the Company. The Company’s representatives sit on their boards and the Company pays membership fees, supporting statutory tasks, and participates in additional projects. Foreign organisations: European Telecommunications Network Operators’ Association (ETNO), Forum for International Irregular Network Access (FIINA), Global Compact (on the Group level), Global Settlements Carrier Group (GSCG), International Cable Protection Committee (ICPC), International Inbound Services Forum (IISF), International Telecommunication Union (ITU), RIPE Network Coordination Centre (RIPE NCC), TeleManagement Forum (TM Forum), Forum of Incident Response and Security Teams (FIRST), GSM Association (GSMA), European Internet Exchange Association (Euro-IX). These are industry organisations and the Company’s membership involves payment of membership fees and participation in various projects.
	102-14	Statement from senior decision-maker	Q&A with Julien& Ducarroz, CEO and President of the Management Board Q&A with Jolanta Dudek, Vice-President in charge of the Consumer Market Q&A with Bożena Leśniewska, Vice-President in charge of the Business Market Q&A with Maciej Nowohoński, Management Board Member in charge of Carriers Market and Real Estate Sale Q&A with Artur Stankiewicz, Chief Digital Officer Q&A with Jacek Kowalski, Management Board Member in charge of Human Capital
	102-15	Key impacts, risks, and opportunities	Risk management
	102-16	Values, principles, standards, and norms of behavior	Orange Group mission Ethics and compliance management
		Each employee of Orange Polska must read and understand our Code of Ethics, and the Ethics in Orange Polska e-learning course is a part of mandatory training for new joiners. Also our suppliers and business partners shall read and understand our Code of Ethics under the compliance clause of our standard contracts. The Code in Polish is available on our website, at http://www.orange.pl/kodeksy.phtml. Issues related to compliance with ethical standards are analysed by the Ethics Committee. It consists of five members: Chairman, two permanent members (Management Board Member in charge of Human Resources and Internal Audit Director) and two members appointed for three-year terms. In addition, the operations of the Committee are supported by two permanent Secretaries.
	102-17	Internal and external mechanisms for seeking advice about ethical and lawful behaviour, and organisational integrity	Ethics and compliance management
	102-18	Governance structure, including committees under the highest governance body	General Meeting activities in 2021 Supervisory Board activities in 2021 Audit Committee activities in 2021 Strategy Committee activities in 2021 Renumeration Commitee activities 2021 Management Board activities in 2021
	102-22	Composition of the highest governance body and its committees (number of members and their gender)	Supervisory Board activities in 2021
	102-23	Information whether the chair of the highest governance body is also an executive officer in the organisation (if yes, his or her function within the management and the reasons for this arrangement)	Letter from the Chairman of Supervisory Board Supervisory Board activities in 2021 Management Board activities in 2021
	102-24	Criteria used for nominating and selecting members of the highest governance body and its committees	Supervisory Board activities in 2021
	102-25	Processes for the highest governance body to ensure conflicts of interest are avoided and managed, and indication whether conflicts of interest are disclosed to stakeholders	Our governance structure
	102-26	Role of the highest governance body in setting the organisation’s purpose, values and development strategy	Our governance structure Audit Committee activities in 2021 Strategy Committee activities in 2021 Renumeration Commitee activities 2021 Management Board activities in 2021
	102-32	The highest committee or position that formally reviews and approves the organisation’s sustainability report and ensures that all material topics are covered
		The integrated report has been reviewed by the Management and Supervisory Board Members, and validated by the Chairman of the Audit Committee.
	102-35	Remuneration policies for the highest governance body and senior executives	Renumeration Commitee activities 2021
	102-36	Process for determining remuneration	Renumeration Commitee activities 2021
	102-40	List of stakeholder groups engaged by the organisation	Our stakeholders
	102-41	Employees covered by collective bargaining agreements	Development and training
	102-42	Identifying and selecting stakeholders	Our stakeholders
	102-43	Approach to stakeholder engagement, including frequency of engagement by type and stakeholder group	Our stakeholders
	102-44	Key topics and concerns raised by stakeholders, and how the organisation has responded, including through its reporting	Our stakeholders
	102-45	Entities included in the consolidated financial statements and covered by the report	Our stakeholders
	102-46	Defining report content and topic boundaries	Our approach to reporting
	102-47	List of material topics	Analysis and materiality matrix ESG Indicators
	102-48	The effect of any restatements of information given in previous reports, and the reasons for such restatements (e.g. mergers or acquisitions, or change of base years or periods, nature of business or measurement methods)	There were no restatements of information in previous reports
	102-49	Changes in reporting	Our approach to reporting
	102-50	Reporting period	Our approach to reporting
	102-51	Date of the most recent report (published)	Our approach to reporting
	102-52	Reporting cycle	Our approach to reporting
	102-53	Contact point for questions regarding the report	Contact
