Industry standards and self-regulation

The details related to policies, due diligence procedures as well as performance indicators can be found in the chapter Care for the needs of our customers and viewers.

Management approach disclosures

All our activities are undertaken in compliance with the law valid in Poland. In particular we operate in compliance with:

• Telecommunications Law
• Press Law
• Broadcasting Act

Every year, together with its annual report,  Polsat Plus Group publishes a statement concerning observance of corporate governance rules in a given year. Relevant documents for the year 2020 are available for the public on our website.

In Poland the corporate governance rules are found in a document entitled Best Practice for GPW Listed Companies 2016. The purpose of these rules is to consolidate the transparency of listed companies, improve the quality of communication between the companies and the investors, strengthen the protection of shareholders’ rights, also in the areas which are not regulated by the law. Best Practice covers these fields in which implementation of the rules may have positive influence on market valuation of companies, thus reducing the cost of acquisition of capital.

Due diligence procedures

In the case of each company from the Group, it is both the legal departments and the functional units, i.e. the ones which carry out specific business activities, that are responsible for making sure that the operations are conducted in compliance with the law.

Our activities on the telecommunications market (Internet access and mobile telephony) are supervised by the Office of Electronic Communications (UKE), while the activity on the TV market is controlled by the National Broadcasting Council (KRRiT). Representatives of our company regularly participate in the work of Polish and international industry organizations while implementing and promoting the solutions developed by these organizations.

We are the signatory of numerous voluntary industry agreements.

Most important ones include:

• QUALID IAB Polska standards concerning online advertising formats
• Broadcasters’ agreements regarding the principles of dissemination of advertisements and sponsor references regarding food or beverages containing components whose presence in excessive amounts in daily diet is not recommended
• IAB Polska initiative for fair advertising
• Code of best practice regarding the principles of protection of minors in respect of on-demand audio-visual media services
• ” Warsaw Declaration” : International Cooperation Key to Combating Piracy (of TV content in the Internet)
• 5G Strategy for Poland Agreement
• Declaration of Cooperation for the Safety of Children in the Internet.
• IAB Qualid digital advertising quality improvement programme

No dedicated compliance management procedures have been implemented in the Group.

Performance

None of the Group’s companies was penalized for non-compliance with laws and regulations in the social and economic area.

The Internet access service we offer contributes to providing equal opportunities for the inhabitants of cities and rural areas alike. Wireless LTE communication offered by Plus and Cyfrowy Polsat networks reaches both, big cities as well as villages and small towns. Our Internet access service is often the only possibility of getting the connection to the Internet, which reduces the threat of digital exclusion on nationwide scale. In May 2020 Plus launched the first in Poland commercially-operating state-of-the-art 5G network and has been dynamically expanding the coverage of this network ever since while assuring new possibilities in the areas of access to latest solutions and services to individual customers, companies and for the economy. Fixed-line Internet access, based on Netia’s infrastructure, has been available in Plus offer since last year.

Cyfrowy Polsat, while bearing in mind the good of underage viewers and their protection against harmful content, offers parental control which can be activated for specific channels or shows. As regards VOD, we have adopted the “Code of best practice in the field of protection of minors” which was developed by KRRiT jointly with the IAB Polska Association of the Employers of Internet Industry.

TV Polsat understands the particular responsibility associated with the influence that TV, and TV advertising in particular, has on the youngest viewers. A self-regulation document, developed jointly by the TV broadcasters carrying out advertising activities for their own channels as well as for the channels they represent (TV Polsat, Telewizja Polska (TVP), TVN) and by the organizations which associate producers of food supplements (PASMI Employers Association “Polish Union of Non-Prescription Drug Manufacturers, POLFARMED Polish Chamber of the Pharmaceutical Industry and Medical Devices, Polish Council for Supplements and Nutritional Foods (KRSiO), Polish Association of Pharmaceutical Industries (PZPPF)), was signed in the head office of the National Broadcasting Council on 25 November 2019. The essence of this self-regulation document is the universal adoption of the regulations whose observance will, on the one hand, ensure access for users to reliable information on the beneficial effects of supplements which support the organism and, on the other, protect viewers, to even a greater extent than to-date, against advertising messages being too intrusive. The self-regulation took effect on 1 December 2019 and it concerns all food supplement ads which are aired from 1 January 2020.

In addition TV Polsat is a signatory of an agreement protecting children against unhealthy diet which clearly formulates the principles to be observed when approving commercials and sponsor references shown in connection with children’s programs. In accordance with this agreement, all advertisers from the industry must submit statements confirming compliance of their products with the criteria developed by the Polish Federation of Food Industry (PFPZ) and the Nutrition Institute (IŻŻ).

We exceed the standards

Our representatives participate in the activities of work groups of ten industry organizations of which we are members. Participation in the work of these groups is voluntary while the topics addressed by the groups include such items as development of the telecommunication market, regulation of media market and intellectual property protection. We are also a member of the Polish Association of Listed Companies.