	102-54	Claims of reporting in accordance with the GRI Standards: Core or Comprehensive option	This report has been prepared inaccordance with the GRI Standards: Core option
	102-55	GRI content index	GRI Index
	102-56	Policy and current practice with regard to seeking external assurance for the report	Independent limited assurance statement
MANAGEMENT APPROACH	103
Economic
		Network development
	103-1	Explanation of topics identified as material and their boundaries	Q&A with Piotr Jaworski, Management Board Member in charge of Network and Technology
	103-2	The management approach and its components	Q&A with Piotr Jaworski, Management Board Member in charge of Network and Technology Network
	103-3	Evaluation of the management approach	Q&A with Piotr Jaworski, Management Board Member in charge of Network and Technology Network
		Customer care
	103-1	Explanation of topics identified as material and their boundaries	Q&A with Jolanta Dudek, Vice-President in charge of the Consumer Market
	103-2	The management approach and its components	Q&A with Jolanta Dudek, Vice-President in charge of the Consumer Market
	103-3	Evaluation of the management approach	Q&A with Jolanta Dudek, Vice-President in charge of the Consumer Market
Social
		Digital and caring employer
	103-1	Explanation of topics identified as material and their boundaries	Responsibility: Clear environmental and social targets CSR Strategy: Being responsible
	103-2	The management approach and its components	Responsibility: Clear environmental and social targets Being a digital and caring employer
	103-3	Evaluation of the management approach	Responsibility: Clear environmental and social targets Being a digital and caring employer
		Social and digital development
	103-1	Explanation of topics identified as material and their boundaries	Responsibility: Clear environmental and social targets Being a digital and caring employer
	103-2	The management approach and its components	Responsibility: Clear environmental and social targets Impact on society
	103-3	Evaluation of the management approach	Responsibility: Clear environmental and social targets Impact on society
Environmental
		Towards climate neutrality
	103-1	Explanation of topics identified as material and their boundaries	Responsibility: Clear environmental and social targets Being a digital and caring employer
	103-2	The management approach and its components	Responsibility: Clear environmental and social targets Impact on society
	103-3	Evaluation of the management approach	Responsibility: Clear environmental and social targets
ECONOMIC	200
Market Presence	202
	202-1	Ratios of standard entry level wage by gender compared to local minimum wage	Social data
Indirect Economic Impacts	203
	203-1	Infrastructure investments and services supported	Network Business Market: ICT-centred strategy Society
Anti-corruption	205
	205-1	Operations assessed for risks related to corruption
		All processes are assessed for risks related to corruption, and in case of operations that are burdened with a higher risks of corruption (e.g. joint venture, mergers and acquisition, real estate sales) additional procedures are applied
	205-2	Communication and training about anti-corruption policies and procedures	Social data
	205-3	Confirmed incidents of corruption and actions taken	No incidents
Anti-competitive Behavior	206
	206-1	Legal actions for anti-competitive behavior, anti-trust, and monopoly practices	No incidents
ENVIRONMENTAL	300
Materials	301
	301-1	Materials used by weight or volume	Environmental data
	301-3	Reclaimed products and their packaging materials	#OrangeGoesGreen priorities
Energy	302
	302-1	Energy consumption within the organisation by fuel types used	Environmental data
	302-4	Reduction of energy consumption	#OrangeGoesGreen priorities Task Force on Climate-related Financial Disclosures
	302-5	Reductions in energy requirements of products and services	#OrangeGoesGreen priorities
Water	303
	303-1	Water withdrawal by source	Indicator reported partially. Environmental data
Emissions	305
	305-1	Direct (Scope 1) GHG emissions	Environmental data
	305-3	Other indirect (Scope 3) GHG emissions.	Environmental data
	305-5	Reduction of GHG emissions	Task Force on Climate-related Financial Disclosures Environmental data
Effluents and Waste	306
	306-2	Total weight of waste by type and disposal method	Environmental data
Environmental Compliance	307
	307-1	Monetary value of fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations No fines for non-compliance with environmental laws and regulations were imposed in 2021.
SOCIAL	400
Employment	401
	401-1	New employee hires and employee turnover	Social data
	401-2	Benefits provided to full-time employees that are not provided to temporary or part-time employees	Working place
Occupational Health and Safety	403
	403-9	Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities	Indicator reported partially. Social data Risk management
	403-10	Work-related ill health	No identified
Training and Education	404
	404-1	Average hours of training per year per employee
	404-2	Programmes for upgrading employee skills and transition assistance programmes	Development and training
	404-3	Percentage of employees receiving regular performance and career development reviews by gender and employment category	Social data
Diversity and Equal Opportunity	405
	405-1	Composition of the organisation’s governance bodies and workforce by gender, age and other diversity categories	Supervisory Board activities in 2021 Management Board activities in 2021 Social data
	405-2	Ratio of basic salary and remuneration of women to men by position	Social data
Non-discrimination	406
	406-1	Incidents of discrimination and corrective actions taken	No such incidents were reported to the Ethics Committee in 2021.
Child Labor	408