Prevention of corruption and bribery

Management approach disclosures

The Group has never permitted and will never give permission for any corrupt practices. Ethics in business has always had very high priority all over our organization – our Code of Ethics covers the Group’s companies. The document defines fair competition, respect for law and ethical behavior.

Due diligence procedures

An internal audit unit operates in Polsat Plus Group (formally it is a division within Cyfrowy Polsat). Moreover, there is an Internal Control Office at Polkomtel while Telewizja Polsat has the Board and Control Office. These units verify whether operations adhere to the procedures and regulations, and they also deal with the issues related to corruption and bribery in sensitive areas of the organization. Every suspicion of corrupt practices is examined meticulously and if our suspicions are confirmed, then we definitely end our cooperation with a given individual or firm.

In the case of Telewizja Polsat, prevention of corruption and bribery is an element of the duties of the legal department which is responsible for assuring that the adopted ethical norms are observed by the employees.

No dedicated due diligence procedures associated with prevention of corruption exist in the Capital Group.

Performance

No incidents having the nature of corrupt practices were noted in Cyfrowy Polsat  Capital Group in 2019 and 2020.

Principles of free competition

No incidents involving behavior violating the freedom of competition or the anti-trust regulations occurred in Cyfrowy Polsat in 2020.

In 2020 the President of the Office of Competition and Consumer Protection did not discover any events infringing upon the freedom of competition in Polkomtel.

No incidents of anti-competitive behavior or monopolistic practices occurred in TV Polsat.

Nevertheless, the company was sued, in connection with a commercial offer submitted to cable TV operators for re-broadcasting of programs of Polsat Plus Group for alleged infringement of principles of fair competition consisting in restricting access to the market. TV Polsat filed for the dismissal of the lawsuit in all cases filled by the cable TV operators and until the date of approval of this report no ruling has been issued in any of the cases.

Moreover Telewizja Polsat was sued by P4 Sp. z o.o.,  the operator of Play mobile network, on account of alleged, so-called “indirect advertising” of Plus mobile network services. Also in this case no final ruling has been issued yet.

Management approach disclosures

In each of the companies who are members of  Cyfrowy Polsat Capital Group the employee affairs are regulated by the valid Work Regulations.

We try to make sure that the policies that we use inside the organization reflect the valid standards. This rule also applies to our Work Regulations. Human Resources Policy operates in Polsat Plus Group. The main purpose of the policy is to build an attractive working environment for the existing and potential employees. The document has been based on the solutions that have been working finely in Polkomtel, Cyfrowy Polsat and Telewizja Polsat, and it has been used to align the understanding of the principles of staff management with the values adopted by the Group.

Due diligence procedures

The Human Resources Policy regulates the process of hiring of new staff, their adaptation, the offered terms of employment and organizational culture, competence development, freedom of association.

We offer fair remuneration to our employees, depending on the type of their duties, scope of responsibilities and complexity of their tasks. The boundary levels of remuneration at individual employment levels/positions are defined by the Remuneration Regulations, while the minimum remuneration level offered by the Group complies with the regulations of Polish law. A common system of HR and payroll support exists across the whole Group, thanks to which the procedures, processes and data are consistent in the whole organization.

Performance

The following performance indicators have been adopted to assess performance:

• GRI 102-8 Information on employees and other workers,
• GRI 102-41 Collective bargaining agreements,
• GRI 405-1 Diversity of governance bodies and employees,
• GRI 403-2 Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities,
• GRI 403-3 Workers with high incidence or high risk of diseases related to their occupation,
• GRI 403-4 Health and safety topics covered in formal agreements with trade unions,
• GRI 404-1 Average hours of training per year per employee,
• GRI 404-3 Percentage of employees receiving regular performance and career development reviews,
• GRI 405-2 Ratio of basic salary and remuneration of women to men

Respect for human rights

The details related to policies, due diligence procedures as well as the performance indicators can be found in the chapter: “Success thanks to the people”.

Management approach disclosures

In Poland the respect for human rights is effectively enforced by Polish law. Forced labor or employment of minors are not the practices to which our business is exposed.

 Polsat Plus Group has implemented the Diversity and Human Rights Respect Policy. We support the Universal Declaration of Human Rights and the Declaration of the International Labor Organization. The fundamental principles and rights stipulated by these declarations have been incorporated into the Code of Ethics and the Human Resources Policy of  Polsat Plus Group.

By virtue of other regulations and codes (e.g. the Work Regulations or the Regulations of the Anti-Mobbing Committee), the Group’s companies are obligated to protect their employees against any act of physical, verbal or psychological harassment; abuse, humiliation or threats coming from either the co-workers or the superiors with respect to the below listed dimensions of diversity: sex, age, sexual orientation, competence, experience, potential degree of disability, nationality, ethnic and social origin, color of skin, communication language, parental status, religion, denomination or lack of any denomination, political views or any other dimensions of diversity which are defined by valid law.

Due diligence procedures

An Internal Anti-Mobbing Committee has been appointed in Cyfrowy Polsat and Polkomtel as an element of the Anti-Mobbing Policy. The Committee is responsible for reviewing the complaints related to occurrence of mobbing. To familiarize our employees with the topic, as well as to make them aware of potential threats and the rights they have, regular mandatory training is carried out for the employees with regard to this topic via our e-learning platform. In the case of Telewizja Polsat, acts having the nature of mobbing are covered by the Anti-Mobbing Procedure which is an internal document of that company.

No dedicated procedures aimed at assuring respect for human rights have been adopted in Polsat Plus Capital Group.

Performance

No complaints regarding alleged mobbing behavior were received by the Anti-Mobbing Committee of Polkomtel in 2020. No complaints regarding alleged mobbing behavior were received by the Anti-Mobbing Committee of Cyfrowy Polsat in 2020.

One complaint regarding alleged mobbing behavior was received by the Anti-Mobbing Committee of TV Polsat in 2020. The case was resolved.

Activities for the society (community)

The details related to the policies, due diligence procedures as well as result indicators can be found in the chapter: “Digital responsibility”.

Due diligence procedures

Due and compliant with the statute performance of POLSAT Foundation’s activities is supervised by the Foundation’s Board. Since November 2016 the Board has had 8 members. The Board’s members include the following:

• Małgorzata Nawrocka
• Katarzyna Ostap-Tomann
• Nina Terentiew-Kraśko
• Józef Birka
• Mirosław Błaszczyk
• Paweł Januszewicz
• Aleksander Myszka
• Tobias Solorz

The Foundation’s activities are supervised by the Minister of Health.

Performance

• GRI 203-1 Infrastructure investments and services supported
• GRI 203-2 Significant indirect economic impacts

We exceed the standards

Our definition of social responsibility:

In  Polsat Plus Group we see and understand the huge impact that our services have on communities. The pillars of our activities for the benefit of society are:

For this reason our Capital Group cooperates with rescue services – WOPR, MOPR, TOPR and GOPR, makes donations and supports Polsat Foundation, supports amateur and professional sports events and promotes physical activity among the society, while also working to prevent digital exclusion and spreading the knowledge about ecology, including in cooperation with the Clean Poland Program Association.

Environmental impact

The details related to policies, due diligence procedures as well as result indicators can be found in the chapter: “Environment-friendly Group”.

Management approach disclosures

All our activities are undertaken while observing the legal order valid in Poland. Our Group operates in compliance with the following laws:

• Environmental Protection Act dated 27 April 2001, 
• Waste Management Act dated 14 December 2012, 
• Waste Electrical and Electronic Equipment Act dated 29 July 2005, 
• Packaging Waste Management Act dated 13 June 2013, 
• Waste Batteries and Accumulators Act dated 24 April 2009

Due diligence procedures

Environmental goals have existed in Polkomtel since 2012. Their observance has become an important element of the Company’s strategy. The Company’s ecological targets include:

• introduction to the market only of these products which meet the relevant norms and regulations,
• achieving the levels of salvaging and recycling of electrical and electronic equipment, batteries and accumulators as well as packaged products which are not lower than the levels required by the law,
• sale of electricity generated from renewable sources of energy, gas burning or cogeneration in the amounts not lower than required by the law,
• rational and thrifty management of electrical energy,
• restriction of the negative environmental impact of other essential factors affecting the natural environment.

In addition, our InterPhone Service set-top box factory holds the following certificates: ISO 9001:2015 and ISO 14001:2015 in the field of design and manufacturing of electronic equipment as well as PN-N-18001:2004 standard in the field of design and manufacturing of electronic equipment which was issued by BSI – British Standards Institution, while Polkomtel conforms with ISO 9001:2015 and ISO 14001:2015 standards. Details regarding ISO certificates are presented in the chapter Environment-friendly Group.

Performance

The following indicators have been adopted to assess performance:

• GRI 301-1 Materials used by weight and volume,
• GRI 302-1 Energy consumption within the organization,
• GRI 306-1 Water discharge by quality and destination,
• GRI 306-2 Waste by type and disposal method,
• GRI 302-4 Reduction of energy consumption.

We exceed the standards

We strive to make sure that every set-top box manufactured in Polsat Plus Group’s factory is packed only in recycled packaging. In addition, while caring for organizational efficiency, costs and protection of natural environment, we take care that the trucks and vans transporting the equipment and other materials to the sales network are loaded in an optimum manner, which enables reduction of emission of carbon dioxide into the atmosphere.

The documents which are intended for reprocessing at Cyfrowy Polsat are destroyed in a special heavy duty shredder. The output is successively shipped as waste paper for recycling to the company with whom Cyfrowy Polsat has a relevant contract.

At Cyfrowy Polsat we conduct continuous collection of waste paper and segregation of waste (e.g. waste toner cartridges). We support good habits which, taking into account the size of the company and the number of people employed, bring tangible changes:

• we use two-sided copying and printing,
• we switch off the lights when leaving a room,
• we use the stand-by mode on computers while they are on,
• we disconnect chargers once battery charging ends,
• we use water rationally and are conscientious when using air-conditioning,
• we no longer use disposable plastic cups and plates.