	408-1	Operations and suppliers at significant risk for incidents of child labor and corrective actions taken	No such risk was identified.
Forced or Compulsory Labor	409
	409-1	Operations and suppliers at significant risk for incidents of forced or compulsory labor and corrective actions taken	No such risk was identified.
Human Rights Assessment	412
	412-2	Employee training on human rights policies or procedures	Social data
Local Communities	413
	413-1	Operations with local community engagement, impact assessments, and development programmes	Economic impact
	413-2	Operations with significant actual and potential negative impacts on local communities
		In case of a telecommunications company, issues related to the safe use of services mean not only utmost care for meeting security requirements, but also reliable information on the devices and technologies used. In response to inquiries regarding potential negative influence of radio waves emitted by telecommunication devices and other devices that use new technologies,we have prepared a global Orange portal on radio waves, which explains in simple terms how mobile telephony works. It includes sections presenting latest scientific reports and recommendations for use of mobile devices to reduce exposure to radio waves. The portal has been also translated to Polish and it is available at https://radio-waves.orange.com
Public Policy	415
	415-1	Total monetary value of financial and in-kind contributions to political parties, politicians or related institutions by country In line with Chapter 7 of the Orange Polska Anti-corruption Guidelines, Orange prohibits all kinds of contributions from the Company (cash, valuable items, goods or services, loans, loan securities) made directly or indirectly to political parties. In the period from 1 January to 31 December 2021, no financial and no in-kind contributions were granted to political parties, politicians or related institutions by country.
Customer Health and Safety	416
	416-1	Assessment of the health and safety impacts of product and service categories	Effortless and friendly customer experience
	416-2	Incidents of non-compliance concerning the health and safety impacts of products and services	No incidents
Marketing and Labeling	417
	417-1	Requirements for product and service information and labeling
		All products in Orange Polska’s portfolio have the relevant labelling, namely: name and address of the manufacturer and operation manual in Polish; CE marking pursuant to the Regulation of the Minister of Infrastructure of 15 April 2004 on the assessment of compliance of telecommunication terminal devices to be connected to public network terminating segments and radio devices with the essential requirements and on marking thereof; the 'basket’ icon pursuant to the Act of 29 July 2005 on waste electrical and electronic equipment; Declaration of Conformity (DoC) pursuant to the Regulation of the Minister of Transport and Construction of 3 February 2006; Specific Absorption Rate (SAR) information pursuant to the Regulation of the Minister of Transport and Construction of 3 February 2006.
	417-2	Incidents of non-compliance concerning product and service information and labeling
		On 14 May and 23 July 2021, UOKiK instituted proceedings regarding practices violating collective interests of consumers in the provision of certain additional services by Orange Polska alleging, among others, insufficient information for consumers in activating the service, lack of information on a durable medium and insufficient replies to customer complaints. On 14 December 2021 and 9 March 2022, UOKiK issued commitment decisions (both without imposing fines) concluding the proceedings instituted on 14 May and 23 July 2021 respectively.
	417-3	Incidents of non-compliance with regulations and/or voluntary codes concerning marketing communications
		In 2021, the appeal proceedings against the penalty imposed by UOKiK in 2017 in the amount of PLN 16.3 million for improper communication to customers on the promotion were completed. The penalty was reduced to PLN 13.0 million, Orange Polska paid a reduced fine.
Customer Privacy	418
		Substantiated complaints concerning breaches of customer privacy and losses of customer data
		The President of the Personal Data Protection Office (UODO) initiated in 2021. 47 new administrative proceedings and sent further inquiries to 75 cases from previous years. The proceedings are related to customer complaints or personal data breach reports sent to UODO. In 27 positives decisions issued in 2021 for Orange the President of UODO confirmed proper processing of personal data by Orange Polska S.A. He also stated that Orange Polska S.A. took actions to minimise the risk of breach of personal data and that the Company complied with the principles set out in the personal data protection regulations, which made it possible to avoid potential breach of privacy charges. At each stage of data collecting and processing, we ensure that customers are informed about the purpose and scope of data processing, as well as their right to access and rectify their personal data. No fines were imposed on the Company for breach of personal data protection regulations in 2021. In 2021, 558 infringement incidents were reported to UODO. In accordance with the new guidelines of UODO, in 2021 we also notified personal data breaches that are the result of customer errors, e.g. when e-mail address provided by the customer is incorrect and therefore the correspondence was sent to the wrong person.
Socioeconomic Compliance	419
	419-1	Non-compliance with laws and regulations in the social and economic area	No incidents

Annual Report 2021

Analysis and materiality matrix

Social data

GRI Content Index

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